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February 2, 2018
February 9, 2018
This policy exists to ensure compliance and mitigate risk for shipments for which Yale is responsible by requiring the use of Yale’s approved shipping application. This policy applies to all individuals making and arranging shipments for which Yale is responsible.
All shipments for which Yale is responsible must comply with all applicable regulations and standards, as well as relevant policies and procedures. 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 research/clinical materials must complete the required training.
Reason for the Policy
Every year, Yale is responsible for thousands of shipments to and from Yale, as well as for shipments between non-Yale entities (third-party shipments), and shipments between Yale locations (intra-campus). 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 regulatory requirements govern the handling of research/clinical material shipments. Regulations require training for everyone involved in any aspect of shipping research/clinical materials to ensure the safety of everyone involved in handling these packages, as well as the safety of air transportation. Regulations also require specific packaging, labeling, marking, and documentation for these packages. 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.
A company whose primary business is the transport of materials (e.g., UPS, FedEx, DHL, World Courier).
Biological, chemical, and/or radioactive materials used in a research or clinical setting.
All goods and materials transported via all transportation modes (e.g., vehicle, airplane, etc.). Shipments include transportation of goods or materials both by carriers and internal Yale mechanisms.
Anyone packaging, handling, completing shipping documentation, shipping, or transporting materials for Yale activities.
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.
All individuals (shippers) requesting or making shipments for which Yale is responsible must do so through Yale’s approved shipping application (eShipGlobal), except for intra-campus shipments, as detailed below. Shippers who fail to use Yale’s approved shipping application, without first receiving an approved exception (see Special Situations & Exceptions, below), will not be reimbursed for costs incurred. 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, including all pertinent disciplinary measures.
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.
Intra-campus shipments include all shipments between Yale locations (e.g., West Campus, Medical, Science Hill). Intra-campus shipments are not required to be processed through Yale’s approved shipping application (except for those involving research/clinical materials, as described below). Instead, intra-campus shipments should be arranged directly through Yale Transport, Receiving & Storage (TR&S) or a specialty mover. Shippers should use their best judgment (assessing size, value, and any other relevant considerations) in deciding whether to utilize these services or transport goods by other means (e.g., on foot, personal vehicle). Shippers must not use common carriers (e.g., UPS, FedEx, DHL, World Courier) for intra-campus shipments.
Yale Environmental Health and Safety (EHS) is responsible for the oversight of regulatory compliance regarding the shipment of research/clinical materials. Shipments containing research/clinical materials must only be prepared and processed by research and clinical personnel who have completed the required training on the safe and proper handling of research/clinical materials administered by EHS. Administrative staff must not participate in any shipper (defined above) activities for research/clinical material shipments (e.g., create shipping labels, package materials, add markings to packages, etc.).
All shipping of research/clinical materials (including shipments both intra-campus and external) must be processed through Yale’s approved shipping application. Research/clinical materials must not be transported via any other means (e.g., campus shuttle, personal vehicle), unless the shipper receives appropriate prior approval (see Special Situations & Exceptions, below).
In instances when researchers need to ship research/clinical materials for which they are not certified to ship (e.g., chemical and radioactive materials), EHS will provide appropriate staff to assist with the shipment.
In addition to adhering to the requirements of section 1430.1, shipments containing research/clinical 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 research/clinical materials are subject to import and/or export regulations. Yale’s approved shipping application will automatically identify whether a proposed shipment is subject to a particular regulation. If a license is required, and the shipment is not otherwise impermissible, EHS will apply for the appropriate license on behalf of the Principal Investigator.
Yale’s Director, 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 will automatically help identify whether a proposed shipment is subject to a particular regulation, but shipments will still need careful review. If a license is required, shippers must contact Yale’s Director, Export Controls for assistance.
In limited situations, use of Yale’s approved shipping application may not be feasible. In such situations, a limited exception may be warranted. For exception approval, shippers, through their department business office, must contact the appropriate office below, depending upon the type of shipment required:
- Shipping, General : Yale Relocation & Logistics Management : email@example.com; 203-432-9961; or
- Shipping Research/Clinical Materials : Yale Environmental Health & Safety : firstname.lastname@example.org; 203-785-3550.
Requests for exceptions must be reviewed and approved by the Yale Shipping Committee. The Shipping Committee is comprised of representatives from the following areas: EHS, Relocation & Logistics Management, the office of the Director, Export Controls, Procurement, and the Business Operations Leadership Team (BOLT). For more detailed information, see Procedure 1430 PR.01 Shipping Policy Exception Requests.
Roles & Responsibilities
Environmental Health & Safety (EHS)
EHS is responsible for the oversight of regulatory compliance regarding the shipment of research/clinical materials. EHS administers and provides appropriate training to research and clinical personnel for the safe and proper handling of research/clinical materials. EHS monitors applicable regulatory changes and updates the research/clinical material shipping process, as appropriate. EHS supplies certified staff to assist with research/clinical material shipments for which researchers are not certified to ship. EHS applies for appropriate import/export licenses for research/clinical material shipments on behalf of Principal Investigators.
Department Business Offices
Department business offices are responsible for instructing shippers within their departments on the appropriate processes for requesting and processing shipments for which Yale is responsible. Department business offices are also responsible for requesting, when appropriate, exceptions to this policy on behalf of shippers within their departments. Department business offices are responsible for the oversight of any carrier accounts opened within their departments. Department business offices are also responsible for reviewing transactions, identifying when shippers have initiated shipments outside the eShipGlobal system, and advising shippers on proper shipping practices.
Director, Export Controls
The Director, Export Controls is responsible for the oversight of Yale shipments subject to export regulations. He/She reviews and approves shipments subject to regulations based upon their destination, intended recipient, and/or contents. He/She assists shippers in obtaining appropriate export licenses, when appropriate.
Procurement is responsible for maintaining integrations between Yale’s approved shipping application and Yale’s financial systems. Procurement is also 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 research/clinical materials.
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.
Yale Shipping Committee
The Shipping Committee is responsible for reviewing and approving, or rejecting, requests to create carrier accounts. The Shipping Committee is also responsible for reviewing any open carrier accounts and assessing whether those accounts should remain open. The Shipping Committee is comprised of representatives from the following areas: EHS, Relocation & Logistics Management, the office of the Director, Export Controls, Procurement, and the Business Operations Leadership Team (BOLT).