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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 Locat 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 I 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 />