Do you transport dangerous goods? IOSH - Hazardous Substances in Healthcare 20 April 2016
Do you transport dangerous goods?
IOSH - Hazardous Substances in
Healthcare
20 April 2016
Carriage of dangerous goods
Carrying goods by road involves the risk of
traffic accidents
If the goods are dangerous, there is also the
risk of an incident, such as spillage, leading
to hazards such as
– Fire
– Chemical burns
– Environmental damage
Dangerous goods
Substances or articles that have been tested
and assessed
– against internationally agreed criteria
– a process called classification
– and found to be potentially hazardous when
carried
– road carriage is prohibited by ADR or authorized
only under the conditions prescribed by ADR
Dangerous Goods Classes
Nine classes
Some class are subdivided
Hazard labels on retail
packaging do not
automatically mean the
product is dangerous in
transport
Packing Group
While Class defines the type of danger,
Packing Group defines how dangerous it is
Three packing groups– PG I - most dangerous
– PG II - moderate danger
– PG III - least dangerous
A substance might appear in more than one
PG depending on its concentration
International Regulation
Each mode of transport has its
own international regulations,
updated every 2 years
– IATA for air
– IMDG for sea
– ADR for road
They are largely harmonised
through UN Model Regulations
National regulation for road
transport
The Carriage of Dangerous Goods and Use
of Transportable Pressure Equipment
Regulations 2009
Regulation 5 – no person may carry, or
cause or permit dangerous goods to be
carried where carriage is prohibited or does
not comply with ADR
Enforcement
In GB, Department for Transport is lead
department, Health and Safety Executive,
DVSA and Police carry out vehicle checks
Office for Nuclear Regulation covers Class 7
(Radioactive)
In NI, HSENI for all classes (except Class 7,
which is covered by NI Environment
Agency)
ADR
Available online (Google ADR2015 UNECE)
Highly prescriptive but structured logically
– Part 1 Aims, duties and exemptions
– Part 2 Classification (assignment of UN number)
– Part 3 The dangerous goods list
– Part 4 Packing instructions
– Part 5 Documentation and vehicle marking
– Part 6 Construction and testing of packages
– Parts 7 to 9 Carriage, vehicle crews, equipment
Duty holders
Consignor
Carrier
Consignee
and other participants e.g.
– Loader
– Packer
– Unloader
Dangerous Goods Safety
Adviser
Each undertaking whose activities include
carriage, packing, loading or unloading of
dangerous goods by road must appoint a
DGSA to help prevent risk
– But not if the quantities are less than referred to in
ADR 1.1.3.6, 1.7.1.4 and Chapters 3.3, 3.4 and 3.5,
or
– It’s not the undertaking’s main or secondary activity
and carriage is occasional and poses little danger
Exemptions for small loads of
packages – ADR 1.1.3.6
Exempted
Placarding and marking
of vehicle
Transport documents
Vocational driver
training
DGSA appointment
Not exempted
General training
Fire extinguisher in cab
Packaging UN type
tested
Exemption for limited
quantities – ADR Chapter 3.3
Small receptacles typically of the sort that
go into the retail distribution chain
Safety is assured if receptacles are in a box
or shrink wrapped
Maximum receptacle size specified in ADR
Certain conditions apply, but most of ADR
does not apply
Do you transport dangerous
goods and do you need to
appoint a DGSA?
Typical healthcare hazardous substances
– Infectious substances/ biological specimens
– Radiopharmaceuticals
– Medicines
– Contaminated instruments
– Compressed medical gases
– Clinical Waste
Infectious substances
Infectious substances transported by labs
Class 6.2 Category A (e.g. ebola, rabies)
Transported in small volumes for testing
UN 2814
No exemption for small quantities
Full application of ADR
DGSA required4G/CLASS 6.2/12
GB/2450
Biological specimens
Specimens transported to laboratories
from GP surgeries
Class 6.2 Category B
UN 3373
ADR special packing provision P650
Not subject to any other ADR
requirements
Radiopharmaceuticals
Transported daily to nuclear medicine
departments for diagnostic imaging
Class 7 UN 2915
No exemption for small quantities
Special requirements (radiation protection
programme, emergency plan)
DGSA required
Medicines
Pharmacy transports medicines between
hospital sites – toxic hazard
Class 6.1 UN1851 (liquid) and UN3249
(solid)
Special provision 601 – medicines ready
for use and packaged for retail distribution
for personal consumption are not subject
to ADR
Cytotoxic medicines
Cytotoxic medicines reconstituted on one
hospital site and transported to another site
Not for retail sale or distribution
SP601 does not apply - ADR applies
Small load exemptions if <333kg – transport
documents and DGSA not required
Other exemptions if limited quantity
Contaminated surgical
instruments
Used surgical instruments transported to
central decontamination unit
ADR 2.2.62.1.5.9 – ADR does not apply if:
– Category B infectious substance
– Carried for cleaning or sterilisation
– In packages that won’t break or leak
– Withstand drop from 1.2 m
– Marked “USED MEDICAL EQUIPMENT”
Compressed medical gases
Compressed oxygen to clients homes
Transported as ‘ready to use set’, with
regulator hose and mask
Exemption from ADR by virtue of ADR
1.1.3.1(b) – carriage of equipment
containing dangerous goods
Only one condition – ensure valve is closed
and equipment is secure in vehicle
Clinical waste
Clinical waste transported on public road
within hospital sites and between hospital
sites
Class 6.2, PG II - low probability of
containing infectious substances
UN 3291
Small load exemptions if load <333 kg
Clinical waste packages
Rigid packaging ‘sharps box’
– Packing instruction P621
– UN approved package
– Clinical waste bags are not approved packages
Large packaging ‘wheelie bin’
– Packing instruction LP621
– UN approved package
– Waste contained in clinical waste bags
Clinical waste exemptions
Small load exemptions if <333 kg
Remaining requirements:
– Fire extinguisher 2 kg (except for healthcare
workers who transport <15 kg waste arising
from patient treatments)
– General training
– Properly loaded to prevent damage to packages
– All packages to be marked with UN approval
code, UN3291 and labelled with Class 6.2 label
Bulk carriage of clinical waste
Clinical waste bags may be carried in bulk in
specially equipped vehicles under special
condition VC3
– Commercial vans will not generally meet the
leakproof criterion
– No exemptions for small loads
– ADR applies
– DGSA required
Frequently asked questions
HSE website contains guidance on Carriage
of Dangerous Goods and answers to FAQs
http://www.hse.gov.uk/cdg/index.htm