Recently, researchers have attempted to export research materials abroad. The Federal Bureau of Investigations (FBI) and other federal law enforcement agencies have increased their surveillance efforts to identify transport of research materials and verify that those exports comply with federal laws. These efforts are part of a nationwide enforcement to control the transport of biological materials that may present a threat to our national security or reduce the theft of intellectual property developed in the U.S., much of it with federal funds.

Transporting certain materials may require import/export permits or other documentation from federal agencies, including U.S. Customs and Border Protection, the Food and Drug Administration, the U.S. Department of Agriculture, Fish and Wildlife, and the Centers for Disease Control and Prevention.

At WSU, the total annual outgoing shipments from Pullman has grown considerably in the past 10 years. In 2010, 155 outgoing shipments were made from WSU Pullman, as shipped by the hazardous material specialists. In 2019, that number grew to 883 outgoing shipments. The shipping program has grown an average of 13.1 percent annually over 10 years.

Hazardous materials and dangerous goods require specific packaging, labeling, and documentation for transport. Federal and international authorities closely monitor shipments of hazardous materials or dangerous goods, including diagnostic specimens and infectious substances.

Anyone shipping hazardous material must have documented training. Such shipments include diagnostic specimens from humans or animals, or cultures of substances infectious to humans and/or animals. Materials must be properly classified. Regulatory provisions must be met prior to shipment, including export control review requirements for international packages.

Training required for all hazardous material shippers

Before you prepare, package, mark, or label a shipment for a hazardous material or dangerous good, you must be trained in accordance with U.S. Department of Transportation requirements [49 CFR 173.1(3)(b)].

Hazardous materials and dangerous goods must be shipped by an employee who has been trained in accordance with U.S. Department of Transportation of ground shipments and International Air Transport Association (IATA) for air shipments regulations.

In Pullman, the Office of Research Assurances maintains trained staff who pick up and ship all hazardous materials originating at the Pullman campus. Trained shipping personnel are available at other WSU campuses and extension offices. Contact the trained shipping coordinator at your site.

Anyone who ships dangerous goods and hazardous materials, including infectious substances, from any WSU location must have first completed approved training. The U.S. Department of Transportation recommends a 34-hour ground shipping course and a 24-hour air transportation course. Ground shipping personnel are required to take a refresher training course every three years per Department of Transportation regulations. Air shipment personnel are required to take a refresher training course every two years per IATA regulations.

It is the responsibility of the supervisor to ensure that the hazardous materials shipping coordinator has received adequate training related to their job functions. In accordance with 49 CFR 172 Subpart H, the employer or supervisor must certify that the shipper’s training is appropriate for the types of shipments their employees offer into commerce. The shipper’s supervisor is accountable for any non-compliance issues that may result from inadequate training. Therefore, when identifying training options for the hazardous materials shipping coordinator, the supervisor is encouraged to contact ORA for guidance.

Instructions for shipping hazardous materials and dangerous goods

Anyone shipping hazardous material must have documented training. Such shipments include diagnostic specimens from humans or animals, or cultures of substances infectious to humans and/or animals. Materials must be properly classified. Regulatory provisions for shipment must be met prior to shipment, including export control review requirements for international packages.

In Pullman, every package that goes out of WSU Pullman requires a Request for Shipment of Merchandise form. Request shipping services from Central Receiving by completing the form. It is available online through the WSU e-forms system. See instructions for completion in the WSU Business Policies and Procedures Manual, 80.15.

In Spokane, use the Shipping Request Form. Take all laboratory research packages to the research laboratory manager for inspection and approval prior to shipping.

In Tri-Cities, use the Request for Shipment form provided by the Copy/Mail Center.

In Vancouver, obtain shipping forms from the mailroom.

In Everett, no forms are required.

For all extension offices, obtain shipping forms from the mailroom.

Consequences of non-compliance

Failure to comply with regulations for shipping hazardous materials and dangerous goods may result in any of the following:
• Increased risk of material release during the shipping process
• Refusal or return of packages, particularly problematic with temperature-sensitive materials
• Fines with the U.S. Department of Homeland Security
• Up to 10 years of imprisonment and $1 million in fines for export control violations.

Ultimately, you are responsible for understanding and complying with the U.S. Department of Transportation and the ITAR regulations when shipping hazardous and dangerous materials. For more information, contact the Office of Research Assurances or visit https://ora.wsu.edu/.