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