Department of Health Seal

TGM for the Implementation of the Hawai'i State Contingency Plan
Section 11.4
SAMPLE SHIPPING

11.4 SAMPLE SHIPPING

Upon completion of sample collection, shipment of samples to an analytical laboratory is typically required. This may include transport from an outer island to an O`ahu-based laboratory or transport to a mainland laboratory. Properly pack the shipping containers to protect the individual sample containers, maintain the samples at temperature, and comply with all applicable transportation regulations.

Chain-of-custody forms are typically placed inside a sealed bag and adhered to the interior of the shipping container. The shipping paperwork is adhered to the outside of the shipping container and the container sealed for shipment. Shipping paperwork need only be attached to one cooler if multiple coolers are used in a single shipment, provided the shipping company concurs with this practice. When shipping multiple coolers in a single shipment, use additional labels to identify the cooler along with the total number of coolers in the shipment (e.g., cooler 2 of 3).

11.4.1 Sample Packing

Standard coolers are typically employed when packing samples for shipment although other shipping containers are acceptable. Interior packing materials include bubble wrap or foam sleeves encasing the individual sample containers and lining the cooler interior. Interior packing materials should be sufficient to prevent breakage during transport. After placing individually wrapped sample containers in the cooler, fill all empty space between sample containers with padding to minimize movement against each other.

Containers for water samples should be packed in an upright position and not stacked on their sides. When shipping water samples, line the bottom of the cooler with absorbent material to contain liquids in case of breakage.

The use of frozen gel ice is convenient to maintain the samples at a temperature of less than 6°C, but water ice may also be used. When using water ice, precautions to prevent spillage from the sample cooler (i.e., containing water ice in triple bags and sealing the cooler drain) are essential to expedient delivery of the shipment to the laboratory. Line the bottom of the cooler with absorbent material when using water ice in coolers.

Immediately prior to shipment, replace the ice or frozen gel packs in the coolers so that samples will be maintained at less than 6°C during transport to the analytical laboratory.

11.4.2 Shipping or Delivery

If utilizing a mainland laboratory, consider shipping and delivery constraints resulting from Hawai`i's geographic location, especially when collecting samples with a short hold time. Ensure sample delivery to the analytical laboratory so that there is sufficient time for analysis of the constituent with the shortest hold time. Samples preserved at less than 6°C using gel packs or ice should be shipped via overnight delivery. If samples are shipped on Friday, arrange for Saturday delivery with the analytical laboratory to ensure the correct temperature is maintained throughout shipping.

Errors in shipping and delivery risk exceeding either the required sample temperatures or analysis hold times. As noted previously, results from samples exceeding the required preservation temperatures or analyzed past the hold times may or may not be usable, depending upon the DQO set forth in the SAP. If the data are deemed usable, the results from the analyses should be interpreted as minimum concentrations.

When shipping air, soil, or water samples either inter-island or to the mainland, follow all appropriate U.S. Department of Transportation (DOT) regulations, specifically Title 49 of the Code of Federal Regulations (CFR), Parts 171 through 180 (Title 49 CFR). The DOT rules and regulations apply to all samples shipped including methanol, sodium bisulfate, and nitric acid preserved samples if a commercial carrier such as FedEx transports the samples. Personnel responsible for shipping soil and water samples in Hawai`i should receive training and refresher training in these regulations. Specific packaging, labeling, and documentation are required by DOT regulations for most samples containing chemical preservatives. In addition, shipping dry ice is also subject to DOT regulations including, but not limited to, shipping container labeling requirements and restrictions on the weight of dry ice included in each shipping container.

Shipment of soil samples from Hawai`i to the mainland is also subject to United States Department of Agriculture (USDA) inspection and regulation. The USDA does not need to inspect water sample shipments. A "USDA Soil Import Permit" is required to prove that the receiving analytical laboratory is certified by the USDA to receive and properly dispose of soil. In addition, all soil sample coolers must be inspected by a USDA representative, affixed with a label indicating that the coolers contain environmental samples, and accompanied by shipping forms stamped by the USDA inspector prior to shipment (US Navy, 2007).

In Hawai`i, soil sample shipments are typically brought to the shipping company at the airport where the shipping company contacts a USDA representative to request an inspection. Alternatively, individuals or consulting firms may enter into an agreement with the USDA to ship soil samples. In this way, the USDA does not need to inspect each soil sample shipment. Consider USDA inspection requirements when planning sample shipments and employ custody seals on each individual sample container to ensure proper chain-of-custody control in the event coolers are opened by the USDA for inspection.

Inter-island shipment of soil in Hawai`i is subject to inspection and regulation by the State of Hawai`i Department of Agriculture (HDOA). Annual intra-state permits for shipping soil may be requested from the HDOA Plant Quarantine Branch in Honolulu.

Non-Hazardous Materials Shipment

Field personnel must state whether any sample is suspected to be a hazardous material. Samples may be shipped as non-hazardous based on previous site sample results, field screening results, or visual observations. In addition, environmental samples are currently exempt from Hazardous Goods regulations. Title 40 CFR, Part 261.40(d) states "A sample of solid waste or a sample of water, soil, or air which is collected for the sole purpose of testing to determine its characteristics or composition is not subject to this Part or Parts 262 through 267 or Part 124 of this chapter or to the notification requirements of Section 3010 of RCRA." (Title 40 CFR) Therefore, no special regulations are required to be followed for the shipment of environmental samples from the field. Note that this provision applies to unpreserved soil and water samples (i.e., no chemical preservatives added during collection).

For groundwater samples specifically, very small quantities of certain dangerous goods may be transported without certain marking and documentation requirements as described in Title 49 CFR Part 172 (Title 49 CFR). The Hazardous Materials regulations do not apply to the commonly utilized sample preservatives methanol, sodium bisulfate, hydrochloric acid, nitric acid, sulfuric acid, and sodium hydroxide added to water samples if their pH or percentage by weight criteria is met (USEPA, 1996; USACE, 1998b; US Navy, 2007). Standard preservative volumes in standard sample containers (e.g., HCl in 40 ml volatile organic analysis [VOA] jar) fall under this definition (USEPA, 1996; USACE, 1998b; US Navy, 2007).

It is extremely important to be aware that regulations may prohibit the shipment of chemically preserved soil samples (such as methanol or sodium bisulfate preserved soil samples intended for volatile analysis). The above paragraph references the shipment of chemical preservatives in water samples only.