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2. The American Red Cross is operating under 49 CFR 173.6 Materials of <br /> Trade Exception with regard to the RMW that we transport in Red Cross <br /> vehicles. The RMW that is produced during the blood collection process is <br /> considered Regulated Medical Waste, n.o.s. (e.g., category B biohazard <br /> waste) by the Federal Department of Transportation and can be transported <br /> under the Materials of Trade Exception. State regulations may be stricter <br /> than the federal regulations, but will be reviewed by Safety Staff on a regular <br /> basis. Changes will be made to this program as needed in order to remain <br /> in compliance with the State and Local Requirements Section of this <br /> procedure. <br /> 3. For shipment of RMW, the Federal MOTs regulations do not require: <br /> • shipping papers; <br /> • emergency response information or <br /> • formal training or retention of training records. <br /> 4. Red Cross drivers who transport RMW in company vehicles will need to be <br /> aware of what they are carrying (i.e., identify the container as containing <br /> RMW for an inspector) and be able to show an understanding of MOTs. <br /> 5. It is still required to transport RMW in compliance with 49 CFR Part 173.197, <br /> in appropriate outer containers (rigid, leak and puncture resistant <br /> packaging), labeled with the universal biohazard symbol, labeled as <br /> Regulated Medical Waste, n.o.s. and labeled with the UN number 3291. <br /> 6. Compliance with specific weight/volume limits: combination packaging <br /> must consist of one or more inner packagings (e.g., biohazard bags, sealed <br /> sharps containers). <br /> • Inner packages may not contain more than 8.8 lbs or 1 gallon of <br /> RMW, and <br /> • Outer packaging (rigid, leak and puncture resistant container) <br /> containing not more than 35.2 lbs or 4.2 gallons of RMW. <br /> • Total RMW volume cannot exceed 440 lbs. on a vehicle. <br /> 7. Vehicles carrying RMW will be marked as required by state regulations and <br /> will have an on-board spill kit as required by each state. <br /> 8. If RMW weight limits are exceeded in reference to the MOTS limitations, <br /> then the exemption no longer applies. In this instance, the American Red <br /> Cross Regulated Medical Waste Transport Form must be used to document <br /> waste transported. Also this form can be used/localized as appropriate to <br /> comply with any state/local requirements for tracking transported waste. <br /> American Red Cross Biomedical Services Safety Page 11 of 17 <br /> Regulated Medical Waste Program Program#023 <br />