Do you transport dangerous goods? IOSH - Hazardous Substances in Healthcare 20 April 2016
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1 Do you transport dangerous goods? IOSH - Hazardous Substances in Healthcare 20 April 2016
2 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
3 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
4 Dangerous Goods Classes Nine classes Some class are subdivided Hazard labels on retail packaging do not automatically mean the product is dangerous in transport
5 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
6 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
7 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
8 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)
9 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
10 Duty holders Consignor Carrier Consignee and other participants e.g. Loader Packer Unloader
11 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 , 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
12 Exemptions for small loads of packages ADR 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
13 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
14 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
15 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 required 4G/CLASS 6.2/12 GB/2450
16 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
17 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
18 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
19 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
20 Contaminated surgical instruments Used surgical instruments transported to central decontamination unit ADR 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
21 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 (b) carriage of equipment containing dangerous goods Only one condition ensure valve is closed and equipment is secure in vehicle
22 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
23 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
24 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
25 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
26 Frequently asked questions HSE website contains guidance on Carriage of Dangerous Goods and answers to FAQs
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