{"operation":"document","citation":"07-0076R","title":"Natural History Museum Of Los Angeles County — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2007-08-02","effective_on":null,"summary":"07-0076R response to Natural History Museum Of Los Angeles County; Natural History Museum of Los Angeles County concerning 172.101, 173.120.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0076r.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0076r.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0076r","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2007/070076.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nWashington, D.C. 20590\n400 Seventh Street, S.W.\nHazardous Materials Safety\nPipeline and\nAdministration\nJUN 2 8 2007\nMr. Leonard M. Navarro\nChief Deputy Director\nRef. No.: 07-0076\nNatural History Museum\n900 Exhibition Boulevard\nOf Los Angeles County\nLos Angeles, California 90007\nDear Mr. Navarro:\nThis responds to your letter dated March 28, 2007, regarding the Hazardous Materials\nRegulations (HMR; 49 CFR Parts 171-180) as they apply to the transportation of fluid\npreserved museum research specimens. Specifically, you ask if those invertebrate stored\nand shipped in 70% ethanol solution, a standard practice in natural history museum\ncollections worldwide, are subject to the HMR.\nThe Vertebrate and Invertebrate sections within the Research and Collections Division at\nthe Natural History Museum of Los Angeles County (LACM) maintain a collection of\nand other invertebrates. Many of your specimens are \"dry\" (skeletons, empty shells,\nover 30 million specimens of mammals, birds, amphibians and reptiles, fishes, insects,\npinned insects, etc.); however, a significant number are fluid preserved (70% ethanol\nspecimens are removed from storage containers and wrapped in paper towels and/or\nThe museum's current shipping procedures involve the following procedures. The large\nspecimens are sealed in 4 mil plastic bags (two layers) with a heat sealer, and then sealed\ncheesecloth moistened with ethanol to prevent desiccation during transit. The wrapped\ninside a third plastic bag with an appropriate amount of absorbent material. The small\nspecimens in shell vials containing less than 30 ml of ethanol are sealed in the same\nabsorbers the era Perimens of pacting mers of liais may be individially seid bur\nthere is little or no visible free flowing liquid. Sealed containers are then packed into :\npacked together in the same bagging procedure. After sealing in the two plastic bags\ncardboard box with a plastic liner filled with Styrofoam packing (peanuts).\nA material described as \"Ethanol solutions, UN 1170\" is classed as a Class 3 (flammable\nliquid) and is subject to the HMR for purposes of transportation in commerce. Although,\n172-101F\n173.120 (d)\n070076\n\n<<<PAGE 2>>>\n\nthe paper towel and/or cheesecloth-wrapped specimens are moistened with ethanol to\nrotect specimens from damage, it is the opinion of this Office that the packagin\nrocedures and methods you use for shipment of the fluid preserved dry specimens\nunder the HMR.\nI hope this satisfies your inquiry. If we can be of further assistance, please contact us.\nSincerely,\nChief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nNatural History\nEngrum\nof Los Angeles County\n3173.120 (d)\n900 Exposition Boulevard • Los Angeles, CA 90007\n$172.101F\nMarch 28, 2007\nApplicability\nMr. Edward T. Mazzullo\n07-0076\nDirector, Office of Hazardous Materials Standards\n400 7'h St. SW Rm.8422\nUnited States Department of Transportation/RSPS (DHA-10)\nWashington D.C. 20590-0001\nDear Mr. Mazzullo:\nmuseum research specimens. By providing you with technical information and an outline of our\nWe are writing to obtain a letter of interpretation concerning the shipment of fluid preserved\nthe Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).\ncurrent shipping procedures, you can determine whether we are subject to the requirements of\nThe Vertebrate and Invertebrate sections within the Research and Collections Division at the\nNatural History Museum of Los Angeles County (LACM) maintain a collection of over 30\nmillion specimens of mammals, birds, amphibians and reptiles, fishes, insects and other\ninvertebrates. This ranks the LACM collections as among the largest in the world. Many of our\nnumber are stored in a 70% ethanol solution (\"fluid-preserved\" specimens), a standard practice\nspecimens are \"dry\" (skeletons, empty shells, pinned insects, etc.); however, a significant\nin natural history museum collections worldwide.\nMuseum collections exist, in part, to offer the scientific community an opportunity to study\nspecimens collected decades (or even centuries) ago, to answer questions about biodiversity,\nnot unlike a library; although instead of books, we have beetles, snails, fishes, and lizards. Just\necology, genetics, evolution, and virtually every aspect of natural history. These collections are\nas a library loans out its books, we loan our specimens to researchers worldwide. This process\nis unique and irreplaceable), but with careful packing procedures damage can be avoided. My\ninvolves great care and effort to ensure our specimens are not damaged in transit (each specimen\nquestion relates to the applicability of the HMR to our shipping procedures, specifically those\nutilized for fluid-preserved specimens.\nCurrent shipping procedures involve the following process. For large specimens, the animal is\nremoved from its storage container and wrapped in paper towels and/or cheesecloth moistened\nwith ethanol to prevent desiccation during transit. Wrapped specimens are then sealed in 4 mil\nplastic bags (two layers) with a heat sealer, and then sealed inside a third plastic bag with an\nml of ethanol are sealed in the same manner as large specimens (i.e., two layers of plastic in a\nappropriate amount of absorbent material. Small specimens in shell vials containing less than 30\nthird plastic bag with absorbent material). For ease of packing, multiple small vials may be\nthe two plastic layers there is little or no visible liquid in the bags. Sealed containers are then\nindividually sealed but packed together in the same bagging procedure. Note that after sealing in\n\"peanuts.\"\npacked into a sturdy cardboard box that has a plastic liner filled with styrofoam packing\n\"...to inspire wonder. discovery and responsibility\nfor our natural and cultural worlds.\"\n\n<<<PAGE 4>>>\n\nMr. Edward T. Mazzullo\nMarch 28, 2007\nPage 2\nPacking is of the utmost importance to us because specimens can sustain significant, permanent\ndamage if allowed to dry out. Thus, we take great care to ensure their safety during transit.\nBased on our current shipping procedures as described above, is LACM subject to the\nrequirements of the HMR if we need to ship fluid-preserved specimens from our collection? If\nfurther information is required in order to make this determination, please feel free to contact me\nat (213) 763-3545.\nThank you very much for your time and I look forward to your response.\nSincerely,\nwwsM.i\nLeonard M. Navarro\nNatural History Museum of Los Angeles County\nDeputy Director, Administration & Operations\nImn:gc\nc: Jural J. Garrett, Chief Deputy Director\nMargaret Hardin, Acting Deputy Director, R&C","truncated":false,"body_characters":6666}