By Patricia Payne, president, JBM Associates, Inc.; consultant, APHL
In some circumstances, when a question arises about classification, hazardous material (hazmat) compliance or how to package a specimen, time is of the essence. You need answers quickly to facilitate getting a response on a test result for patient diagnosis or treatment. Fortunately, there are several options for receiving help fast.
It is often possible to get answers to specific questions on-demand by contacting the regulatory agency involved in hazmat transportation compliance. Questions regarding transport of infectious substances by motor vehicle and air transport can be directed to one of the agencies below:
- Department of Transportation (DOT) issues federal regulations for motor vehicle, air and water transport of any hazardous material in the Hazardous Materials Regulations (HMR, 49 CFR Parts 100-185). Those regulations are freely accessible at the US Government Publishing Office website. For immediate answers to questions regarding hazmat packaging instructions, rulemakings or how to use the HMR, contact the Hazardous Materials Information Center Monday through Friday from 9:00 AM to 5:00 PM (EST) at 1-800-HMR-4922 (1-800-467-4922) or 202-366-4488 for Washington, DC residents.
- International Air Transport Association (IATA) issues airline carrier regulations in the Dangerous Goods Regulations (DGR), which is required to be followed by all IATA member airlines. The DGR is available in print and electronically. Both are copyright materials that can be purchased online from the IATA website. Questions regarding the IATA regulations can be asked by calling +1 (514) 390-6770 or email at firstname.lastname@example.org.
In my experience, the DOT information center is very responsive to questions. It is rare to wait to speak with a DOT employee or receive an answer. The IATA phone number is answered by IATA staff in Montreal, Canada who most often take your question and pass it on to the appropriate staff in a different location. I have found that IATA responds faster to questions sent by email than by phone. I usually receive a response within 1-2 days, sometimes within a few hours, after sending an email to IATA. The silver lining of the longer wait for an IATA vs DOT response is that the question and answer are in writing, which can be filed for future reference and to share with others.
The cargo agencies used to transport our samples, including FedEx and UPS, also have hazmat hotlines. Their hotlines are staffed seven days a week and nearly 24 hours a day. Hotline employees provide answers to questions related to packaging, documentation and transport. Contact the FedEx Dangerous Goods/Hazardous Materials Hotline at 1-800-463-3339 and then press 81. The UPS Hazardous Materials Support Center can be reached at 1-800-554-9964.
None of the agencies mentioned above will provide advice on questions concerning classification. For assistance with classification, it is best to contact the reference laboratory that will be testing your specimen or identifying microorganisms. All state public health departments have staff who are trained to help you classify. For many pathogens, including new and emerging pathogens, check the CDC website. By placing the microorganism name in the upper right search box, you will be directed to a page with links to information related to laboratory and medical personnel. Those links often, but not always, provide the classification of a specific microorganism.
In addition, APHL accepts questions regarding classification, packaging, documentation and transport of infectious substances at email@example.com. Last but not least, this blog has a comment section that can be used to post questions. The advantage of posting a comment to the blog is that multiple people who may have the same comment can view the answer, make additional comments and share their experiences. This not only provides a forum for sharing packaging questions but also helps to facilitate uniform regulatory compliance.