Transport of Clinical Waste in BULK
Transport of Clinical Waste in
BULKA ‘Street’ guide for compliance
The SMDSA and its Members support the Department of Transport position (as submitted to the UN) on BULK transportation of clinical waste. In the current absence of guidance to operators on compliance with the Exemption, the following ‘street guide’ has been developed by SMDSA and agreed with HSE as meeting the requirements and objectives for carriage in BULK.
- Bulk is effected as soon as the first bag is loaded onto a vehicle and not placed inside a UN type approved rigid container. ie there is no lower limit, the criteria below applies fully to all vehicles – including vans and cars.
- The vehicle body/container must have rigid sides, roof and doors. ie open skips and caged or curtain sided vehicles do not comply.
- The vehicle/container must be leakproof by design. I.e. must be fitted with a lip, trough, or (at least) absorbent 'pig'. The criteria is that liquid does not escape from the vehicle/container.
- 'Sharps' are not permitted in bulk and must be contained in UN type approved rigid packaging. Eg. Sharps’ box.
- Other solid clinical waste UN3291 shall be contained in UN type approved leakproof sealed plastic bags. NB For the purposes of ‘BULK’, plastic bags are not, and must not be considered as, 'packages', but as secondary containment. Note: The bag is still being carried in ‘BULK’ if placed inside a wheelie bin which is NOT UN approved, since it is not in an approved package. However, if the bag is placed within rigid packaging which complies with UN type approval (eg UN type approved wheelie bin), - this is NO LONGER bulk - but packaged goods, and requirements for packages apply instead.
- Where a vehicle is carrying rigid packagings and plastic bags (BULK) together in the same closed bulk container they shall be adequately segregated from each other, such as by suitable rigid barriers or dividers, or mesh nets, so that they prevent damage to the bags during normal conditions of transport. Eg Sharps’ boxes must be segregated from bags carried as BULK.
- Spillages must be cleaned before the next load is carried.
- A plain orange panel must be displayed to the front of the vehicle. An orange panel must be displayed to both sides and rear showing UN number (3291) emergency action code (2X) and the hazard diamond (infectious class 6).
- PPE must be carried on the vehicle appropriate to spillage of the container. [Regulation 14.4]
- One
2Kg Fire Extinguisher must be carried in the cab of the vehicle. [Regulation 23(3)(b)]
- Drivers' Vocational Training Certificate (ADR certificate) will be required when vehicle exceeds 3.5 tonne GVW.
- Parking and supervision rules apply when the load exceeds 2000 Kg.
- Where a vehicle is carrying in bulk and correctly marked for the purpose, but also is carrying one or more UN containers, then bulk conditions (as above) shall take precedence as these conditions are more stringent than those for packagings.
SMDSA is currently involved as industry representative of the Working Group on an interim addendum to the Health Services Advisory Committee’s publication 'The Safe Disposal of Clinical Waste', which will include ‘formal’ guidance on BULK carriage of clinical waste.
