Interpretation Response #05-0139 ([The Field Museum] [Ms. Jolynn Willink ])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: The Field Museum
Individual Name: Ms. Jolynn Willink
Location State: IL Country: US
View the Interpretation Document
Response text:
Aug 9, 2005
Ms. Jolynn Willink Reference No. 05-0139
Safety and Benefits manager
Department of Human Resources
The Field Museum
1400 S. Lake Shore Drive
Chicago, Illinois 60605-2496
Dear Ms. Jolynn:
This responds to your letter dated June 6, 2005 regarding the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180) as they apply to the shipment of zoology specimens. Specifically, you ask if the “dry” specimens (skeletons, skins, pinned insects) stored in 70% ethanol solution (fluid-preserved specimens) are subject to the HMR. You provided information, as follows:
The Zoology Department of the Field Museum maintains a collection of over 18 million specimens of mammals, birds, fishes, insects and other invertebrates, and amphibians and reptiles. The museum loans its specimens to researchers world-wide, and, to ensure the specimens are not damaged in transportation, each specimen is carefully packed.
The museum’s current shipping procedure is a two-step process. The specimens are removed from their storage jars and wrapped in cheesecloth moistened with ethanol to protect the specimen from drying out. The cheesecoth-wrapped specimens are then placed into a plastic bag that is closed with a heat sealer. This bag is then heat-sealed inside a second bag, which is then heat-sealed inside a third bag, with sufficient absorbent material. There is no visible or free-flowing liquid at the time they are sealed. The bags are then packed in cardboard boxes and cushioned with styrofoam packing (peanuts).
A material described as “Ethanol solutions, UN1170” is classed as a Class 3 (flammable liquid), and is subject to the HMR for purposes of transportation in commerce. Although the cheesecloth-wrapped specimens are moistened with ethanol to protect the specimens from drying out, it is our opinion that the packaging procedures and methods you use for shipment of the dry specimens mitigate the minimal hazard that may be present during
transportation. Therefore, in accordance with § 73.120(d), shipments of the zoology
specimens preserved in ethanol that are packaged as described above are not subject to regulation under the HMR.
I hope this satisfies your inquiry. If we can be of further assistance, please contact us.
Sincerely,
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
172.101F