UN Containers - The facts explored
Dee Ward, Marketing Manager, Daniels Healthcare Ltd, and Louis Howe, Environmental Advisor, PHS Group Ltd
In 1957 the U.K. signed an international treaty called "Accord Europeen relatif au transport international des marchandise dangereuses par route" (European agreement concerning the international carriage of dangerous goods by road). This is known as "ADR" and its purpose is to provide a standardised and internationally recognised means of protecting human health and the environment from the dangers posed by the transport of dangerous goods.
The requirements of "ADR" are implemented via Carriage of Dangerous Goods (Classification, Packaging & Labeling) Regulations 1996 & The Carriage of Dangerous Goods by Road Regulations 1996. At this time Clinical Waste became subject to these regulations although it is important to understand that "Sanpro" wastes, i.e. products of human hygiene, are not considered to be Clinical Waste for the purposes of these regulations (see para 90 Approved Requirements and test methods for the classification and packaging of dangerous goods for transport).
Although the Regulations became law in 1996, the U.K. was allowed a five-year derogation during which to prepare for the higher standards. This five-year "derogation" expires at the end of 2001 and full compliance with the Regulations will be mandatory from the 1st January 2002.
So, in practical terms, what does it all mean?
In simple terms it means we cannot transport Clinical Wastes in anything other than rigid containers that have been tested and approved as suitable. But, firstly, we must understand how to classify Clinical Wastes in order to specify the appropriate type of rigid container.
Dangerous Goods are split into nine broad categories with Class 6.2 appropriate to Clinical Wastes if they contain:
"Viable micro-organisms that are known or reasonably believed to cause disease in animals or humans"
The World Health Organisations Laboratory biosafety manual divides micro-organisms into four "risk groups". Wastes containing pathogens from risk groups 2, 3 and 4 are considered "Dangerous" for transport. The Clinical Waste Management industry should not be asked to manage wastes contaminated with risk group 4 pathogens as these should only be found in isolation hospitals and must be autoclaved prior to collection.
If the contaminating pathogens from risk groups 2 or 3 are known then it is appropriate to use U.N. 2814 (infectious substances affecting humans) or U.N. 2900 (infectious substances affecting animals). However, the reality in the U.K. is that we do not know which group they come from so the Health & Safety Executive deem it appropriate for the industry to use U.N. 3291, the U.N. number used "where there is a relatively low probability that infectious substances are present". It is important to note that this classification does not extend to Group D clinical wastes (including many medicines, pharmaceuticals and cytotoxic wastes) as these may be 'Special' wastes and will possess many different characteristics and hazards - eg toxic, carcinogenic, corrosive or flammable. The management regime for these will be the subject of another article.
Having found the appropriate U.N. number for the waste, a container can be selected.
Suppliers of containers should be asked if the unit is "type approved" for Clinical Waste. Type approved containers will have been tested at the Packaging Industry Research Association (P.I.R.A.), the appointed UK testing house. The principle test carried out is the drop test whereby the container is filled with the relevant materials, i.e. as it would be used in normal use, and dropped on each corner onto a concrete floor from a height of 1.2m at -18 degrees C. If the integrity of the container remains intact after all tests are carried out, it will receive approval, and a certificate and approval code can be issued. The approval code will normally be stamped onto the container during manufacture.
A typical code found on a U.N. type approved container is: e.g:1H2/Y1/S/99/GB/3154
1H2 The first digit (1) identifies the type of container:
1 = Drums; 2 = Barrel; 3 = Jerry Can; 4 = Box; 5 = Sack
The 'H' indicates the material of construction:
A = steel; H = plastic
The '2' relates to the size of the aperture
1 = less than 7 cm (with lid off); 2 = more than 7 cm
Y1 = This is the packing group
S = Solids; L = Liquids
99 = Date of manufacture
GB = Great Britain
3165 = This is the individual packaging code for each product.
Combination containers can be used e.g. a U.N. Type Approved yellow bag lining a rigid container but they must have been tested as a combination unit and received approval only for use as such. Similarly, yellow bags and burn bins can be transported in wheeled bins but where the bin has a capacity of less than 450 litres/400 Kg it must have been tested as a combination package. Where the bin has a capacity of greater than 450 litres/400 Kg then any U.N. Type Approved container can be used within.
The container must also bear a hazard warning label (see insert) as specified in Schedule 1, parts I & II of The Carriage of Dangerous Goods (Classification, Packaging & Labeling) Regulations 1996, the designation of the goods i.e. Clinical Waste, N.O.S., as well as the U.N. number, and these markings must be visible at all times whilst on the vehicle.
So what are the options for Dangerous Goods Safety Advisers when advising producers of Clinical Waste?
Small producers of Clinical Waste will have the option of using one-way burn-bins or re-usable containers. They may also use yellow bags/burn-bins placed into a wheeled bin on a vehicle. Large producers can either obtain the services of a contractor providing a wheeled bin exchange service or use their own suitable equipped vehicles. In all cases all the containers must be U.N. Type Approved and carry the appropriate warning labels.
It must also be borne in mind that, although the U.K. received a five-year derogation from the requirement to use rigid containers, the requirements for the vehicles used to transport clinical waste came into effect in 1996 and have continuously applied. Specifically, that when carrying a mass of waste that exceeds the thresholds in Table 2 of The Carriage of Dangerous Goods by Road Regulations 1996, the appropriate measures must be taken e.g. Orange Plating, Tremcards, Fire Extinguishers & "ADR" training (in house for under 3.5 tonne g.v.w.) for drivers. (See regulations for full list - note Clinical Waste is transport category 2)
These regulations are designed to make the world a safer place for all and, after a five-year period of grace in which to prepare, we have no excuse for failure to ensure that our contractors and customers alike fully implement the requirements.