Natural History Museum Of Los Angeles County — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Washington, D.C. 20590 400 Seventh Street, S.W. Hazardous Materials Safety Pipeline and Administration JUN 2 8 2007 Mr. Leonard M. Navarro Chief Deputy Director Ref. No.: 07-0076 Natural History Museum 900 Exhibition Boulevard Of Los Angeles County 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 and other invertebrates. Many of your specimens are "dry" (skeletons, empty shells, over 30 million specimens of mammals, birds, amphibians and reptiles, fishes, insects, pinned insects, etc.); however, a significant number are fluid preserved (70% ethanol specimens are removed from storage containers and wrapped in paper towels and/or The museum's current shipping procedures involve the following procedures. The large specimens are sealed in 4 mil plastic bags (two layers) with a heat sealer, and then sealed cheesecloth moistened with ethanol to prevent desiccation during transit. The wrapped 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 absorbers the era Perimens of pacting mers of liais may be individially seid bur there is little or no visible free flowing liquid. Sealed containers are then packed into : packed together in the same bagging procedure. After sealing in the two plastic bags 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, 172-101F 173.120 (d) 070076#

Page 2the paper towel and/or cheesecloth-wrapped specimens are moistened with ethanol to rotect specimens from damage, it is the opinion of this Office that the packagin rocedures and methods you use for shipment of the fluid preserved dry specimens under the HMR. I hope this satisfies your inquiry. If we can be of further assistance, please contact us. Sincerely, Chief, Standards Development Office of Hazardous Materials Standards#

Page 3Natural History Engrum of Los Angeles County 3173.120 (d) 900 Exposition Boulevard • Los Angeles, CA 90007 $172.101F March 28, 2007 Applicability Mr. Edward T. Mazzullo 07-0076 Director, Office of Hazardous Materials Standards 400 7'h St. SW Rm.8422 United States Department of Transportation/RSPS (DHA-10) Washington D.C. 20590-0001 Dear Mr. Mazzullo: museum research specimens. By providing you with technical information and an outline of our We are writing to obtain a letter of interpretation concerning the shipment of fluid preserved the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). current shipping procedures, you can determine whether we are subject to the requirements of 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. This ranks the LACM collections as among the largest in the world. Many of our number are stored in a 70% ethanol solution ("fluid-preserved" specimens), a standard practice specimens are "dry" (skeletons, empty shells, pinned insects, etc.); however, a significant in natural history museum collections worldwide. Museum collections exist, in part, to offer the scientific community an opportunity to study specimens collected decades (or even centuries) ago, to answer questions about biodiversity, not unlike a library; although instead of books, we have beetles, snails, fishes, and lizards. Just ecology, genetics, evolution, and virtually every aspect of natural history. These collections are as a library loans out its books, we loan our specimens to researchers worldwide. This process is unique and irreplaceable), but with careful packing procedures damage can be avoided. My involves great care and effort to ensure our specimens are not damaged in transit (each specimen question relates to the applicability of the HMR to our shipping procedures, specifically those utilized for fluid-preserved specimens. Current shipping procedures involve the following process. For large specimens, the animal is removed from its storage container and wrapped in paper towels and/or cheesecloth moistened with ethanol to prevent desiccation during transit. Wrapped specimens are then sealed in 4 mil plastic bags (two layers) with a heat sealer, and then sealed inside a third plastic bag with an ml of ethanol are sealed in the same manner as large specimens (i.e., two layers of plastic in a appropriate amount of absorbent material. Small specimens in shell vials containing less than 30 third plastic bag with absorbent material). For ease of packing, multiple small vials may be the two plastic layers there is little or no visible liquid in the bags. Sealed containers are then individually sealed but packed together in the same bagging procedure. Note that after sealing in "peanuts." packed into a sturdy cardboard box that has a plastic liner filled with styrofoam packing "...to inspire wonder. discovery and responsibility for our natural and cultural worlds."#

Page 4Mr. Edward T. Mazzullo March 28, 2007 Page 2 Packing is of the utmost importance to us because specimens can sustain significant, permanent damage if allowed to dry out. Thus, we take great care to ensure their safety during transit. Based on our current shipping procedures as described above, is LACM subject to the requirements of the HMR if we need to ship fluid-preserved specimens from our collection? If further information is required in order to make this determination, please feel free to contact me at (213) 763-3545. Thank you very much for your time and I look forward to your response. Sincerely, wwsM.i Leonard M. Navarro Natural History Museum of Los Angeles County Deputy Director, Administration & Operations Imn:gc c: Jural J. Garrett, Chief Deputy Director Margaret Hardin, Acting Deputy Director, R&C#