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Interpretation Response #07-0076 ([Natural History Museum of Los Angeles County] [Mr. Leonard M. Navarro])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Natural History Museum of Los Angeles County

Individual Name: Mr. Leonard M. Navarro

Location State: CA Country: US

View the Interpretation Document

Response text:

Jun 28, 2007


Mr. Leonard M. Navarro                 Reference No. 07-0076
Chief Deputy Director
Natural History Museum
  Of Los Angeles County
900 Exhibition Boulevard
Los Angeles, California 90007

Dear Mr. Navarro:

This responds to your letter dated March 28, 2007, regarding the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they apply to the transportation of fluid preserved museum research specimens. Specifically, you ask if those invertebrate stored and shipped in 70% ethanol solution, a standard practice in natural history museum collections worldwide, are subject to the HMR.

The Vertebrate and Invertebrate sections within the Research and Collections Division at the Natural History Museum of Los Angeles County (LACM) maintain a collection of over 30 million specimens of mammals, birds, amphibians and reptiles, fishes, insects, and other invertebrates. Many of your specimens are “dry” (skeletons, empty shells, pinned insects, etc.); however, a significant number are fluid preserved (70% ethanol solution).

The museum’s current shipping procedures involve the following procedures. The large specimens are removed from storage containers and wrapped in paper towels and/or cheesecloth moistened with ethanol to prevent desiccation during transit. The wrapped specimens are sealed in 4 mil plastic bags (two layers) with a heat sealer, and then sealed inside a third plastic bag with an appropriate amount of absorbent material. The small specimens in shell vials containing less than 30 ml of ethanol are sealed in the same manner as the large specimens (i.e., two layers of plastic in a third plastic bag with absorbent material). For ease of packing, multiple vials may be individually sealed but packed together in the same bagging procedure. After sealing in the two plastic bags, there is little or no visible free flowing liquid. Sealed containers are then packed into a cardboard box with a plastic liner filled with Styrofoam packing (peanuts).

A material described as “Ethanol solutions, UN 1170” is classed as a Class 3 (flammable liquid) and is subject to the HMR for purposes of transportation in commerce. Although, the paper towel and/or cheesecloth-wrapped specimens are moistened with ethanol to protect specimens from damage, it is the opinion of this Office that the packaging procedures and methods you use for shipment of the fluid preserved dry specimens to prevent desiccation mitigates the minimal hazard that may be present during transportation. Therefore, in accordance with § 173.120(d), shipments of invertebrate preserved in ethanol for research and collection purposes are not subject to regulation under the HMR.
I hope this satisfies your inquiry. If we can be of further assistance, please contact us.



John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards

172.101 F, 173.120 (d)

Regulation Sections

Section Subject
173.120 Class 3-Definitions