The advantages offered by non-emergency medical transportation are massive and often life-changing especially for individuals who need transportation assistance. In addition, non-emergency medical transportation is a very vital tool for people who need medical attention outside of emergency medical care.

Patients who require essential medical equipment to travel can find solace in the services offered by non-emergency medical transporters. These transportation professionals can competently manage the medical condition of the person they are transporting by making available certain essential medical equipment.

These types of equipment may include oxygen tanks, wheelchairs, colostomy bags, or other standard fluid bags. Also, note that the availability of non-emergency medical transportation can guarantee that patients with vital medical equipment can be moved safely to and from appointments while being monitored by another person who is well trained to handle their individual needs.

In the United States, have it in mind that medical oxygen (or oxygen USP) is considered both a hazardous material by the U.S. Department of Transportation (DOT) and a prescription drug regulated by the U.S. Food and Drug Administration (FDA).

The DOT considers it a hazardous material since it is delivered to the patient in a vehicle in a gaseous or liquid state. Owing to that, to ensure the safe transportation of medical oxygen, the DOT follows the law that comes from title 49 of the Code of Federal Regulations sections 40, 382, 383, 387, 390-397, and 399 (otherwise known as Federal Law).

The DOT mandates that the vehicle in question be fitted in a certain way, employees are trained on certain topics, and that they all carry certain papers in the vehicle.

Rules for Carrying Oxygen for NEMT Providers

If you are interested in carrying oxygen as a NEMT provider, here are basic rules you have to be wary of.

  1. Vehicle

According to the U.S. DOT, any vehicle used in transporting hazardous materials in the United States is expected to carry an oxygen manifest. These shipping papers can also be referred to as hazard manifests, pick-ticket, oxygen manifest, waybills, daily trip sheet, etc.

They more or less contain information on the exact type, size, and quantity of hazardous material you are moving and will have to be near of the seat-belted driver and left in the vehicle at all times. Note that lack of shipping papers or improperly prepared shipping papers remains one of the most common DOT violations.

These papers are necessary any time a hazardous material is transported or made available for transport, even if only one cylinder is being transported with the patient. In the United States, the only exception to the shipping paper requirement is when the hazardous material is used as a material of trade.

For instance, an HVAC worker or a welder is moving the gas to a job site, where they intend to use the gas during or for the work. Oxygen is then considered a material of Trade. However, oxygen does not fall under the material of trade exception.

Note that a person who falls under a material of trade exception is not selling hazardous materials; instead, they are selling services.

  1. Personnel Training

In the United States, hazmat training is required by the DOT for all hazmat employees or anyone who handles hazardous material during transportation, and drivers of vehicles transporting 1,001 pounds or more of hazardous materials.

This involves the driver, filler, or anyone who loads, unloads, or otherwise touches the hazardous material. It also involves anyone who is employed full-time, part-time, or temporarily.

In addition, if the driver of any vehicle is expected to fill oxygen—either from a liquid Dewar mounted in the truck or from a transfer system—they will also need the training to stay in line with FDA requirements on manufacturing drug products.

Note that every hazmat employee is expected to have the following training every three years and within 90 days of employment for new hires.

This training will have to be well documented to show inspectors when requested, however, if you can show proof of this training from a previous employer that is within the required time frame, you can be exempted from retaking the training.

  • General awareness safety training is meant to educate hazmat employees about DOT law, such as training requirements, vehicle requirements, and other standards the DOT expects.
  • Job-specific and safety training is meant to teach hazmat employees how to safely adhere to DOT law when in contact with specific hazardous material they transport every day (i.e. oxygen).
  • Security awareness training is also another very vital training that covers ways to safeguard the driver and public from attacks using hazardous materials.
  • Drivers must have commercial driver’s license (CDL) training.
  • Drivers must receive drug and alcohol information.
  • Drivers’ supervisors must be trained on drug testing.
  1. Other Medical Related Rules

Below are some other rules and regulations NEMT providers carrying oxygen are expected to comply with;

  • Use a cart or holster to carry portable oxygen. Holsters are well-designed shoulder bags with an opening on top. Note that the tanks are not meant to be placed in closed bags or backpacks.
  • Properly secure tanks so they do not roll in a vehicle. Liquid oxygen tanks should never be laid on their sides, but portable cylinders can be laid on their sides, but the valves will have to be properly secured from a collision. Tanks are not expected to be placed in a tightly closed space like a trunk.
  • When using oxygen, clients will have to sit near a partially opened window to forestall oxygen and heat from building up in the vehicle.

Oxygen is most often stored in one of two ways: under high pressure as a gas or as a cryogenic liquid. Note that both forms can be very deadly to transport if not handled properly. However, every situation is unique and it is best to consult your local authority having jurisdiction (AHJ) to be sure all safety rules and regulations are being followed.

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