The Pipeline and Hazardous Materials Safety Administration (PHMSA) this week published a Safety Advisory in the Federal Register for the transportation of materials they are, or may be, contaminated with Ebola.
The US DOT regulates materials that are contaminated with the Ebola virus as a Class A infectious substance in the Hazardous Materials Regulations (49 CFR 171-180), however, the classification does not apply to Ebola waste that has been incinerated, autoclaved or “otherwise inactivated.”
The PHMSA’s new guidance addresses handling, shipping and transporting Ebola-infected waste including how to select the proper packaging, how to treat Ebola-contaminated waste before transporting it, closing the container to prevent tears, leaks and damage and “operational control for medical facilities and transporters.”
“PHMSA recognizes that shipping or transporting large volumes of Ebola contaminated waste may require variance from the hazmat regulations. PHMSA issued a non-site-specific special permit to allow for alternative packaging in these cases. Shippers and waste haulers can apply for party status to the special permit, DOT SP-16279, in accordance with 49 CFR 107.107. To request a unique special permit, shippers and waste haulers should follow the rules at 49 CFR 107, Subpart B,” the agency states.
In September, the DOT issued guidance for truck drivers transporting Ebola contaminated items from hospitals.
Infections substances are regulated as a hazardous material under the DOT’s Hazardous Materials Regulations (HMR).
“The HMR apply to any material DOT determines is capable of posing an unreasonable risk to health, safety, and property when transported in commerce.1 An infectious substance must conform to all applicable HMR requirements when offered for transportation or transported by air, highway, rail, or water. Refer to the Center for Disease Control (CDC) for guidance on handling these agents before transporting them,” the DOT guidance states.
A Category A infections substance is a material known or “reasonably expected” to contain pathogens, such as ebola, that are capable of “causing permanent disability or life threatening or fatal disease in otherwise health humans.” Category A substance is also a substance classification that is given, based on a patent’s or animal’s medical history, symptoms or professional judgment.
Category A substances should be handled differently than regulated medical waste. According to the DOT:
- Regulated medical waste is a waste or reusable material known or suspected of containing a Category B pathogen that is derived from medical treatment or biomedical research.
- A Category B pathogen is not in a form that is generally capable of causing permanent disability or life-threatening or fatal disease in otherwise healthy humans or animals.
- Because of the hazards posed by Category A infectious substances, these materials have more stringent packaging requirements and are not included in the definition of a “regulated medical waste.”
DOT says the transportation of medial equipment (sharps, linens, gowns, dressings, pans, toilets masks, goggles, face shields, respirators, booties, cleaning products) that are suspected with being contaminated with a Category A infectious substance must comply with 173.196.
In general, a Category A infectious substance must be triple packed in a:
(2) watertight secondary packaging, and
(3) rigid outer packaging.
In addition, Category A infections substances must be:
- Shipped at ambient temperatures or higher must be packaged in accordance with § 173.196(b)(1),
- Shipped refrigerated or frozen must be packaged in accordance with § 173.196(b)(2), and
- Shipped in liquid nitrogen must be packaged in accordance with § 173.196(b)(3). (See http://www.ecfr.gov/cgi-bin/text-idx?SID=1baa09de1469d4c6ede30d6f6f303959&node=pt49.2.173&rgn=div5
Shippers must identify “key hazard communication information.” Shipping papers must include:
UN numbers and proper shipping name of the Category A infectious substance. For example, Ebola’s shipping name is: “UN 2814, Infectious substances, affecting humans.”
The shipping papers must also include:
- Hazard class: Division 6.2 (infectious);
- Packing group: N/A;
- Type and quantity of packaging; and
- Emergency response information (e.g., telephone number).
The outer packaging must be labeled with “INFECTIOUS SUBSTANCE” and directional arrows must be displayed, indicating which way is the correct upright position of the container.
Should a driver who is transporting Category A infectious substance encounter a transportation emergency, such as fire, spill, breakage, etc., it must be rerouted to the National Response Center at 1-800-424-8802 within 12 hours.