ADR and medical specimens: Category A or B, exempt specimens, dry ice and who classifies

The ADR is an international agreement, but in the Netherlands it is, through three links, also the law for a ride from the collection point to the laboratory around the corner. The first link is the Act on the Transport of Dangerous Goods: it applies to carrying by land, offering and accepting, loading and unloading, packing for the purpose of transport and receiving dangerous goods, without any restriction to international transport. The act works with designated substances for which operations are prohibited or allowed only under conditions.

The second link is the Decree on the Transport of Dangerous Goods, which defines the ADR and provides that substances are designated by ministerial regulation, in accordance with the ADR. The third is that regulation: the Regulation on the Transport of Dangerous Goods by Land (VLG). Its Annex 1 is the Dutch translation of ADR Annexes A and B, and the provisions apply to every transport the regulation covers. Annex 2 contains the Dutch deviations and additions; as far as can be ascertained it contains nothing specific about Class 6.2, UN 3373, P650 or dry ice.

Above that hangs European law: the directive on the inland transport of dangerous goods applies to transport within or between Member States, including loading and unloading, and refers through a delegated directive to the ADR annexes as applicable from 1 January 2025. The Dutch RIVM sums it up: the ADR is implemented in the Netherlands through the WVGS and the VLG. The ILT supervises transport, loading and unloading, and packing, and puts it simply: anyone transporting something must first determine whether it has to be classified as a dangerous good.

The ADR is the European agreement on the carriage of dangerous goods by road, with Annexes A and B containing the list of dangerous goods, the packing and marking provisions and the requirements for vehicles and crews. It is revised every two years. The text now in force is the 2025 edition, applicable since 1 January 2025, with a transitional period until 30 June 2025 during which the previous edition could still be used. For anyone writing protocols, that means a check for changes with every new edition.

Medical specimens fall under Class 6.2, infectious substances: substances which are known or reasonably expected to contain pathogens. Patient specimens are, in the ADR, all materials collected directly from humans or animals. Classification has three possible outcomes. Category A (UN 2814 for humans and animals, UN 2900 for animals only) is capable of causing permanent disability or life-threatening disease on exposure; in case of doubt Category A applies, and the ADR gives an indicative list. Category B (UN 3373) is any infectious substance that does not meet the Category A criteria. The exempt specimen has a minimal likelihood of pathogens and is not a dangerous good, provided it is packed leakproof and in three layers with the marking 'Exempt human specimen'.

A medical shipment is therefore not automatically an ADR shipment. Shipments that cannot contain pathogens, such as documents or devices, do not fall under Class 6.2; whether another ADR class applies depends on the substance and is a question for the sender, not for the courier. The explanation with the examples from the ADR and the common misconceptions is in what UN3373 means; the overview of the whole subject in transporting medical specimens.

The ADR divides the duties. The sender ascertains that the goods are classified and authorised for carriage, provides the information and uses only approved and marked packagings; the packer observes the packing provisions and the marking; the loader checks for damage and leakage. The carrier checks that the goods are authorised for carriage and that the information has been provided, ascertains by visual inspection that there are no obvious defects, leakage or cracks, may rely on the information of the other participants, and may not continue the transport after an infringement until it has been remedied.

The ILT puts it more briefly: the sender classifies, informs and packs, and remains responsible even when outsourcing those tasks; the carrier checks whether the shipment complies with the ADR. For a laboratory this means that classification is a decision someone takes and records, not something the courier does at the door. How that division of roles works in the daily chain from collection to analysis is explained in laboratory transport.

In Table A, UN 3373 carries special provision 319: substances packed, and packages marked, in accordance with P650 are not subject to any other provision of the ADR. The exemption depends entirely on the packaging and the mark; what P650 exactly requires is explained in packing instruction P650. If those are in order, no dangerous goods transport document, no orange plate, no ADR training certificate for the driver and no other ADR equipment is needed; if they are not, the ordinary ADR provisions apply, which is exactly why a courier leaves a shipment without a mark behind. Anyone looking up the ADR exemptions on the ILT website will not find UN 3373 there: that list (private individuals, the nature of the transport operation, limited quantities, the 1000-point rule) covers other exemptions, and for UN 3373 the limited quantity is zero. The route for specimens is special provision 319.

For a UN 3373 shipment packed and marked in accordance with P650: no. Special provision 319 exempts such a shipment from all other ADR provisions, and the driver's training falls under those. What the driver does have to be able to do follows from the carrier's duties and from the agreements with the laboratory: recognise the mark, assess the outer packaging, know what to do in case of a leak or damage and what to record at the handover.

For Category A it is different. UN 2814 and UN 2900 do not have the exemption of special provision 319: packing instruction P620 applies there, a transport document stating the technical name or the suspected Category A classification, and the other ADR provisions, including those on training and equipment. Anyone who wants a Category A shipment transported needs a carrier set up for that, and would do well to ask for it explicitly in advance.

When specimens travel on dry ice, UN 1845, carbon dioxide, solid, comes into play. Dry ice is not subject to the ADR, except for chapter 5.5.3 on coolants: the packages must let the gas escape so that no pressure builds up, the vehicle must be well ventilated or otherwise carry a warning mark, the people involved must be trained in line with their responsibilities, and the package is marked CARBON DIOXIDE, SOLID or DRY ICE with the words AS COOLANT, in an official language of the country of origin and, if that is not English, French or German, also in one of those. For refrigerant gases in double-walled cryogenic receptacles for medical or biological specimens the ADR has a separate special provision (593). A cool box with cooling elements adds no dangerous good.

Supervision of the transport of dangerous goods by road lies with the officials designated for that by ministerial decision; in practice that is the Human Environment and Transport Inspectorate (ILT). The ILT oversees the transport itself, loading and unloading, and packing, and therefore also what happens in a laboratory or collection point before the courier arrives. Anyone who follows the division of roles in the ADR and records who did what does not stand empty-handed at an inspection.

UrgentX transports laboratory specimens that the sender has classified and packed as UN3373 or as an exempt specimen. At pickup we check the mark and the outer packaging; an incompletely packed or unrecognisable shipment does not come with us, and we report it immediately. Because a P650 shipment is exempt from the other ADR provisions, we do not present the ADR as a quality mark; it is the rule the shipment and our check have to meet. What we record and what you get from us is described under transport of laboratory samples.