This depends on several things.

Carrying biohazardous material is regulated by the DOT (Department of Transportation). The DOT has both national and state laws, where the former are usually universally accepted as the laws and guidelines for the latter. You need to contact your state DOT agency and ask them if there are national/state laws that affect your agency. There may be different laws depending on whether the biohazardous material is human/animal tissue or is simply reagent waste.

Furthermore, the laws change dramatically depending on the amount of material your facility produces. You will want to investigate the possibility of becoming a CESQG (Conditionally exempt small quantity generator). By doing this, you may carry waste in personal vehicles without placing hazardous placards on the vehicle, without having an EPA number, and without having specialized insurance. However, if you do not qualify as a CESQG, you have three options: 1) have a true waste transportation company dispose of your waste; 2) have your company start your own transportation company (I'm serious--the law requires you to have a transportation license for all waste transport on state byways that is not CESQG-produced); 3) buy a hard-core disposal unit and throw all the waste down the drain.

If you cannot qualify as a CESQG, I recommend option # 1. # 2 is very costly, and # 3 is hard on the flowers. Having another company transport and dispose of your waste is generally the best method, as long as you ensure they are properly insured, have excellent records, have good references, and have an EPA number. Since you are accountable for your waste even after the removal, transportation and disposal or eliminateion of the waste, be sure to track and ensure the proper disposal of the waste at the final site (they should send documentation that proves this is being done).

A CESQG can be a large industrial manufacturer or a small shop. CESQG status is achieved by producing less than 100 kgs. (220 lbs.) of hazardous waste per month, including a maximum of 1 kg. acutely hazardous waste. If a business generates more than this amount, it is required by law to use a licensed hazardous waste hauler to manifest and transport its waste.

Incidentally, I recommend, if you do qualify as a CESQG, to get an EPA number anyway--this helps in the production and dissemination of proper tracking and paper trails, and maintains a fear factor for the disposal guy who dumps his sludge in the local river at 3:00 AM.

 

Jon (a garbage guy who cares)

 

 

 

 

 ---Original Message-----
From: Mplhisto@aol.com [mailto:Mplhisto@aol.com]
Sent: Saturday, April 27, 2002 6:47 PM
To: histonet@pathology.swmed.edu
Subject: Regulations

[Jon Kerr] 

 

  Can anyone tell me any regulations on someone carring biohazardous specimens in thier own vehicle versus a company vehicle thanks