DATE: Reissued April 28, 1997
TO: All Chemistry Department Lab Personnel
FROM: Safety Committee
SUBJECT: Guidelines for Transport of Hazardous Materials in Lederle Graduate Research Tower

(1) The FNSM Lederle Graduate Research Tower Safety Committee, in order to facilitate the safe transport of hazardous materials between floors within the Tower, recommends that transportation of substantial amounts of hazardous materials between floors in the Tower must be carried out either by use of the dumbwaiter elevator, or by obtaining in advance through the Director of Operations the key needed to allow key-operation of the main LGRT passenger elevators. Large amounts of hazardous substances effectively may be defined as any amount that may not be transported conveniently by a single person without the use of a wheeled cart or similar transportation aid. An example of the movement of a large amount of hazardous substances would be the movement of a large number of chemical or biological reagents from one floor to another on a push-cart, with the bottles or flasks of reagents not all being protected by safe secondary containment. We recommend that large amounts of hazardous substances should be transported by use of the keyed mode of the main LGRT freight elevator, with only trained research or EH & S personnel allowed on the elevator. Workers transporting large amounts of materials should warn anyone else wanting to get on the elevator that hazardous materials are being transported. Proposed guidelines for enabling general use of the dumbwaiter are contained on the accompanying memo. The remainder of this memo will be restricted to discussion of use of the LGRT passenger elevator, for those occasions where use of the dumbwaiter is unavailable or inappropriate.

(2) Hazardous materials include ( not necessarily exclusively) any chemical or biological reagents contained in glass or other potentially breakable containers, large cylinders of cryogenic gases, and shipments of multiple high-pressure bottled gases. Radioactive hazardous materials of any activity must be transported upon the passenger elevators, with adequate secondary containment as defined under appropriate EH & S guideline-- under no circumstances should any radioactives be transported on the dumbwaiter at any time!! Small amounts of moderately hazardous materials and small amounts of moderately radioactive materials may be transportable on the passenger elevators under conditions noted in the following paragraph, (4).

(3) Under no circumstances should open containers of hazardous materials ever be transported on the elevators, regardless of whether others besides the transporting person are present to be harmed. All research reagents may be considered hazardous for ease of definition, and should be transported with secondary containment.

(4) Small amounts of moderately hazardous material would be any amount that would easily be carried by a single person. Examples would include transport of a small number of glass containers of chemicals and reagents, or of a single moderate sized bottle. Transportation of such materials could be carried out by placing the bottles in secondary containment, such as a plastic pail and covered on top with a well-attached cover--for small bottles that may rattle in a pail, extra packing material such a vermiculite may be desirable. It is very easy and cheap to provide one or two such containers for any active lab, of a size simultaneously easy to carry and sufficient to contain most single containers of reagents. Transportation of open beakers or flasks of any reagent, no matter how presumably innocuous, is not permitted. Spillage or breakage is always a potential hazard when glass containers are placed on an open pushcart without a secondary container.

(5) A bottle of reagent inside a secondary unopened metal can or container would be considered safely contained for transport on the elevator. Transportation of large numbers of empty, but breakable containers (e.g., glass flasks) on the passenger elevators would not constitute movement of hazardous materials, but should only be carried out if the flasks are in a secondary container such as a box or a cart with side-rail, that will prevent their being tipped off the cart and broken. Alternatively, the dumbwaiter may be used for transport of modest amounts of glassware.

(6) Radioactive material require extreme care, even if the worker involved does not consider them dangerous. All radioactives should be transported with secondary containment, such as a plastic pail with absorbent material on the bottom and a closely-fitted cover. If such a container tips over, or the container inside breaks, no harm is done, and no public fears are aroused. For this reason, no radioactive materials of any description are ever allowed in the dumbwaiter, since this facility is not under constant scrutiny for breakage and spills . It requires almost no money and very little effort to put radioactive substances in secondary containment for interfloor transportation. There is absolutely no acceptable excuse for not doing so in a modern professional laboratory.

(7) Individual cases of transport may require some definition in discussion with trained personnel in individual departments, and in Environmental Health and Safety. In particular, EH & S has clearly communicated that is stands ready to provide data on any aspect of hazardous material transport, such as where to get affordable containers and carts for transportation of materials. It is important that we as scientists in this public-accessible LGRT building do our best, not only to make the public safe in fact, but to make the public feel safe when going about business in the building. This memo is not meant to represent a final policy, but to be part of evolving starategies toward rational, safe interfloor transport of hazardous materials in a public building where the movement of untrained personnel is typical, and where steps must be taken to protect these personnel from potential hazards and fears associated with such transport.