Bert and other Histonetters:

There is a little known ruling by DOT that dates back to 1995 stating that
10% Formaldehyde solutions by air have to be treated as a Class 9 hazard
within the US even though it does not meet the IATA definitions of a
dangerous good.  So, if you're planning on shipping via FedEx or other air
carrier (including USPS) then you should declare the formalin as a Dangerous
Good.  It requires packing group 3 packaging and the proper shipping
description is "Other Regulated Substances, liquid, n.o.s., (formaldehyde),
9, NA3082, III.

The determination was made at the request of a company who manufactures
dangerous goods packaging.  As recently as 10 months ago we checked with DOT
to see if the ruling is still in force and we were told that it
is...although not widely published.

So, even if the tissue might be exempt as a dangerous good (under the
proposed CDC rulemaking) the formalin is not.  If you have any questions
give me a call.

Linda E. Durbin
EXAKT Technologies, Inc.
7416 N. Broadway Ext., Ste. E
Oklahoma City, OK  73116
Tel:  800.866.7172
Fax:  405.848.7701



-----Original Message-----
From: Bert Dotson [mailto:amdj@duke.edu]
Sent: Friday, April 21, 2000 3:42 PM
To: HistoNet@pathology.swmed.edu
Subject: Re: Formalin in the mail


I'm sure it's becoming increasingly difficult to comprehend the US 
regulatory apparatus, but when mailing specimens, OSHA is the least of your 
worries. You are adding DOT, PHS, USPS and possibly IATA to your alphabet 
soup mix. The most comprehensible summary of these regs is available free 
of charge simply by calling Federal Express and asking for their 
information on shipping hazardous goods and diagnostic specimens. The most 
comprehensive review is in NCCLS H5-A3.

For simplicity sake assume you are mailing less than 50 mls, of formalin 
with a small tissue specimen within the US. This doesn't meet the 
qualifications for a "dangerous good" so we can set IATA aside. You need a 
primary container to withstand leakage, a secondary container to withstand 
leakage. and a final outer packaging (sturdy tube or box). To ensure that 
you don't have any problems, you can fill the secondary container with 
paper towels or gauze or (even better) formalin neutralizing padding 
capable of absorbing the entire contents of the primary container. This 
last bit is generally not required, but the definitions are just vague 
enough that others could argue your 50ml hazardous good shipment fits a 
more dangerous category.

PHS 42 CFR 72 and DOT 49 CFR 171 are the major regulations governing this 
activities. The Post office "domestic mail manual" can also be of some 
help.

Bert Dotson

-----Original Message-----
From:	Tammy Bird [SMTP:VVTBird@ihc.com]
Sent:	Thursday, April 20, 2000 8:13 PM
To:	HistoNet@pathology.swmed.edu
Subject:	Formalin substutite

I know this subject has been discussed into the ground, but recently I
have been ask about OSHA standards for sending formalin through the
mail.  Sending specimens with formalin on them.  Does anyone know
anything about OSHA requirements and what substitutes are accepatable
and still do a good job of fixing?

Thanks for any help you can give.
Tammy