Transportation Of Dangerous Goods

1
Transportation Of Dangerous Goods

• Requirements for Healthcare Wastes

2
Summary of Issues

• Application of CDGTPE 2004 Amendments 2005
• Definition of Infectious for Transport
• UN Numbers used for Clinical Waste
• Implications of the Changes in ADR/CDGTPE 2005
• UN Numbers used for Pharmaceutical Cytotoxic
  Wastes
• Packaging Used
• Load Thresholds
• Rigid Containers vs. Bulk Waste
• ADR Training
• Vehicle Equipment
• Reports on Accidents/Incidents
• New requirements of ADR 2007 CDGTPE 2007
• Summary of Responsibilities

3
CDGTPE 2004 Amendments 2005

• The Carriage of Dangerous Goods and Use of
  Transportable Pressure Equipment Regulations 2004
  (CDGTPE) and the CDGTPE (Amendment) Regulations
  2005.
• Apply to the carriage of dangerous goods by road
  and rail.
• They place general duties on everyone with a role
  in the carriage of dangerous goods, and specific
  duties on those in the transport chain, i.e.
  consignors, carriers, loaders, packers, etc.
• Refer to the European Agreement concerning the
  International Carriage of Dangerous Goods by Road
  2005 (ADR 2005) and Regulations concerning the
  International Carriage of Dangerous Goods by Rail
  2005 (RID 2005)
• They replaced (in May 2004), by a single
  Statutory Instrument (SI), 12 previous SIs that
  regulated the carriage of dangerous goods by road
  and rail in GB.

4
Definition of Infectious for Transport

• The term infectious is referred to in a number
  of EEC Directives, particularly those
  affecting waste management
• In each one, due to the background to the
  Directive, a particular definition is given to
  the term infectious
• The major consideration of the term infectious
  and the transportation of infectious material in
  the UN Model Regulations (from which ADR and
  CDGTPE are derived) is directed towards the
  transport of diagnostic specimens and cultures
• For the purpose of ADR, infectious substances are
  those substances known or reasonably expected to
  contain pathogens

5
CDGTPE 2005

• Adoption of the 13th Edition of the UN
  Recommendations on the Transport of Dangerous
  Goods, ADR 2005 (applicable from 1st July 2005)
• This contains a revised definition of infectious
  substances and clinical waste
• This is referenced in CDGTPE (Amendment)
  Regulations 2005
• Prior to the current changes in legislation,
  classification of infectious substances was based
  upon assignment to a Risk Group, according to
  the hazard posed in a laboratory environment
  (Risk Groups 1 to 4).
• The use of WHO Risk Groups 1 to 4 is superseded
  by the revised WHO system of Category A and B
  infectious substances in ADR 2005.
• There is no direct relationship between the old
  style WHO Risk Groups and Category A and B
  infectious substances.

6
CDGTPE 2005

• Category A An infectious substance which is
  transported in a form that, when exposure to it
  occurs, is capable of causing permanent
  disability, life-threatening or fatal disease
  to humans or animals
• Category B An infectious substance which does not
  meet the criteria for inclusion in Category A
• Example of substances included on the Category A
  list
• Bacillus anthracis (cultures only) Ebola
  virus Escherichia coli, verotoxigenic
  (cultures only) Hepatitis B virus (cultures
  only) Lassa virus Marburg
  virus Rabies virus Classical swine
  fever virus Foot and mouth disease virus

7
UN Numbers Used for Infectious Substances,
Clinical Waste and Diagnostic Specimens (Class
6.2)

• There are four UN numbers that can be used to
  classify goods that contain infectious substances
  or pathogens as dangerous goods for transport.
• Substances assigned to Category A must be
  consigned/shipped as either UN2814 or UN2900 as
  appropriate and
• Clinical wastes containing Category A infectious
  substances shall be assigned to UN 2814 or UN
  2900 as appropriate.
• UN 2814 INFECTIOUS SUBSTANCE, AFFECTING HUMANS
  only
• UN 2900 INFECTIOUS SUBSTANCE, AFFECTING ANIMALS
  only

8
UN Numbers Used for Infectious Substances,
Clinical Waste and Diagnostic Specimens (Class
6.2)

• If an infectious substance does not meet the
  classification criteria of Category A then it is
  assigned to Category B.
• Substances assigned to Category B must be
  consigned/shipped as UN 3373 or UN3291
• UN 3291 CLINICAL WASTE UNSPECIFIED, N.O.S. or BIO
  MEDICAL WASTE, N.O.S. or REGULATED MEDICAL
  WASTE, N.O.S.
• UN 3373 DIAGNOSTIC SPECIMENS

9
What Implications Do these Regulations have on
Clinical Waste Producers?

• There is no change to the way in which producers
  package, label or store clinical waste.
• Medical or clinical wastes containing infectious
  substances in Category B must be assigned to UN
  3291 Clinical waste, unspecified, n.o.s. or (Bio)
  Medical waste, n.o.s. or Regulated medical waste,
  n.o.s.
• If producers have clinical wastes that fall into
  Category A, i.e. contaminated with Category A
  pathogens, they have to package and label their
  waste accordingly. Packaging differs to that of
  UN 3291 Clinical Waste and the advice of a
  qualified Dangerous Goods Safety Advisor (DGSA)
  should be sought.
• If producers have specimens they should be
  classified as UN3373 Clinical Specimens or
  Diagnostic Specimens. Packaging differs to that
  of UN 3291 Clinical Waste and the advice of a
  qualified DGSA should be sought.

10
What about Avian Influenza Virus?

• Avian influenza, or bird flu, is a communicable
  disease caused by viruses that normally infect
  only birds but on rare occasions have infected
  humans.
• Subtype H5N1 is the most notable at present
• Main route of human infection is presently
  considered to be by direct contact with surfaces
  and objects contaminated with faeces.
• Human to human spread of the disease is very
  rare, if it occurs at all.
• Avian influenza can be considered as a new or
  emerging pathogen which is capable of causing
  life threatening or fatal disease in otherwise
  healthy humans or animals.
• Is it a Category A pathogen for the purposes of
  transportation?

11
Classification of Avian Influenza Virus

• Classification is based on the form in which a
  specimen is to be transported
• Category A cultures, faeces, carcasses or
  other products (e.g. blood) derived from animals
  known or suspected to have been infected with
  A(H5N1) avian influenza virus
• Category B human blood and other human
  samples known or suspected to contain the
  A(H5N1) subtype, or cultures, faeces, carcasses,
  blood or other samples known or suspected to
  contain any other subtype of avian influenza
  virus
• Further advice is available at
• www.who.int/csr/disease/avian_influenza/avian_fa
  qs/en/index.html

12
Pharmaceuticals and Cytotoxic Wastes

• The widespread use of UN 3291 is inappropriate
  for waste chemicals and medicines that do not
  contain infectious substances.
• Pharmaceutical and cytotoxic wastes can be
  classified as UN 3291 provided that the waste has
  been in direct contact with a patient, e.g.
  disposable gloves, soiled dressings, swabs,
  fully/partially discharged syringes etc
• Response from the Health and Safety Executive,
  Safety Policy Division, Transport of Dangerous
  Goods on the selection and use of UN numbers for
  the transportation of pharmaceutical wastes
• The use of UN 3291 is wrong since pharmaceutical
  wastes are not infectious substances. They would
  have to be classified as a toxic substance, which
  is defined as a substance that is liable to
  either cause death or serious injury or to harm
  human health if swallowed or inhaled or by skin
  contact. 
• Pharmaceuticals would have to be classified to
  ascertain their qualities and determine what
  precautionary measures need to be taken before
  transporting the goods.

13
Pharmaceuticals and Cytotoxic Wastes

• The following UN numbers should be used in place
  of UN 3291 when transporting drugs and other
  pharmaceutical products
• UN 1851 MEDICINE, LIQUID, TOXIC, N.O.S.
•  
• UN 3248 MEDICINE, LIQUID, FLAMMABLE, TOXIC,
  N.O.S.
•  
• UN 3249 MEDICINE, SOLID, TOXIC, N.O.S.

14
Packagings Used

• Dangerous goods moving nationally or
  internationally have to be carried in UN-approved
  packagings
• They are designed and performance tested to the
  standards set out in The Model Regulations to
  ensure that they are strong enough to be handled
  through transport systems under normal conditions
  without failure
• Performance testing is carried out under national
  arrangements on a prototype batch of packagings
  provided by the manufacturer
• If successful, a certificate is issued by the
  approved testing station (e.g. PIRA) which may
  have certain conditions attached to be followed
  by users and shippers

15
Packagings Used

• UN-approved packagings can be recognised by the
  following
• UN 5H2/Y10/S/02/GB/4657
• This means that the packaging is UN
  approved A plastic bag (woven and
  sift-proof) For Packing Groups II and
  III Tested to a capacity of 10kg For
  solid material only Manufactured in
  2002 Approval obtained in GB Manufacture
  r reference 4657

16
Packagings Used

• Limited Quantities are dangerous goods small
  enough in quantity not to require the provisions
  with regard to packaging, marking and labelling
• Limited Quantities do not apply to all classes of
  dangerous goods, e.g. they apply to goods in
  Class 6.1 (e.g. pharmaceuticals) but not to those
  of Class 6.2 (e.g. clinical waste)
• A transport document is not required
• These primary exemptions apply to individual
  receptacle and packaging quantities, not the mass
  of the load as a whole

17
Changes Implemented by CDGTPE Load Thresholds

• Under The Carriage of Dangerous Goods by Road
  Regulations 1996 (CDGRoad) load limits were set
  out in Table 2 of Schedule 1 as follows

18
Changes Implemented by CDGTPE Load Thresholds

• These load limits changed under CDGTPE 2004 to
  the following

19
Changes Implemented by CDGTPE Load Thresholds

• It should be noted from this that the package
  size threshold of CDGRoad has been dropped and
  that now every container, regardless of size,
  will count towards the load size.
• For example, previously under CDGRoad clinical
  waste of Transport Category 2 could be
  transported in rigid containers or in yellow
  clinical waste bags inside rigid containers
  (wheelie bins) and were defined as packages.
• Provided that each individual package weighed
  less than 10kg, the load size was not applicable
  as the package did not exceed the threshold to
  count towards the load size.
• Now, under CDGTPE all containers and yellow bags
  will count towards the load size/threshold.
• Once the load threshold is reached there is a
  requirement to apply the Regulations in full.

20
Clinical Waste Rigid Containers vs. Bulk Waste

• Rigid containers transported on vehicles will
  have to be kept below the 333kg threshold to
  avoid orange plating the vehicles.
• If the vehicles require orange plates, drivers
  will require in-house training provided their
  vehicle does not exceed 3.5 tonne (max.
  permissible weight), TREMcards, relevant PPE,
  emergency equipment etc as set out in ADR 2005
  Chapter 8.1.5.
• If the vehicle exceeds 3.5 tonnes then driver ADR
  training is required and the associated
  equipment/documentation as detailed above.
• ADR training will become a requirement for
  drivers of all vehicles regardless of maximum
  permissible weight from July 2005 (transitional
  period until January 2007) if transporting
  dangerous goods over the load threshold values.
• If transporting clinical waste in bulk the
  Regulations apply as soon as waste
  is placed on the vehicle.

21
Requirements of the training and examination
regime

• The drivers will be required to undertake the
  following teaching units
• Core including Security - this requirement is
  mandatory
• Drivers transporting clinical waste will then be
  required to complete the following additional
  teaching units
• Packages
• Class 6

22
Dangerous Goods Security a new requirement ?

• In response to the events of 11 September 2001,
  the United Nations agreed proposals to enhance
  the security of transporting dangerous goods.
  These proposals were published in the 13th
  revised edition of the UN Model Regulations in
  December 2003.
• New regulations for the security of transporting
  dangerous goods in Great Britain came into force
  on 22 July 2005. These regulations are based
  entirely upon the new security requirements laid
  out in the international agreements for the
  transport of dangerous goods by road and rail.
• The new security regulations will require any
  company or organisation that is involved in the
  transport of dangerous goods to
• only offer dangerous goods to carriers that have
  been appropriately identified
• make sites that temporarily store dangerous goods
  secure
• have a security awareness training programme in
  place and,
• have a security plan in place, if involved with
  high consequence dangerous goods.
• Further advice can be found at www.dft.gov.uk

23
Vehicle Equipment

• Vehicles will be required to ensure that all of
  the emergency equipment listed in ADR 2005
  Chapter 8.1.5 is carried and is fully functional
  on vehicles with a maximum permissible weight
  greater than 3.5 tonnes
• This includes wheel chocks, warning markers,
  hi-viz vests, torch (suitable to load) TREMcard
  and relevant PPE, fire extinguishers (cab and
  load compartment)
• If only on a journey solely within the UK there
  is no requirement for wheel chocks (Authorisation
  24)
• Only a requirement for one 2kg dry powder fire
  extinguisher in the vehicle cab if solely
  transporting clinical waste (UN 3291)

24
Reports On Accidents and Incidents

• If a serious incident occurs during the
  transportation of dangerous goods there is a need
  to comply with ADR Section 1.8.5.1 and report to
  the national authority, e.g. DfT in the UK. This
  relates to a transport related injury as a direct
  result of the carriage of the dangerous good
  itself.
• ADR does not specify a time scale in which to
  submit this report, and the new UK domestic
  regulations mirror ADR.
•  
• Please note that this is in addition to the
  requirement to report the incident under the
  Reporting of Injuries, Diseases and Dangerous
  Occurrences Regulations 1995 (RIDDOR).
•  

25
Changes - ADR 2007 CDGTPE 2007

• ADR 2007 is due to come into force in July 2007
• New domestic regulations will also come into
  force in July 2007
• Authorisation 53 allows the anticipation of
  certain changes adopted for the 2007 editions of
  ADR and RID
• Authorisation 53 is valid from now until the 2007
  editions are referenced in the CDGTPE Regulations
  (July 2007)
• Changes relate to dangerous goods as a whole but
  there are some changes specific to Class 6.2
  Infectious Substances

26
ADR 2007 CDGTPE 2007 Class 6.2 Infectious
Substances

• Definition of cultures has been amended.
• New definition of patient specimens has been
  added.
• Clinical waste has been linked to environmental
  legislation, in particular the European Waste
  Catalogue and WM2 (Joint Agencys Technical
  Guidance on Hazardous Waste)
• Hazardous infectious wastes (18 01 03 18 02 02)
  UN3291 Clinical Waste dangerous goods for the
  purpose of transportation
• Non-hazardous wastes (18 01 04 18 02 03) not
  dangerous for the purpose of transportation

27
ADR 2007 CDGTPE 2007 Class 6.2 Infectious
Substances

• New conditions for transportation of wastes of
  Class 6.2 (UN 3291) in bulk
• Bulk containers and openings are to be leakproof
• Waste in leakproof plastics sacks/bags new
  tests for impact and tear resistance
• Single articles exceeding 30kg do not need to go
  in a plastic sack/bag, e.g. soiled matresses
• Labelling emboss Class 6.2 label onto wheelie
  bins directly
• Print must be black
• Background must be of contrasting colour
• Authorisation 38 valid until 31st December 2015

28
Summary of Responsibilities

• Consignors are required to Identify the
  goods Package the goods accordingly Labe
  l the goods accordingly Provide a transport
  document (this can be a combined waste
  transfer note and transport document)
• Carriers are required to Provide a suitable
  vehicle Ensure that the consignor has
  fulfilled their duties as detailed
  above Provide emergency equipment as
  detailed in the TREMcard and also under the
  provisions of ADR Ensure that drivers
  are trained in accordance with
  ADR Ensure that vehicles are
  marked/placarded as per the requirements of
  ADR

29

• Dr Nick Williams
• Safety, Health and Environmental Manager DGSA
• PHS Group Plc
• E-mail nickwilliams_at_phs.co.uk
• Tel [phone]