Thursday, May 15, 2014

DOT Hazardous Material Transportation Regulations

Rules and Regulations

How do DOT hazardous material transport regulations affect you? Well, simply as a member of the public, the regulations designed to keep the U.S. up to par with international HazMat laws are a necessity. As a member of the medical profession, the changes that have occurred over the last several years affects your transport and disposal of medical waste products.

Disposing, Recycling, Transporting

Disposal and recycling techniques for medical waste of all types is intrinsically dependent on the transport of hazardous materials in many cases. The types of disposal techniques available may depend on the transport of  hazardous, or anatomical waste products, and the state and federal rules and regulations governing this. Starting  with knowledge of classifications and regulations from disposal to transport and then assessing the best disposal techniques in terms of safety, efficiency, and cost are vital.

There are many  intricate details of compliance regarding transport of waste, medications, and other hazardous materials that can alter the way in which you transport these items.

Information Needed - and required

At MedTrainer, we can help you to achieve compliance with the Department of Transportation regulations, by informing, educating, and training staff. The hazardous materials regulations changes were first on the horizon with Docket HM-181, providing  hazardous material transport standards copacetic with international standards to assist with foreign trade and maintain competitiveness for U.S. goods.

The latest in regulations designed to keep the U.S. operating in conjunction with international HazMat transportation laws appeared in July, 2003. Alterations in our operating practice have occurred due to the Twelfth revised edition of the UN Transport of Dangerous Goods-Model Regulations as well as Amendment 31 to the International Maritime Organization's IMDG Code; and the International Civil Aviation Organization's 2003-2004 ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air. All of this labyrinth of rules holds many  important changes affecting U.S. shippers and carriers of hazardous materials.

HM-215E is a particularly key piece of legislation that updates shipping descriptions, a problem that many shipper have due to a lack of knowledge about the new regulations. Making changes in the way in which your shipping is handled will prevent non-compliance with current HazMat regulations, and federal and state inspectors visiting and fining you.

Of particular interest are amendments to the Hazardous Materials Table (HMT) which have added, revised and removed certain hazard classes, packing groups, provision, authorizations, and even shipping names. Bulk packaging requirements have also changed. Staff responsible for transport must review the HMT entries that are new: added, changed and also deleted. Specific attention should be paid to the new proper shipping names for materials that your staff handles regularly.

Also review revisions and additions for special provisions, such as aerosol entries classifications, and flammable items. The toxicity and fire hazard of items has also changed. The proper shipping name in many cases must now include any subsidiary hazard.

Another new addition: a requirement that necessitates the number and types of packaging on shipping documents. An alternative basic description sequence is also now allowed.

Limited quality markings and air eligibility markings are also now a requirement. Packaging requirements themselves have also changed.

Additionally, there are have been revisions to requirements for air-transported packages, liquified and non- liquified gas transport, descriptions, and categories. There have also been more revisions to and additions on both the Self-Reactive Materials Table and the Organic Peroxide Table.

Class Acts

Classes of materials have also been revised overall: Hazard Class 1 represents explosives, Hazard Class 2 compressed gasses, Hazard Class 3: Flammable Liquids, Flammable solids are represented by Hazard Class 4. Hazard Class 5: Oxidizers and Organic Peroxides, Hazard Class 6: Toxic Materials,  Hazard Class 7: Radioactive Material  with subheadings for classification purposes of  Radioactive I , Radioactive II, and Radioactive III . Hazard Class 8 pertains to Corrosive Material that can cause destruction of the human skin, while a class 9 hazard refers to miscellaneous  material that can present a shipping hazard but doesn’t meet the definitions of the other classes.

Regardless of type, if a shipment contains a hazardous material, Hazmat General Shipping Procedures must be followed.  And what are these?

First, one must determine if the chemicals being shipped or offered for shipment are listed in
Hazmat Table 49 CFR Subpart B, 172.101. In this document, all hazardous waste is defined as
“A substance or material that the Secretary of Transportation has determined is capable of posing an unreasonable risk to health, safety, and property when transported in commerce, and has designated as hazardous under section 5103 of the Federal Hazardous Materials Transportation law (49 U.S.C. 5103).”

Hazardous Material Table

Next, the task is to refer to information contained in the hazardous materials table, indicating mode of transportation, descriptions and proper shipping names, class and division, as well as UN/NA identification number. The packing group, labels, special provisions, and packaging requirements are also described. There is also information referring to air or land transportation.

Packaging systems approved by the United  Nations Transportation Board must also be used as they’re designed to prevent any hazardous material escaping during transport. And correct markings and labeling are required for hazardous material shipment. If proper packaging and labeling is not employed? Well, naturally the package may not be delivered to their destination, but there’s worse possibilities afoot, other than the obvious health hazards for those handling or transporting the packages. For example: senders could be subjected to fines or even prison sentencing. Personal liability for any health risks that occur in transport is also possible.

Learn and Stay Safe

That’s a substantial risk for shipper to be taking, and arguably no one would undertake such a risk or create such a hazard willingly. However - that’s the risk medical shippers are taking if staff is not properly trained in compliance measures, which of course is where MedTrainer can help.

No time to instruct on numeric hazard class or packing techniques? Then MedTrainer’s proven teaching strategies can provide uniform training for all staff, and cover both compliance and safety issues in one fell swoop.

Just the correct completion of shipping papers required for hazardous shipments can take some getting used to. Certainly DOT shipping descriptions may be a given, but did you know that includes items such as dry ice? Yes, dry ice is a class 9 miscellaneous hazard that is classified by both DOT and IATA as a material that includes explosion, suffocation, and contact hazard.

As a class 9 hazard, dry ice is another material that requires a hazardous material declaration form to be attached to any shipment regardless of what else that shipment contains. And dry ice packaging must allow the release and venting of the gaseous carbon dioxide the ice contains - styrofoam box, cardboard outer cover, with a label indicating dry ice enclosed. All of this plus any required markings if the dry ice accompanies another hazardous material.

Now you may feel that some of this labeling, categorizing, packaging and more are onerous tasks, but they are designed for safety. The reason for fines and for the necessary compliance in the first place is to protect shippers, senders, handlers, and receivers from the hazards transported products may contain. In the same way, hazardous waste transporters themselves must follow their own requirements in order to be allowed to treat, recycle, store, or dispose of hazardous materials.

Safety First

Department of Transportation regulations for the transport of hazardous materials are key for safety all across the board, and stringent adherence to DOT guidelines and regulations is monitored. That means medical, dental, pharmacological, and veterinary staff members responsible for shipping hazardous materials, whether a medical product or a waste product, are also going to be carefully monitored. It's now a federal requirement that anyone preparing hazardous materials for transport must be trained before doing so and retrained every three years.

To prevent problems from health hazards to fines and monitoring, the best path is getting staff up to speed on DOT requirements and changes in regulations that have taken place in recent years. Compliance isn’t just a rote path to be followed here. It’s a necessity for safety, health - and the health and safety of your business and co-workers. Proper training is a way of life where DOT regulations are concerned.

1 comment:

  1. You make a good point about keeping safety first. I would think it is important to understand how to handle hazardous materials and what to do in case of an emergency involving the dangerous goods. It seems like it is safest to make sure you have the proper training and are familiar with the current regulations.