|Export Review Form||Transporting & Shipping Items||Contacts||Export Regulations||Biologicals & Hazardous Materials|
|Carry On & Checked Bags||DOT/IATA Training||Export Control Training||TSCA Compliance||Importing Biologicals|
UNMC and UNO conforms to strict government regulations. When sharing, shipping, transmitting, or transferring goods (testing kits, chemicals, equipment, hardware and materials including biological materials), technology (technical information and data), software/codes (commercial or custom) to a foreign national in the US or a foreign individual/entity or country outside the US, you are required to have an Export Control Review done by Export Control and Environmental Health & Safety. After the review, we can provide guidance and assistance concerning the permitting, licensing, packaging, and shipping of these materials.
- Export Control Policy (8005)
- Hazardous Material/Dangerous Goods Shipping Plan
Trevor Carritt, UNMC Export Control & EHS Specialist
Brenda L. Kolobara, UNO Research Compliance Officer
Patrick Wheeler, UNO Environmental Health & Safety
Export Control and International Shipments
It is the University of Nebraska’s policy that all personnel, including employees, visiting scholars, and students, comply with all United States export control laws and regulations, including the Department of Commerce (DOC) Export Administration Regulations (EAR), the Department of State International Traffic in Arms Regulations (ITAR), and the regulations administered by the Treasury Department’s Office of Foreign Assets Control (OFAC).
Depending on the country of destination, controlled technologies and commodities regulated under ITAR and DOC may require a license prior to shipment.
The Department of Commerce’s Export Administration Regulations (EAR) have a wider impact on research and development. EAR regulates the export of so-called “dual-use” technologies listed in the lengthy and detailed Commerce Control List (CCL). Dual-use technologies and commodities have civil, commercial, and peaceful purposes but are listed on the CCL because of their strategic value or potential for military use or terrorism. Many CCL items are not hazardous, valuable, or uncommon. The CCL contains many technologies and commodities commonly found in laboratories or used for field research, including:
- Biologicals (viruses, bacteria, toxins, and genetic elements)
- GPS units
- Laboratory Equipment (centrifuges, fermenters)
- Chemicals (including newly synthesized chemicals)
- Diagnostic Kits/Reagents
- Computers or Tablets/iPads
- Cameras (digital, infrared)
- Encryption Software and Source Code
- Marine and Oceanic Equipment
- Aerospace Equipment
The Department of State’s International Traffic in Arms (ITAR) regulates defense articles and services. Regulated items are listed on the U.S. Munitions List (USML). The USML is based on whether an article or service is deemed inherently military in character.
The Treasury Department’s Office of Foreign Assets Control (OFAC) enforces prohibited travel and asset transfers with countries subject to U.S. boycotts, trade sanctions, and embargoes. The State Department regulates the export of inherently military technologies in accordance with the International Traffic in Arms Regulations (ITAR).
Shipment Legal Requirements
- Embargoed Countries: Cuba, Iran, North Korea, Syria, and Sudan are countries with strict import and export license requirements. Many other countries also have existing risk alerts due to sanctions, embargoes, prohibitions, and other conditions.
- Restricted Party Screening: The US government maintains lists of individuals and entities that US organizations are prohibited from collaborating with or shipping to and require an export license for any shipment to a restricted party. Please contact the Export Control Officer for assistance with screenings or export license applications.
- Export License Review and Declarations: US export regulations may require an export license or license exception based on the item (including technical data), shipping destination, value, or end user. Automated Export System (AES) filing for shipments valued over $2500 or those that require an export license are compulsory under the Foreign Trade Regulations. The Export Control Officer can review and advise on available license exceptions.
Published works and personal correspondence are not subject to export controls and, therefore, can be shipped to international recipients without needing to submit a Request for Export Controls Review Application, unless the total value of the shipment exceeds $2499.
“Published works” include scholarly works (journals, individual articles, textbooks, presentation papers, publicly available theses and dissertations, posters etc.), published books, magazines and newspapers, and similar printed material. Unpublished manuscripts may be subject to export controls if they contain research data not intended for publication, so consult with your export compliance coordinator prior to exporting these items.
“Personal correspondence” includes personal and professional messages (letters to relatives, communication with a conference organizer etc.), awards (certificates, plaques etc.), and personal items (food, clothing etc.).
If your shipment includes equipment, software, or chemical, biological, or radioactive materials, you will still need to submit a Request for Export Controls Review Application. Contact Sam Padilla at 402-559-9328 or firstname.lastname@example.org for additional information.
Biological and Hazardous Materials
The transportation of biological and hazardous materials is highly regulated by the Department of Transportation (DOT) and the International Air Transport Association (IATA). UNMC and UNO personnel are required to adhere to the strict training and packaging requirements of these entities. Guidance and training are provided to help transport research materials safety and lawfully.
Shipping Biological Links
- Biologicals and Dry Ice Shipping Examples
- EHSA Online Training (contact EHS at 402-559-6356 or email@example.com to access)
Export Biological Links
- EAR Human and Animal Pathogens
- EAR Genetic Elements
- EAR Plant Pathogens
- EAR Diagnostic Products
- ITAR Category XIV
Hazard Classes are categories of hazards that are assigned to HM/DG. All regulated material will fit within one of these classes:
- Flammable liquids
- Flammable solids
- Oxidizing substances
- Toxic chemicals and Infectious substances.
- Radioactive material
- Misc. (Dry Ice, lithium batteries)
Hidden Dangerous Goods. Products may contain Dangerous Goods that are not readily apparent. If you are shipping any of the following, please contact EHS at 402-559-6356 for further determination.
- Electronic products, mobile phones and accessories, photographic equipment, torch/flashlight, dry batteries, lithium batteries, prototype lithium batteries, rechargeable batteries, wet cell batteries, alkaline batteries, batteries contained in equipment, speaker, solar charger or ultra-capacitor.
- Personal care products, cosmetics, perfume, nail polish, household chemicals, cleaning agents, aerosols, bleach, drain cleaners, pesticides, wax, toolbox, glue, spray paint, lubricants, lighter fluid.
- Motor vehicles, motorcycles or electric vehicles parts, engines, lawn mowers, generator, carburetor, fuel tank, fuel, fuel controllers, fire extinguishers, air bag, ships or aircraft parts, barometers.
- Agricultural or industrial chemicals, chemicals with strong odor or volatile chemicals, metal powder, pigment, flammable solids, oxidizers, toxic or corrosive substances, pesticides, compressed gases, flammable liquids, resins, inks, paints, sealants, adhesives, mercury.
- Medical equipment, radioactive substances, pharmaceuticals raw materials, vaccines or virus samples, compressed gases, cryogenic liquefied gases, dry ice, sphygmomanometer, thermometers.
- Electrical appliances, refrigerators, air conditioners, vacuum tube, magnetic tubes, magnets, smoke detectors.
Aviation Regulated Solids or Liquids are any material that has narcotic, noxious, irritating, or other properties such that, in the event of spillage or leakage on an aircraft, could cause extreme annoyance or discomfort to crew members so as to prevent the correct performance of assigned duties.
Chemicals are transported to, from, and within our university for a variety of reasons. This can include sending chemicals to collaborating universities or companies, returning products to manufacturers, faculty shipping chemicals off-site to other institutions when accepting a new position, and when laboratories move from one building to another on-site. Please contact EHS for guidance in determining which chemicals are regulated by DOT or IATA. Chemicals that are not regulated may be shipped by the employee. Chemicals that are regulated must be shipped by EHS. UNMC/UNO/NM employees or their departments are responsible for all costs associated with transporting chemicals.
Commercial items transported out of the United States in carry-ons or with checked luggage are considered hand-carried exports. Consider shipping the items in advance, if possible. If hand-carrying items, such as samples, chemicals, medication and/or research supplies or equipment, review is required by Export Compliance in order to ensure the items are not restricted for transport if they are hazardous goods or chemicals or determine whether they are export-controlled technologies. Items considered “Tools of the Trade” (e.g., laptops, phones & certain equipment), which will be returned to the country of origin at the end of travel, may not be considered a hand carried export but may need to be evaluated for compliance with other transportation regulations. Note that certain destinations may have import restrictions for such items and may require you to declare the items upon entry or get required permits in advance.
Planning ahead and packing properly can facilitate the screening process and ease your travel experience at the airport. Know what you can pack before arriving at the airport by checking the prohibited items list. Carrying prohibited items may cause delays for you and other travelers, but they may also lead to fines and sometimes even arrest.
TSA may impose civil penalties of up to $13,333 per violation per person. All non-personal items that are taken on international trips for University business must be reviewed by UNMC Export Control and Environmental Health and Safety.
Application of the DOT/IATA regulations concerning the transport of dangerous goods. Training must include:
- general familiarization training, which must be aimed at providing familiarity with the general provisions
- function specific training, which must provide detailed training in the requirements applicable to the function for which that person is responsible
- safety training, which must cover the hazards presented by dangerous goods, safe handling, and emergency response procedures
- security awareness training that addresses the nature of security risks, recognition of security risks, methods to address and reduce such risks, and actions to be taken in the event of a security breach. It should include awareness of security plans (if appropriate) commensurate with the responsibilities of individuals and their role in implementing security plans.
Contact Environmental Health & Safety for available training at 402-559-6356 or firstname.lastname@example.org.EHSA Online Training (contact EHS to setup access at 402-559-6356)
- CITI Training for Export (see Export Control website for more information)
- Create your user account through the CITI website (www.citiprogram.org).
Information regarding documentation for chemical shipments subject to the Environmental Protection Agency’s Toxic Substances Control Act.
Shipping Forms & Links
- Export Review Form
- Dangerous Goods Checklist
- UNMC Commercial Invoice Example
- UNMC Commercial Invoice With Letterhead (Excel)
- UNO Commercial Invoice With Letterhead (Excel)
- FedEx Commercial Invoice
- Example of FedEx Commercial Invoice
- Example of FedEx International Airway Bill
- Lithium Battery Transportation Plan
- Information on UPS Contract
- List of Items Spreadsheet Template
- Foreign Trade Schedule B (Census)