Responsible Official: University Controller
Responsible Office: Controller’s Office
Effective Date: February 2, 2018
Revision Date: February 18, 2026
Policy Sections
1430.3 Intra and Inter-Campus Transport
1430.4 Export Control Regulation and Licensing
Scope
This policy exists to ensure compliance and mitigate risk by establishing requirements for all Shipments For Which Yale Is Responsible, including the use of Yale’s Approved Shipping Application. This policy applies to all Yale faculty, students, staff, and other Authorized Individuals making and arranging Shipments For Which Yale Is Responsible. This policy applies only to Shipments related to University activities; personal Shipments may not be processed through Yale’s Approved Shipping Application or Yale Carrier accounts, regardless of the individual’s willingness to reimburse the University.
Policy Statement
All Shipments For Which Yale Is Responsible must comply with all applicable regulations and standards. This policy and associated procedure(s) support those applicable regulations and standards. All Shipments For Which Yale Is Responsible must be processed through Yale’s Approved Shipping Application, unless otherwise specified. All personnel involved in any aspect of shipping or receiving Clinical / Research Materials and Otherwise Regulated or Potentially Hazardous (“CRORPH”) Materials must complete the required training, as detailed below.
Reason for the Policy
Every year, Yale initiates or arranges thousands of Shipments to and from University and research locations, including Shipments to external Collaborators, between non-Yale entities (third-party Shipments), between Yale locations (Intra and Inter-campus Shipments), and Shipments arranged on behalf of Collaborators. Use of Yale’s Approved Shipping Application ensures that Carrier account numbers are not revealed to outside entities, thus reducing the risk of shipping fraud. Use of Yale’s Approved Shipping Application further ensures that community members have access to Yale’s negotiated Carrier rates.
Additionally, various federal regulatory requirements govern the handling of CRORPH Materials Shipments. These regulations require training for all personnel involved in any aspect of shipping CRORPH Materials, ensuring the safety of individuals handling these packages, as well as the safety of those involved in air, ground, rail, and vessel transportation. These regulations also require specific packaging, labeling, marking, and documentation. Use of Yale’s Approved Shipping Application ensures compliance with these requirements.
Further, certain Shipments are subject to import/export regulations, depending upon their origin, destination, intended recipient, and/or contents. Use of Yale’s Approved Shipping Application assists in identifying whether a Shipment is subject to a particular regulation.
Definitions
Authorized Individuals
Persons who are not Yale faculty, students or staff but who have been formally granted written authorization by a Yale department, Principal Investigator, or administrative office to prepare or arrange Shipments on behalf of Yale. This may include employees of contracted service providers such as customs brokers, freight forwarders, or specialized couriers, when acting within the scope of their agreement with Yale. Authorized Individuals are expected to complete all required training and meet all applicable regulatory requirements for the materials being shipped, as appropriate to their role.
Carrier
A company whose primary business is the transport of materials (e.g., UPS, FedEx, DHL, World Courier).
Certified Shipper
A Yale faculty, student, staff member, or other Authorized Individual who has successfully completed all required training for the type of CRORPH materials being shipped, as determined by Yale Environmental Health and Safety (“EHS”), and is currently authorized to prepare and arrange Shipments in compliance with all applicable regulations. Certification must be maintained by completing refresher training at the required regulatory intervals.
Collaborator
A non-Yale entity that sends material to Yale, utilizing documentation created by Yale’s Approved Shipping Application, at the Yale receiver’s expense.
Clinical / Research Materials and Otherwise Regulated or Potentially Hazardous (“CRORPH”) Materials
Biological, chemical, and/or radioactive materials used in research or clinical settings, or any other regulated or potentially hazardous material (e.g., infectious substances, diagnostic specimens, dry ice, formalin, ethanol, tritium, sealed sources, magnets, batteries, etc.)
Intra-Campus
The transport of materials between buildings or locations within the same Yale campus. Examples include moving materials between two buildings on Central Campus or within the Medical Campus.
Inter-Campus
The transport of materials between different Yale campuses or geographic locations. Examples include Shipments between Central Campus and West Campus.
Shipment
All goods and materials transported via any transportation mode (e.g., vehicle, airplane, etc.). Shipments include transportation of goods or materials both by Carriers and internal Yale mechanisms.
Shipments For Which Yale Is Responsible
Any Shipment that is initiated, paid for, or arranged by a Yale faculty, student, staff, or other Authorized Individual for University-related purposes; Shipments using Yale’s Approved Shipping Application or Yale Carrier accounts; Shipments where Yale is listed as the Shipper; and Intra and Inter-campus Shipments between Yale locations.
Shipper
A Yale faculty member, staff, student, or other Authorized Individual who, on behalf of Yale packages, handles, completes shipping documentation for, or transports materials in connection with Yale activities. This definition does not include third-party Carriers or courier services.
Yale’s Approved Shipping Application
The required method for requesting and processing Shipments For Which Yale Is Responsible Currently, eShipGlobal is Yale’s Approved Shipping Application
Policy Sections
1430.1 Yale Shipping
All Shippers requesting or making Shipments For Which Yale Is Responsible must do so through Yale’s Approved Shipping Application except for certain Intra and Inter-campus Shipments of Non-CRORPH materials, as detailed in 1430.3. Failure to use Yale’s Approved Shipping Application, without an approved exception (see Special Situations & Exceptions, below) or other non-compliance with this policy, will result in denial of reimbursement for associated costs (e.g.; shipping charges) and may subject the Shipper to the consequences described in the Non-Compliance Section of this policy. Violations of this policy involving a University Purchasing Card (“PCard”) are subject to the provisions of Policy 3215 Yale Purchasing Card and Procedure 3215 PR.01 Yale Purchasing Card Procedure, additionally including all pertinent disciplinary measures described therein.
All Shipments For Which Yale Is Responsible must comply with the following regulations:
- U.S. Department of Commerce, Bureau of Industry and Security, Export Administration Regulations;
- U.S. Census Bureau, Foreign Trade Statistics Regulations;
- U.S. Department of State, International Traffic in Arms Regulations (ITAR); and
- U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) Regulations.
1430.2 Shipping Clinical / Research Materials and Otherwise Regulated or Potentially Hazardous (“CRORPH”) Materials
EHS is responsible for the oversight of regulatory compliance regarding the Shipment of CRORPH Materials. Shipments containing CRORPH Materials must only be prepared and processed by research and clinical personnel who have completed the required Research Materials Shipping Training, administered by EHS, on the safe and proper handling of CRORPH Materials
Administrative staff must not perform any of the physical or technical activities required of a Certified Shipper for CRORPH Materials Shipments (e.g., create shipping labels, package materials, applying hazard markings to packages, etc.). These activities are the sole responsibility of the Shipper.
All shipping of CRORPH Materials (including Shipments both Intra/Inter-campus and external) must be processed through Yale’s Approved Shipping Application. CRORPH Materials must not be transported via any means other than what is listed in Yale’s Approved Shipping Application (e.g., FedEx, Lab Logistics, TR&S) ), unless the Shipper receives appropriate prior approval, either through the mechanisms built into Yale’s Approved Shipping Application or according to Special Situations & Exceptions, below. Prohibited means of transport include, but are not limited to, personal vehicles, ride-share services, and city buses.
In instances when researchers need to ship CRORPH Materials which, based on Yale’s Approved Shipping Application determines they are not personally authorized to ship, (e.g., chemical and radioactive materials), EHS contacts the Shipper to coordinate the Shipment.
In addition to adhering to the requirements of section 1430.1, Shipments containing CRORPH Materials must also comply with all applicable regulations and standards including, but not limited to:
- U.S. Department of Transportation, Hazardous Materials Regulations;
- International Civil Aviation Organization, Technical Instructions for the Safe Transportation of Dangerous Goods by Air; and
- International Air Transport Association, Dangerous Goods Regulations.
Certain CRORPH Materials are subject to import and/or export regulations. See Section 1430.4 Export Control Regulation and Licensing for more information.
1430.3 Intra and Inter-Campus Transport
CRORPH Materials requiring movement on or around Yale’s campus(es) must be processed through Yale’s Approved Shipping Application ).
If the materials are flagged as restricted or potentially restricted, the approval determination is routed to EHS for additional review of Intra/Inter-campus transport eligibility. EHS contacts the Shipper with additional guidance about how to proceed with transport.
If approved, shipping labels and other documentation meeting all requirements for the Shipment are generated through Yale’s Approved Shipping Application
Some CRORPH Materials may be transported via the Yale Shuttle, but only with prior approval from EHS via Yale’s Approved Shipping Application and if all regulatory requirements are met
Non CRORPH (e.g.; furniture, books, etc.) Materials requiring movement on or around Yale’s campus(es), do not require use of Yale’s Approved Shipping Application . It is at the Shipper’s discretion to either self-transport the materials or to request transport from TR&S.
1430.4 Export Control Regulation and Licensing
Yale’s Director [of] Export Controls is responsible for the oversight of Yale Shipments subject to export regulations. Certain Shipments are subject to export regulations, depending upon their destination, intended recipient, and/or contents. Yale’s Approved Shipping Application automatically identifies whether a proposed Shipment is subject to a particular regulation, but Shipments still need careful review either from the Director of Export Controls or EHS. If a license is required, and the Shipment is not otherwise impermissible, the Yale Director of Export Controls, or EHS, for CRORPH materials, applies for the appropriate license on behalf of the Principal Investigator and/or Shipper.
If a Shipper is aware that an item is Export Controlled, the Shipper must contact Yale’s Director, Export Controls for assistance. For additional information, please consult Policy 1370 Export-Controlled Information
1430.5 Non-Compliance
Failure to comply with this policy may result in denial of reimbursement for shipping costs, suspension of shipping privileges, personal financial responsibility for any fines or penalties, criminal liability, and disciplinary action up to and including termination or separation from the University. Use of Yale’s Approved Shipping Application or Carrier accounts for personal Shipments is strictly prohibited and may result in personal liability for charges and other disciplinary measures. Violations involving a PCard are subject to Policy 3215 Yale Purchasing Card.
Special Situations & Exceptions
In limited situations, use of Yale’s Approved Shipping Application may not be feasible or practical. In such instances, an exception may or may not be needed, depending on the circumstances. Shippers refer to the following protocol:
REQUIRES EXCEPTION
For circumstances where business needs and/or other extenuating circumstances may support the use of a different shipping mechanism, the Shipper is required to obtain an exception, as outlined below:
- CRORPH Materials: Contact EHS: ehs@yale.edu; 203-785-3550.
- Non- CRORPH Materials: Contact TR&S Associate Director: elliott.taylor@yale.edu.
All requests for exceptions should be made at least five (5) business days in advance. Exceptions are reviewed by the appropriate parties of the Yale Shipping Committee within 2-3 business days of submission, but approval is not guaranteed; plan accordingly. The Shipping Committee is comprised of representatives from: EHS, Relocation & Logistics Management, TR&S, Procurement, the Office of the Director [of] Export Controls, and the Controller’s Office. For more detailed information and the relevant form, see Procedure 1430 PR.01 Shipping Policy Exception Requests.
DOES NOT REQUIRE EXCEPTION
For circumstances where the Shipper attempts to first use eShipGlobal and the Shipment is identified (by eShipGlobal) as unable to proceed via that Application OR the Shipper is aware that the Shipment is not suitable for eShipGlobal:
- CRORPH Materials: Not Applicable; all CRORPH Materials require approval from EHS for Shipment. Contact EHS: ehs@yale.edu; 203-785-3550.
Non-CRORPH Materials: Contact TR&S Associate Director: elliott.taylor@yale.edu
Roles & Responsibilities
Environmental Health & Safety (“EHS”)
EHS is responsible for the oversight of regulatory compliance regarding the Shipment of CRORPH Materials. This includes administering and providing appropriate training to research and clinical personnel for the safe and proper handling of CRORPH Materials; monitoring applicable regulatory changes and updating the CRORPH Materials shipping process, as needed. EHS supplies certified staff to assist with Shipments which researchers are not certified to ship and applying for necessary import/export licenses for CRORPH Material on behalf of Principal Investigators.
Departmental Business Offices
Departmental Business Offices are responsible for instructing Shippers within their departments on the appropriate processes for requesting and processing Shipments For Which Yale Is Responsible. Departmental Business Offices are also responsible for requesting, when appropriate, exceptions to this policy on behalf of Shippers within their departments. Departmental Business Offices are responsible for the oversight of any Carrier accounts opened within their departments. Departmental Business Offices are also responsible for reviewing transactions, identifying when Shippers have initiated Shipments outside Yale’s Approved Shipping Application, and advising Shippers on proper shipping practices.
Director, Export Controls
The Director [of] Export Controls is responsible for the oversight of Yale Shipments subject to export regulations. They review and approve Shipments subject to regulations based upon their destination, intended recipient, and/or contents. They assist Shippers in obtaining export licenses, when appropriate.
Information Technology Services (“ITS”)
ITS is responsible for maintaining integrations between Yale’s Approved Shipping Application and Yale’s financial systems.
Procurement
Procurement is responsible for providing shipping transaction data, as requested, to the Yale Shipping Committee for review and analysis.
Relocation & Logistics Management
Relocation & Logistics Management is responsible for the oversight of regulatory compliance regarding the Shipment of items other than CRORPH Materials.
Shippers
All individuals requesting or making Shipments For Which Yale Is Responsible must comply with this policy and related procedures. All Shippers must use Yale’s Approved Shipping Application to process Shipments, unless an exception has been granted.
Transport, Receiving, & Storage (“TR&S”)
TR&S provides support for campus moves, storage, ground transportation, courier services, and shipping & receiving for Central Campus, Medical Campus, Science Park, West Campus and the West Haven Veteran Affairs (VA) Medical Center.
Yale Shipping Committee
The Yale Shipping Committee is responsible for reviewing, and approving or rejecting, requests to create Carrier accounts, and reviewing any open Carrier accounts to assess whether those accounts should remain open. Members of the Shipping Committee are also responsible for reviewing (as needed), and approving or rejecting, submitted exception requests for shipping Non-CRORPH Materials outside of eShipGlobal. The Shipping Committee is comprised of representatives from the following areas: EHS, Relocation & Logistics Management, TR&S, Procurement, the Office of the Director [of] Export Controls, and the Controller’s Office.
Related Resources
Procedure 1430 PR.01 Shipping Policy Exception Requests
Form 1430 FR.01 Shipping Policy Exception Request Form
Policy 1370 Export-Controlled Information
Policy 3215 Yale Purchasing Card