Since 1969, the AVMA has had the policy titled "Shipment of Diagnostic Specimens" (http://www.avma.org/issues/policy/hazardsub_transport.asp). This policy states that laboratory specimens properly "packaged to prevent leakage or breaks in the containers" pose "no health hazard or sanitation problem." This is true because once specimens are packaged correctly neither the package handlers nor the environment will be exposed to the specimen. Additionally, the policy states that veterinarians are "to review their methods of preparing diagnostic specimens and ensure that they are in compliance with all applicable guidelines and federal and state laws," which includes required training.
Incorrect packaging of infectious substances can quickly land a veterinary practice in hot water. Veterinary practices send specimens to diagnostic labs on a daily basis, and it is vital to ensure that the staff (including veterinarians) who package the items have had the required documented training and that each shipment meets current packaging standards. Any items found to fall below these standards may result in the shipper being visited by the Federal Aviation Administration (FAA) or the U. S. Department of Transportation (DOT). Fines associated with noncompliance of packaging or training can be substantial.
According to our resources, requirements associated with packaging infectious substances were last updated in 2006 when the U. S. standards became harmonized with international United Nations (UN) standards. The DOT Pipeline and Hazardous Materials Safety Administration (PHMSA) has published two documents which are designed to help shippers understand their responsibilities which when followed will provide safety for all involved in the transport of these substances. The publication titled Transporting Infectious Substances Safely is the DOT / PHMSA guide for shippers regarding these regulatory changes, including the establishment of a classification system for infectious substances (categories A and B). In 2009, DOT / PHMSA released What You Should Know: a Guide to Developing a Hazardous Materials Training Program, which explains the training requirements.
In addition to the above resources, the DOT / PHMSA Office of Hazardous Materials Safety (OHMS) maintains a section on its website dedicated to providing viewers with replies to questions submitted about the Hazardous Materials Regulations. Although the interpretive letters are not legally binding, they do provide valuable guidance. Among other letters which may be available, an interpretation letter posted by DOT / PHMSA / OHMS in July of 2009, addresses a training question. Please, visit the Hazmat Interpretations webpage (http://www.phmsa.dot.gov/hazmat/regs/interps) for more details.
Remaining questions regarding these regulations should be directed to the Office of Hazardous Materials Initiatives and Training (address listed below) or to any one of its regional offices, which are listed on the DOT / PHMSA Training and Outreach website.
Office of Hazardous Materials Initiatives and TrainingPHH-501200 New Jersey Avenue, SEEast Building, 2nd FloorWashington, DC 20590
* This is a specific citation from the US Code of Federal Regulations
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