# Mildred Mitchell Bateman Hospital — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 03-0070
- **title:** Mildred Mitchell Bateman Hospital — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2003-04-18
- **effective on:** Not available
- **summary:** 03-0070 response to Mildred Mitchell Bateman Hospital concerning 173.199.
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-03-0070.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-03-0070
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2003/030070.pdf
**body:**

<<<PAGE 1>>>

U.S. Department
of Transportation
400 Seventh St., S.W.
Research and
Washington, D.C. 20590
Special Programs
Administration
APR 18 2003
Laboratory Director
Ms. Gail Kelly, MT (ASCP)
Ref. No. 03-0070
Mildred Mitchell Bateman Hospital
1530 Norway Avenue
Huntington, WV 25705
Dear Ms. Kelly,
This responds to your March 6, 2003 letter requesting clarification on transporting diagnostic
specimens via dedicated courier under the Hazardous Materials Regulations (HMR; 49 CFR
Parts 171-180). Specifically, you ask what constitutes a "dedicated courier" under the HMR.
According to your letter, your facility uses drivers that perform multiple duties. They transport your
specimens to a local hospital, and, later that morning the drivers may transport a patient to a group
home. You state that when your drivers transport specimens to local hospitals, they are dedicated to
that job. You also state that you were advised by this Office that your drivers would be considered
dedicated as long as they are not doing anything else when they transport your specimens.
Diagnostic specimens or biological products are excepted from the HMR when transported by private
or contract motor carriers used exclusively to transport diagnostic specimens or biological products
(e.g., in dedicated vehicles, mostly couriers who transport specimens for doctors, home health care
providers, hospitals, etc.). Medical or clinical equipment and laboratory products may be transported
aboard the same vehicle provided they are properly packaged and secured against exposure or
contamination. However, in order for your vehicle to be "dedicated," patients would not be authorized
to be transported in the same vehicle at the same time the specimens are being transported.
I hope this answers your inquiry.
Sincerely,
Hilli
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
030070
(13.199

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04/03/2003
07: 55
5238362
LABORATORY
PAGE 02
Boothe
03-0070
File: 173.199
Mildred Mitchell Bateman Hospital
Laboratory
1530 Norway Ave
Huntington, WV 25705
March 6, 2003
Edward Mazzullo
Director of HAZMAT Regulations
Dear Six,
I would like clarification of the DOT regulation governing transportation of Diagnostic
Specitens by courier. The regulation specifies "dedicated courier". What constitutes a
dedicated courier?
In our facility we have drivers that do multiple jobs. At 8 AM they may be taking our
specimens to a local hospital and at 11AM transport one our patients to a group home.
I spoke to Arthur today and he said that our drivers would be onsidered dedicated as
When they take are specimens they are dedicated to that job.
have clarification in writing to attach to my file.
long as they are not doing anything else when they transport our specimens. I need to
Our FAX # is 304-523-8362 and phone # 304-525-7801 ext 317.
Thank you.
Gail Kelly, MT(ASCP)
Laboratory Directox
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