Interpretation Response #03-0070 ([Mildred Mitchell Bateman Hospital] [Ms. Gail Kelly, MT (ASCP)])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 04/18/2003

Company Name: Mildred Mitchell Bateman Hospital

Individual Name: Ms. Gail Kelly, MT (ASCP)

Location State: WV Country: US

View the Interpretation Document

Response text:

Apr 18, 2003

Ms. Gail Kelly, MT (ASCP)                Reference No. 03-0070
Laboratory Director
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,

Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards

173.199

Regulation Sections