DOT Hazardous Materials

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DOT Hazardous Materials
Regulated Medical Waste

• Nathan Douglas, R.S., M.S.
• Chemical Biological Safety Officer
• Marshall University

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Why are we here?

• A person who knowingly violates a requirement
  of the Federal hazardous material transportation
  law, an order issued thereunder, is liable for
  a civil penalty of not more than 50,000 and not
  less than 250 for each violation, except the
  maximum civil penalty is 100,000 if the
  violation results in death, serious illness or
  severe injury to any person or substantial
  destruction of property, and a minimum 450 civil
  penalty applies to a violation relating to
  training. When the violation is a continuing one,
  each day of the violation constitutes a separate
  offense.

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Training Outline

• General awareness / familiarization
• Function-specific training
• Safety training
• Personal Protection
• Accident Avoidance
• Emergency Response
• Security awareness and in-depth training

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Regulations

• Several agencies have regulations that cover
  Regulated Medical Waste (RMW)
• also called biohazard waste, infectious medical
  waste, red bag trash, and regulated waste.
• Department of Transportation
• 49 CFR, subtitle B, Chapter 1, subchapter C
• Occupational Safety Health Administration
• 29 CFR 1910.1030
• West Virginia Department of Health Human
  Resources
• 64 CSR 56

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Hazardous Material Employee

• A person who is employed, and in the course of
  such employment directly affects hazardous
  materials transportation safety

Includes all employees that Load, unload, or
handle hazardous materials Prepare hazardous
materials for transportation Sign waste
transport manifest papers
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Training Requirements

• Hazmat employees must be trained when performing
  duties
• Refresher training is required every 3 years
• Must be directly supervised by a trained person
  until trained
• Training conducted within 90 days of hire or
  assignment of duties

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What is a Hazardous Material (HAZMAT)

• According to the US DOT
• 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.

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Hazardous Materials

• Dangerous goods are divided into 9 classes on the
  basis of the risk they present.
• They can be assigned more than 1 class if they
  present additional hazards
• Each class has a primary hazard, and can have
  numerous sub-hazards, called divisions.
• Vehicles transporting hazmat are required to
  display a placard indicating the hazard contained
  inside.

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US DOT Hazmat Class Division Placards
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Note

• There is a DOT exemption to placarding for RMW
  Division 6.2 materials, but the Bloodborne
  Pathogens Standard requires the biohazard symbol
  on containers used to store, transport or ship
  blood or other potentially infectious materials.
• The contractors truck will only have a biohazard
  sticker, not a 6.2 placard.

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Hazardous Material Packaging

• Each Class Division has established Packing
  Group requirements. Either PG I, II, or III
• The Packing Group indicates the degree of danger
  presented by the Hazmat, and determines the
  protective packaging required for safe transport
• PG I great danger, most protective packaging
• PG II medium danger
• PG III least danger, least protective packaging

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Our Hazardous Materials

• Class 2 Poisonous / Toxic
• Division 6.2, Infectious Substances
• Category B
• Biological Products
• Cultures
• Patient Specimens
• Regulated Medical Wastes

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DOT Hazardous Materials Table
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DOT Hazardous Materials Table

• 1. Symbols None
• 2. Description and Regulated medical waste,
  n.o.s.
• Proper Shipping Name Clinical waste,
  unspecified, n.o.s.
• (BIO)Medical waste, n.o.s.,
• Biomedical waste, n.o.s. or
• Medical waste, n.o.s
• 3. Hazard Class or Division 6.2
• 4. Identification Numbers UN3291
• 5. Packing Group (PG) II

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Regulated Medical Waste

• A waste or reusable material derived from the
  medical treatment of an animal or human, which
  includes diagnosis and immunization, or from
  biomedical research, which includes the
  production and testing of biological products.

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OSHA Regulated Waste

• Liquid or semi-liquid blood or other potentially
  infectious materials contaminated items that
  would release blood or other potentially
  infectious materials in a liquid or semi-liquid
  state if compressed items that are caked with
  dried blood or other potentially infectious
  materials and are capable of releasing these
  materials during handling contaminated sharps
  and pathological and microbiological wastes
  containing blood or other potentially infectious
  materials.

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WVDHHR Infectious Medical Waste

• Medical waste which is capable of producing an
  infectious disease. Medical waste shall be
  considered capable of producing an infectious
  disease if it has been, or is likely to have
  been, contaminated by an organism likely to be
  pathogenic to healthy humans, if such organism is
  not routinely and freely available in the
  community, and such organism has a significant
  probability of being present in sufficient
  quantities and with sufficient virulence to
  transmit disease.

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Sharps

• Any object contaminated with a pathogen or that
  may become contaminated with a pathogen through
  handling or during transportation and also
  capable of cutting or penetrating skin or a
  packaging material.

• Includes needles, syringes, scalpels, broken
  glass, culture slides, culture dishes, broken
  capillary tubes, broken rigid plastic, and
  exposed ends of dental wires.

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Package the Material

• Regulated medical waste must be packaged at the
  Packing Group II performance level and meet
  general packaging requirements
• PG II exception for private/contract carriers
• Inner containers must be packed with closures
  upward if they contain liquid hazardous materials

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Packaging Requirements

• Inner bag with minimum thickness of 1.5 mil
• Sharps containers must be securely closed to
  prevent spills or protrusions
• Top of bag closed by tying in a knot or twisting
  and folding over, then tightly taping
• Shipping container snapped closed or cardboard
  box taped shut on all seams

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Packaging Requirements

• Package filled and its contents limited so under
  normal conditions of transportation there is no
• release of hazardous material to the environment
• substantial reduction in the effectiveness of the
  package
• chemical reaction with or inside the package
• breakage, leakage or movement of the inner
  packaging

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Additional Requirements

• Items like staples do not protrude through the
  outer packaging in a way that would damage the
  inner packaging.
• The package is not filled to a gross mass greater
  than the maximum gross mass marked on the
  packaging (Standard 18 x 18 x 22 boxes are
  limited to 45 lbs).
• No hazardous material may remain on the outside
  of a package after filling.
• A package containing inner packagings of Division
  6.2 materials may not contain other hazardous
  materials.

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Package Markings

• General marking requirements
• Proper Shipping Name and Identification Number
• Package Orientation Arrows
• Generating Facilitys Name and Address
• WV Requires the package to be dated once full
• Markings must be
• Durable, in English, and printed on the surface
  or on a label, tag, or sign
• Displayed on a contrasting background
• Unobscured by labels or attachments

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Biohazard Labeling in the Bloodborne Pathogens
Std.

• Warning labels shall be affixed to containers of
  regulated waste.
• Labels have to have biohazard symbol wording
  per OSHA Bloodborne Pathogen Standard

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Pathologic Waste

• Stericycle uses a labeling system to
  differentiate between packages of Regulated
  Medical Waste that can be autoclaved and those
  that must be incinerated.
• Pathologic and trace chemotherapeutic wastes must
  be incinerated. We should use incinerator-only
  for pharmaceuticals.
• Our Generator Label is typically white. Yellow
  labels are used for incinerate-only waste.

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Manifest - Shipping Papers

• All manifests will have the following
• Identification Number (UN 3291)
• Proper Shipping Name (Regulated Medical Waste,
  n.o.s.)
• Hazard Class or Division (6.2)
• Packing Group (PG II)
• Description of the shipping container
• The manifest must also include, the total
  quantity of material shipped.

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Manifest Shipping Papers

• Quantity of Materials Shipped
• Usually report number of containers and volume in
  cubic feet
• Boxes are generally 4.3 cu ft.
• Can also be reported by weight per box, and total
• You should verify that the total quantity shipped
  block is the same as the number of boxes removed
  from the facility

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Completing the Manifest

• Manifests also contain Shippers Certification
• This is to certify that the above named materials
  are properly classified, described, packaged,
  marked and labeled, and are in proper condition
  for transportation according to the applicable
  regulations of the Department of Transportation.
• Must be signed legibly by a trained employee.
• Indicates that we agree with the volume (number
  of containers) of waste sent off-site

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Safety

• OSHA Bloodborne Pathogen Standard
• Mandates that employers provide a safe and
  healthy work environment
• Provide Hepatitis B vaccination
• Provide required PPE and ensure it is used
• Provide training on HBV and HIV and other
  bloodborne pathogens annually
• Have a written Exposure Control Plan, revised
  annually, evaluate safer sharps systems and use
  them where feasible

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Personal Protection

• OSHA Bloodborne Pathogen Standard
• Requires employees to observe Universal
  Precautions
• Treat all contaminated items like theyre
  infectious
• Wear appropriate PPE
• Handle and dispose properly
• Healthcare personnel have 2 main PPE
• exam gloves and clothing (scrubs).
• Face masks used where splashes/sprays are
  anticipated, must also use safety glasses/goggles

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Accident Avoidance

• Most common healthcare accident is needlesticks
• Extra care must be exhibited when working with
  children that squirm
• Sharps containers must be replaced when contents
  reach the full line, not allowed to overfill
• Containers must be securely closed before theyre
  moved out of the exam room

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Emergency Response

• 1st Needlestick
• Follow Exposure Control Plan available on
  employee web site
• Wash the affected area with soap and water
• Notify department Collateral Duty Safety Officer
• They will identify the source patient for
  testing, obtain consent, and have specimen
  collected
• Immediately seek treatment at nearest Emergency
  Department
• Identify yourself as having been exposed to BBP
• Prophylaxis should be given within 1-2 hours
• Request a Workers Compensation form be completed,
  not insurance

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Emergency Response

• Needlestick, cont
• Follow up with Internal Medicine Department
• They will discuss lab reports from source patient
  and exposed employee
• Provide consultation about potential diseases and
  recommended testing timeline
• Complete a Needlestick Incident Report and submit
  to Safety Officer
• Safety Officer will ensure information is
  complete and will review incident with
  post-exposure management team, and maintain
  records

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Emergency Response

• 2nd Spill of blood or OPIM
• For small spill (1 vaccutainer or less, 10 ml
  max)
• Cleanup should only be performed by persons
  trained in Bloodborne Pathogens
• Wear gloves
• Spray area with disinfectant
• Fresh bleach 110 dilution , or tuberculocidal
  product
• Use tongs or other mechanical means to pick up
  sharps and broken glass. Dispose in sharps box.

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Emergency Response

• Small Spill of Blood or OPIM, cont.
• Wipe up liquids with paper towel and dispose in
  biohazard bag.
• Spray the area of the spill with disinfectant
  again
• Allow 15 minutes contact time, or per
  instructions on container if duration is
  different
• Wash and disinfect mechanical devices used during
  cleanup
• Dispose gloves in biohazard bag

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Emergency Response

• Spill of Blood or OPIM
• For large spill (more than 1 vaccutainer, 10 ml)
• Secure the area from entry by unauthorized
  persons
• Put on appropriate PPE (gown, shoe covers, mask,
  etc.)
• Spray all containers and the entire spill area
  with disinfectant and allow 15 minutes contact
  time.

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Emergency Response

• Large Spill of Blood or OPIM
• Clean up sharps and liquids similar to small
  spill
• Disinfect area again, allow 15 minutes contact
  time, or per label instructions
• Clean and disinfect equipment
• Dispose single-use PPE. Biohazard if soiled,
  trash if not.
• Make arrangements to have spill kit replenished,
  as necessary.

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Security

• Marshall University, the Joan C. Edwards School
  of Medicine, University Physicians Surgeons,
  Inc. and the Marshall University Medical Center
  manage Regulated Medical Waste in a controlled
  manner where only authorized personnel have
  access to secured storage areas.
• Due to the nature of Regulated Medical Waste
  generation patients are in areas where waste is
  initially generated and temporarily stored.
• Waste is either treated on-site via autoclave or
  shipped off-site through a permitted contract
  service, documented by waste manifests that are
  retained for 3 years (WV requirement, DOT is 2
  years).

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Security

• Potential Threats
• Non-secured areas, or unattended points of entry
• Unauthorized personnel allowed access
• Prevention Techniques
• Know the driver(s)
• Look for an official uniform, ask for id when in
  doubt
• Report suspicious behavior

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Compliance Checklist

• Inner container (bag) is closed.
• Box is in good condition.
• Box does not weigh more than 55 lbs.
• Outside of box is not contaminated.
• Stericycle barcode sticker is attached, and date
  filled in when box/bin taped closed.
• Total quantity is written on shipping paper.
• Shipping manifest is legibly signed by trained
  employee.

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Conclusion

• DOT regulates the transportation of hazardous
  materials
• Proper identification
• Classification
• Packaging
• Training of personnel
• If you have questions, ask.
• Nathan Douglas, 696-3461
• douglas2_at_marshall.edu