Connecting the DOTs

By Dan Scungio, MT(ASCP) SLS

 

 

 

It’s that time of year! Black Friday and Cyber-Monday have come and gone, and now all of your packages are traveling…some by ground, some by air, some via the United States Postal Service (USPS), and others by UPS or FedEx.  Sometimes hazardous laboratory specimens and materials travel this way, and sometimes we send them via a courier service.  Sometimes we send them at room temperature, and sometimes we send them with dry ice.  Did you know there were safety rules regulating all of this? Of course you did!

 

If you pack or ship laboratory specimens or if you affect the packing or shipping of specimens (that are hazardous materials), you not only need to be aware of the rules, but you are required to have specific training at least every three years.This training is required by the Department of Transportation (DOT) and varies depending on the shipping task performed.  These tasks could be packaging and labeling, shipping of dry ice (by air or vessel), preparing documentation, or transporting.  The DOT does not offer a certification for specimen packing and shipping; only your employer can do that.

 

The Code of Federal Regulations (CFR) part 172.101 lists 9 classes of hazardous materials, separating and designating the hazards for the purpose of transporting those materials.  Class 6 covers toxic and infectious substances.  This class is further divided into division 6.1 (poisonous material) and 6.2 (infectious substances).  Therefore the majority of transported laboratory specimens and cultures fall under Division 6.2. These materials can be further sub-divided into categories A and B. If dry ice is added to the package, a Class 9 substance, more transport rules apply.

 

As you can see, classifying hazardous materials for transport is a complicated matter.  The DOT will not help with this, nor will the companies you use for shipping.  It is considered the responsibility of the shipper to properly classify their own items.  To aid in classification, the DOT provides a flow chart.  This chart can be found in the DOT brochure, “Transporting Infectious Substances Safely,” which can be found at www.phmsa.dot.gov/hazmat/training/publications.    The USPS also provides a flow chart for materials shipped by that agency at pe.usps.gov/text/dmm300/601.htm#wp1064962. You can also obtain these materials in print form at no charge by request.  If you need further assistance with classification, your state public health lab may be willing to help you.

 

Once you have classified your item for transport, it is time to package it properly and label the package for transport.  Most Division 6.2 material must be shipped in triple-packaging; a leak-proof primary container, a rigid and leak-proof secondary container, and an outer package that’s large enough both for the contents and for the required labeling.  OSHA requires that inner packaging must have bio-hazard labeling human blood or other potentially infectious material no matter is classification.  If shipping by USPS, an inner bio-hazard label is required even if the item is an animal or other non-regulated specimen.   Correct outer labeling of packages varies by class, and includes items such as specific category (A and B) labels, emergency response information, and dry ice information.

 

If you use private couriers for specimen transport, the DOT gives a packaging exception known as “Material of Trade.”  The exception allows for less stringent packing and labeling for specimens (not including cultures).  This means that there must be only inner packaging and strong, tight outer packaging with only limited labeling.  You may transport cultures in these same vehicles, but they should be packaged separately with the proper labeling.  If that is too cumbersome, you can transport specimens and cultures together all labeled under the culture labeling regulations.  During transport, the packages should be strapped or wedged inside the vehicle.

 

So let’s connect the dots, training…classification…packaging…transport.  For many laboratory specimens this is a highly complex process with many rules and regulations surrounding it.  I did not come close to telling the whole story here.  There was no discussion about the specific documentation required.  I did not mention the International Air Transport Association (IATA), a major regulatory agency whose regulations affect any air transport or even ground shipping by agencies that can ship by air.  There are proper shipping names that must be used for substances, United Nations designations and special permit requirements! 

 

As mentioned earlier, not everyone involved in packaging and shipping needs to know everything about each step in the process, but it is clear that you must provide thorough training for the employees based on their tasks. Look on line for training DVDs or you may be able to have an expert come in to provide training.  Safety Lady LLC had a 25 minute DVD that meets DOT, IATA and CAP requirements for shipping education.  It comes with 1 contact hour of P.A.C.E.® that meets most state requirements for licensure.  For more information go to:   http://www.safetylady.com/product_gallery/.  The Shipping DVD is the 8th product on the page.  By following the shipping regulations, you keep yourself safe, and you also keep others who handle your shipments safe as well.