Mildred Mitchell Bateman Hospital — Hazardous Materials Safety Interpretation

Page 1U.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#

Page 204/03/2003 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#