New DOT Training Requirements

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U.S. DOT's infectious substance transport rule includes new training requirements for generators as well as tranporters.

On August 14, 2002, the U.S. Department of Transportation (DOT) issued revised requirements for transporting infectious substances (Federal Register, Vol. 67, No. 157, pp. 53118-53144). Infectious substances include etiologic agents, regulated medical wastes, diagnostic specimens, and certain biological products. These revisions have been made to conform to World Health Organization criteria and to be consistent with the United Nations Recommendations on the Transport of Dangerous Goods. The effective compliance date for this final rule is February 14, 2003.

"These rules have been proposed for over a year and a half now and are no surprise to the medical waste industry," says Nelson "Sig" Slavik, Ph.D., of Environmental Health Management Systems, Inc., Niles, MI. Slavik testified before DOT on behalf of the American Hospital Association in 1993 and 1995 during the initial development of the rules. The medical waste industry and applicable federal agencies – including the Centers for Disease Control and Prevention, the Occupational Safety and Health Administration, and the Environmental Protection Agency – have worked closely with the DOT to ensure workable regulations.

Slavik notes, however, that what may come as a surprise is the responsibility the medical facility has under DOT regulations. Of critical concern is the training mandated for healthcare staff involved in the labeling, containment, and manifesting of shipments of infectious substances including regulated medical wastes and diagnostics specimens. Personnel in most healthcare facilities are unaware of DOT training requirements for off-site medical waste shipments, and now these requirements extend to diagnostic specimens. The rules also apply to medical facilities actively involved in research, shipping cultures and stocks of etiologic agents or genetically modified organisms.

Employee training has been an ongoing DOT requirement for transporters of any hazardous materials, including infectious substances. These training requirements now extend beyond the transporter to the facility offering the materials for shipment. The extent of the training depends on the activities in which the medical facility engages when preparing the materials for transport. Specific rules for training are found in 49 Federal Code of Regulations Part 172.704. The healthcare facility should work closely with its transporter to ensure that both the transporter and the hospital comply with training requirements and other DOT requirements for packaging, labeling, manifesting, and emergency response.

The final rule also includes new requirements for shipping diagnostic specimens. Shipping requirements are minimal for those diagnostic specimens containing Risk Group 2 or Risk Group 3 materials (as defined in the final rule). All diagnostic specimens in these categories must be contained in packaging meeting minimum performance criteria and must be marked "Diagnostic Specimens." Diagnostic specimens in Risk Group 1 are not regulated. Any specimen containing Risk Group 4 materials, however, is under the full restrictions of Division 6.2, "Infectious Substances."

Healthcare facilities must familiarize staff with the requirements set forth in the final rule. Ensure that your transporter knows the rules and can provide you with the training required for your employees as well as the packing and labeling materials required for your shipment.

This information was obtained from Premier, Inc.'s Safety Share website

 

TRAINING LINKS:

US DOT - Office of Hazardous Material Safety homepage

US DOT - Office of Hazardous Material Safety :  Hazmat Regulations and Intrepretations         

US DOT - Office of Hazardous Material Safety :  Hazmat Training Requirements

US DOT - Federal Motor Carrier Administration homepage

US DOT - Federal Motor Carrier Administration :  Security Information