Environmental Health and Safety

DOT Hazardous Materials Regulated Medical Waste Post-Test

Name: Title:

Department: PI/Supervisor:

Work (BLDG/RM): Email: *NOTE* By completing this test, you are confirming that you have viewed the entire training presentation. 1. Which agency regulates the transportation of hazardous materials?

a) EPA b) DOT c) OSHA d) NFPA

2. Who is required to provide training for hazmat employees? a) Hazmat employer b) Hazmat employee c) DOT d) OSHA

3. Which of the following materials would be labeled as a Class 6.2 material? a) Propane b) Biohazard waste c) Methanol d) Sulfuric Acid

4. What is the packaging group assignment for Regulated Medical Waste? a) Packaging group I b) Packaging group II c) Packaging group III d) No packing group

5. US DOT requires shipping papers must be retained by the shipper for: a) 1 year b) 2 years c) 365 days d) 375 days

T u f t s E H S D O T R M W T r a i n i n g T e s t | 2 0 1 5

2 | P a g e 200 Harrison Avenue, Boston, MA 02111 ι TEL: 617.636.3615 ι FAX: 617.636.2419

6. DOT trained employees must go through recurrent training a minimum: a) Once every year b) Once every two years c) Once every three years d) Once in a lifetime

7. Identify the security training area(s) required for registered hazmat offerors: a) Security awareness training b) In-depth security training c) Security awareness and In-depth security training

8. Chemicals can enter the body by: a) Inhalation, ingestion, injection, skin absorption b) Ingestion, coughing, mucociliary response c) Injection, inhalation, sneezing, coughing d) Skin absorption, coughing, sneezing, mucociliary response

9. The red bag must be hand tied by gathering and twisting the neck of the bag and using a tie or single knot. a) True b) False

10. When you sign the shipping papers, you are certifying that: a) You are trained to sign them. b) Materials to be shipped are properly described. c) Materials are properly packaged, marked, and labeled per DOT. d) Agreement to the volume being shipped. e) All of the Above.

*NOTE* By completing this test, you are confirming that you have viewed the entire training presentation. Return completed test to Tufts EHS (ehs-training@tufts.edu). If you are unable to send via email, please print out and send interdepartmentally to: Environmental Health & Safety; Posner 105, 200 Harrison Avenue; Boston To Be Completed By TEHS Staff: Completion Date: Expiration Date: Score:

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DOT Hazardous Materials Regulated

Medical Waste TrainingPrepared In Accordance with the:

US Department of Transportation Hazardous Materials Regulations; and OSHA and Mass.

Department of Public Health

Environmental Health and Safety2013

DisclaimerThis training has been developed to specifically address the DOT training on the packaging and transportation of Regulated Medical Waste.

This training is required for any employee to sign Stericycle manifests for sharps disposal and/or red bag waste. Employees must be re-trained and re-certified every 3 years.

Significant penalties can result if training requirements are not met.

Please contact the Tufts EHS at 617-636-3615 for assistance.

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Training Agenda• Introduction to the Applicable Regulations• General Awareness and Familiarization• Function Specific• Packaging • Marking and Labeling• Documentation• Safety • Security• Test

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Administrative and Regulatory AgenciesDOT hazardous material training regulations; 49 CFR 172.700DOT requires each employee who affects hazardous material transportation to receive this training. 2 main functions in a hospital, university setting:• Preparing the package for transport• Signing shipping papers

OSHA- 29CFR 1910.130, blood borne pathogen standard & RMW definitionEPA-Definition, Medical Waste Tracking Act 1988-1999; cradle to grave, segregation, packaging, labeling marking, MA DPH-105 CMR 480.00

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What is Regulated?• Hazardous materials or articles or substances which are capable of

posing a risk to health, safety, property or the environment when transported in commerce.

• DOT and EPA cross reference definitions to identify and define hazardous waste.

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General Awareness, Familiarization Applicability of The HMR• The Hazardous Material Regulations (HMR) can be found in 49 C.F.R.

§ 171 through 180 (available on DOT web site at www.hazmat.dot.gov)

• The DOT HMR apply:o To all shipments of hazardous materials “in commerce;”o When loading, moving, unloading and storing any shipment of

hazardous materials that are still under active shipping paper; ando To hazardous materials under active shipping papers until they are

unloaded from the transporter’s truck onto the receiving entity’s property.

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Specific Responsibilities• Ensure that all materials offered for shipment are properly:

o Identified;o Classified; o Packed;o Marked; o Labeled; ando Accompanied by proper documentation.

• Provide training to employees that will enable them to carry out their responsibilities in compliance with the regulations.

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Training Requirements• Employers are required to provide training to Hazmat Employees.• Hazmat Employee is a person who is employed by a hazmat employer

and who in the course of employment directly affects hazardous materials transportation.

• You’re a hazmat employee if you assist in packaging hazardous materials or sign the shipping papers when offering hazardous materials for transport.

Frequency• DOT

o Within 90 days of employmento Every 3 years at a minimum, oro As often as the regulations change

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Training Records• Training records must include:• Individual’s name;• Most recent training completion date;• Description, copy or reference to training

materials used;• Name and address of the organization or

individual providing the training; and• Certification that employee has been trained and evidence that a test

has been completed satisfactorily.• Current training records must be kept during employment + 90 days• Documents must be kept on file in your office and available to any

transportation inspector upon request.

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Listed Hazardous MaterialsKnown to be harmful to human health and environment regardless of concentration

THREE TYPES

• Non-Specific source waster (F001-F039), solvents etc.• Specific source wasters (K001-K161), Typically not found @

universities or healthcare • Discarded commercial chemical products (P and U). Epinephrine,

ethylene oxide and certain unused pharmaceuticals.

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Characteristic Hazardous Waste • Flammable: material that is capable of causing fire through friction,

absorption of moisture or spontaneous chemical changes, or ignitable compressed gas, or an oxidizer.

• Corrosive: compound capable of corroding steel at rate greater than ¼ inch/yr.

• Reactive: material that is normally unstable, undergoes violent change without detonation, water reactive, forms potentially explosive mixtures or toxic gases with water. Cyanide or sulfide which can generate toxic gases.

• Toxic: Material that is acutely or chronically toxic to humans or environment. Regulated Medical Waste falls into this category per DOT as a poisonous material

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DOT ClassificationThere are 9 Classes of Hazardous Materials1. Explosive2. Gases3. Flammable Liquids4. Flammable Solids5. Oxidizing Agents6. Toxic and Infectious Agents

- 6.1 Toxic Substances- 6.2 Infectious Substances and Biological Substances

7. Radioactive8. Corrosive9. Miscellaneous

o Dry Ice, Genetically Modified Organisms, lithium batteries

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General Definitions• DOT has classified & defined the following as Class 6, Division 6.2

hazardous materials under 173.134

o Infectious Substances; a material known to contain or suspected of containing a pathogen, bacteria or micro-organism that can cause disease in humans or animals.

o Regulated Medical Waste (RMW)

o Biological Specimens, Category and Category B

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Categories of 6.2 Infectious Substances • Category A Infectious Substance:

Substance in a form capable of causing permanent disability or a life threatening/fatal disease in a healthy human or animal upon exposure.

• Category A material should NEVER be placed in a Red Bag liner or a Regulated Medical Waste container.

• All Category A waste is autoclaved before disposal.

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Categories of 6.2 Infectious Substances • Category B Infectious Substance UN3373:

A substance that does not meet the definition of a Category A Infectious Substance.

• Will not kill or cause permanent disability.

• Category B infectious substance which is a waste culture, stock or any other waste or reusable material can be transported as Regulated Medical Waste (RMW) and assigned UN3291

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Regulated Medical Waste (RMW) USDOT• Any infectious substance that is not a Category A (capable of causing

permanent disability or life threatening or fatal disease) can be transported as Regulated Medical Waste (RMW).

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Regulated Medical Waste (RMW) OSHA• Liquid or semi-liquid blood or other potentially infectious material

• Contaminated items that would release blood or other potentially infectious materials in a liquid or semi-liquid state if compressed. This includes body fluids or blood that is dried or caked and has the potential to flake if handled.

• Contaminated sharps.

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Regulated Medical Waste (RMW) Pathological Wastes• Includes recognizable human or animal tissue or body parts. States

have specific definitions.

• Found in Histology, Pathology or Morgue.• May require special labeling on containers• May require special treatment. State may have additional specific

regulations. MA requires this waste to be incinerated.

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Regulated Medical Waste (RMW) Chemotherapy Waste• Includes items used in the preparation or administration of chemo

that may become contaminated with chemotherapeutics.o Empty vialso Empty IV bagso Needles, syringeso Gloves, gowns

• Found in the pharmacy, caner centers, oncology units and research facilities.

• May require special labeling on containers• May require special treatment; do not autoclave, incinerate only.

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Packaging• The Hazardous Materials Table @ 49CFR172.101 should be referenced

when packaging hazardous materials.

• The packaging should be durable and secure enough to keep the public and environment safe during transportation.

• Markings and labels should indicate the degree of danger the material presents during transportation in commerce.

• The packing group (PG) indicates the packaging requirements.

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Hazard Class, ID No., and Packing Group• Hazard Class identifies the type of hazard posed by the material.

RMW is 6.2

• UN or NA identification number is a unique numeric designation. RMW UN3291

• Packing Group (I, II, and III) indicates the degree of the hazard, I being the greatest, and III the least.RMW PGII

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Packaging• RMW falls under PGII, medium danger

• PGII containers must pass a series of drop, stack, vibration and water absorption tests.

Packing GroupsI – High DangerII – Medium Danger

III – Low Danger

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Packaging• RMW haulers utilizing a vehicle exclusively for transporting RMW are

excepted requirement (173.134) but must follow general packaging requirements as outlined in 173.24 and 173.24(a). Therefore, they are exempt from labeling & placarding as a 6.2 class, but OSHA blood borne pathogen standard requires biohazard label.

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Labeling Requirements• Universal biohazard symbol (29 CFR 1910.1030)

• Regulated Medical Waste n.o.s

• UN3291

• The word “Biohazard”

• Arrows pointing up

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RMW Packaging Requirements• Packaging requirements for RMW are outlined in 49 CFR

o 173.24 & 173.24(a) non-bulk containers (smaller than 119 gallons)

o 173.197 bulk containers (carts on wheels, containers larger than 119 gal and roll-off boxes). This may also apply to non-bulk containers if the vendor is not using a truck exclusively for the transport of RMW.

o State of MA does NOT allow bulk containerization.

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Non-Bulk Containers (small totes and boxes under 119 gal)• Types of non-bulk containers include

o Reusable containerso Boxes

• Follow general packaging requirements 49CFR 173.24 & 173.24(a)

• General Packaging Requirements must be used when a vendor uses a vehicle exclusively for the transportation of RMW

• May not contain other hazardous materials

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Non-Bulk Containers (small totes and boxes under 119 gal)• Containers meeting general packaging guidelines must be:

o Rigid & leak resistanto Impervious to moistureo Strong so effectiveness is not substantially reducedo Closedo Puncture resistanto Sharps containers securely closed

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Corrugated Boxes• Set up box using 2” standard shipping tape or auto locking

mechanisms• Arrows must always point up• Line with a red bag (min thickness 1.5mil)• Once full, tie the bag gathering and twisting the neck of the bag and

use a tie or twist knot • Inner contents cannot leak when the bag is upside down (no free

flowing liquids). Penalty for leaky containers is $9k• Seal box with 2” standard shipping tape or engage auto-locking

mechanisms

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Sharps Containment Systems• Generators must properly select sharps containers in order to protect

employees during transport.

• Sharps containers must be placed in a secondary container or meet leak proof requirements (gasket)

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Container Type Handling Requirements Secondary containerRequirement

Sharps container without gasket

Sharps containers must be over packed with secondary packaging to ensure they are leak proof

Place sharps container in bag and place in reusable container. Place sharps container in bag and place in corrugated box

Sharps container with gasket and vent

Sharps container must be properly closed per manufacturer requirements and vent properly closed

No additional packaging required as long as the vent is properly closed and lid is properly sealed

Sharps containers with gasket

Sharps container must be properly closed per the manufacturer requirements

No additional packaging required as long as lid is properly sealed

Sharps Containment Packaging

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Types of Containers

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Containers• Stericycle Biosystems are reuseable containers

• Prepackaged labkits

• Biosystem inserts are disinfected

• Autoclave bags that turn a different color when autoclaved

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Shipping Papers• Required to transport all hazardous materials

• Must be signed and dated by a trained employee.

• Must be maintained by the generator o 2 yrs per USDOTo State specific requirements may apply.o MA requires generator to keep for 3 yrs.

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Shipping Papers/Manifest• 49CFR 172.200; Entries must be legible

and in English• Must contain:

o Proper shipping nameo Regulated Medical Waste n.o.so Hazard class and division- 6.2o Waste Identification No.-UN3291o Packing group-PGIIo Total Quantity-cubic feet or weight

• Emergency Response Number (Stericycle’s)

• Shippers certification (signature)

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Shippers Certification• When you sign a shipping paper you are confirming the following on

behalf of your facilityo Materials contained in this load are properly describedo Properly packagedo Properly marked and labeled per DOTo Agreeing to volume transported

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Safety• Protect employees from exposure

• Practice safe handling procedures; outside of box is not contaminated

• Ensure containers are safe for transport on public highways; not overfilled, correctly closed

• Follow proper packaging to insure safe transport; not leaking, nothing protruding

• Properly secure containers; storage area

• Stericycle will NOT accept improperly packaged, marked or labeled containers

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Employee Safety• PPE worn by Hazmat employees when loading, unloading, packaging,

or otherwise handling hazardous materials may include:o Eye protection - safety glasses with side shields, goggles, and face

shields;

o Hand protection – heat, chemical, & abrasion resistant gloves; and

o Protective clothing - lab coats, aprons, closed-toe or steel-toe shoes.

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Safety• OSHA annual bloodbourne pathogen training;

universal precautions-treat everything as if it could be infected.

• Modes of transmission;o Needle sticks (most common accident)o Blood to blood contacto Eye, mouth, non-intact skin or other mucous

membrane contact (abrasions)• Only fill sharps containers to “full” line.• Sharps containers should be securely closed

before they’re moved out of lab

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Emergency Incident Reporting• To request assistance in the

event of a hazardous materials spill or exposure, contact your supervisor and Tufts Environmental Health & Safety.

• Complete accident and incident reporting form, found on the TU EHS website.

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Emergency Response• Do not put yourself in an unsafe situation or attempt any action with

which you are uncomfortable.

• If it is not safe to remain at the scene of the incident, leave the immediate area.

• Stay nearby to provide information to emergency responders.

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Spill Clean Up• Cleanup should only be performed by persons trained in Bloodborne

pathogens.

• If you can safely clean up a small spill that does not pose a health or safety threat, you may do so using appropriate clean up materials and PPE (gloves, gown etc).

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Spill Clean Up• Spray area with disinfectant

• 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, wash hands

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Security RisksMany hazardous materials may potentially be used as weapons or weapons of convenience. It is critical to the assurance of public safety that HazMat employees be conscious of the security risks inherent in the handling and management of hazardous materials.

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Unauthorized Access• Tufts implements many routine

security measures to prevent unauthorized access to its facilities, including:o Key/card access to buildings

and secure areaso Visitor escort ruleso Campus Police patrolso Employee training on security

requirements

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Employee Responsibilities• All Tufts employees should be alert to potential security risks.

Prudent precautions include:o Restricting access to hazardous materials and waste to authorized

personnel only;o Keeping chemical storerooms, shipping and receiving areas, and

waste storage areas locked when unattended;o Questioning unfamiliar/unbadged persons about their presence; ando Making sure any hazardous materials received are as ordered

according to packing lists, shipping papers, etc.

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En Route Security• Packaging and preparation of hazardous materials for shipment is

performed by authorized Tufts employees or contractors.

• Tufts contracts with licensed waste haulers to transport hazardous materials; know your driver & company’s uniforms

• At no time during preparation, transport, or storage incidental to movement should hazardous materials be left unattended

• Verify the volume on the shipping paper with the volume that driver is actually taking

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Security BreachesIn the event of a security breach, immediately contact Campus Police at x66911 or 617-636-6911.

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Compliance Check List Inner container (bag) is closed, tied correctly.

Box is in good condition.

Outside of box is not contaminated.

Container has biohazard symbol, the word “Biohazard” and arrows pointing up.

Total quantity is written on shipping paper.

Shipping manifest is legibly signed by trained employee.

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Summary• DOT regulates the transport of RMW

o Is waste properly identified & classified?o Is waste packaged to keep it safe during transport?o Are employees packaging this waste trained in the risks associated

with the hazardous material?o Are employees who assist in the packaging of these materials

properly trained?o Are employees who sign the shipping papers properly trained?o Are materials stored in a secure area?

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Test TimeThis quiz is needed to document that you have completed and understand all sections of this training.

A passing score of 80% is required. A Certificate of Training will be sent to you if the test was passed. Please be sure to keep this certificate for your records.

We thank you for your time and cooperation in helping Tufts University and yourself maintain

continued compliance with applicable regulatory requirements.

Completion of this training is required every (3) three years.

Questions or comments can be directed to Tufts Environmental Health and Safety x63615.