# Transporting Infectious Substances Safely

- **operation:** document
- **citation:** PHMSA Guidance, Transporting Infectious Substances Safely
- **title:** Transporting Infectious Substances Safely
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2022-06-10
- **effective on:** 2022-06-10
- **summary:** Transporting Infectious Substances Safely Document Transporting-Infectious-Substances-Safely-Phh50-0186-0622.pdf (1.34 MB) This brochure describes the USDOT regulations for the classification criteria and packaging requirements for the transportation of infectious substances, 49 CFR, Parts 171-180. Issued Date: Friday, June 10, 2022
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- **source url:** https://www.phmsa.dot.gov/training/hazmat/transporting-infectious-substances-safely
**body:**

Transporting Infectious Substances Safely

Document

 Transporting-Infectious-Substances-Safely-Phh50-0186-0622.pdf (1.34 MB)

        This brochure describes the USDOT regulations for the classification criteria and packaging requirements for the transportation of infectious substances, 49 CFR, Parts 171-180.

          Issued Date: Friday, June 10, 2022

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TRANSPORTING INFECTIOUS
SUBSTANCES SAFELY
WWW.PHMSA.DOT.GOV

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NOTICE
This publication was prepared as a training aid in the proper use
of the Hazardous Materials Regulations (HMR) and should not
be used to determine compliance with 49 CFR, Parts 100-185.
This guidance does not have the force and effect of law
and is not meant to bind the regulated entities in any way.

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TABLE OF CONTENTS
INTRODUCTION
CLASSIFICATION SYSTEM
CATEGORY A AND CATEGORY B
CLASSIFICATION PROCESS
CLASSIFICATION SCENARIOS
REQUIREMENTS FOR SHIPMENTS
PACKING, MARKING AND LABELING OF
CATEGORY A INFECTIOUS SUBSTANCES
PACKING AND MARKING OF
CATEGORY B INFECTIOUS SUBSTANCES
REGULATED MEDICAL WASTE
PACKING, MARKING AND LABELING
CLASSIFICATION SCENARIO
PRIVATE OR CONTRACT CARRIERS
EXCEPTIONS
EXCEPTIONS FOR CERTAIN AIR SHIPMENTS
MATERIALS OF TRADE
OTHER EXCEPTIONS
OTHER REQUIREMENTS
CARRIAGE BY AIRCRAFT
INCIDENT REPORTING
TRAINING REQUIREMENTS
SECURITY PLANS
EXAMPLES OF CATEGORY A: UN2814,
INFECTIOUS SUBSTANCES AFFECTING HUMANS
EXAMPLES OF CATEGORY A: UN2900,
INFECTIOUS SUBSTANCES AFFECTING ANIMALS
DEFINITIONS
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INTRODUCTION
WHY ARE INFECTIOUS SUBSTANCES REGULATED IN
TRANSPORTATION?
An infectious substance is regulated as a hazardous material under
the U.S. Department of Transportation (DOT) Hazardous Materials
Regulations (HMR), 49 CFR Parts 171-180. The HMR apply to any
material DOT determines is capable of posing an unreasonable risk
to health, safety, and property when transported in commerce. An
infectious substance must conform to all applicable HMR requirements
when transported or offered for transportation by air, highway, rail,
or water.
The Pipeline and Hazardous Materials Safety Administration (PHMSA)
updated these requirements in a final rule on June 1, 2006. In that
final rule, the HMR established a two-tiered classification system for
infectious substances—Category A and Category B.
CLASSIFICATION SYSTEM
The classification criteria and packaging requirements for the
transportation of infectious substances are consistent with international
standards. The harmonization of these standards ensure an acceptable
level of safety for transporting infectious substances and facilitate their
domestic and international transportation.
The Category A and Category B classifications are based on criteria
developed by the UN Committee of Experts working with the World
Health Organization (WHO), the U.S. Centers for Disease Control and
Prevention (CDC), medical professionals, microbiologists, transportation
professionals, and packaging technical experts. They are consistent with
the requirements contained in the United Nations Recommendations
for the Transport of Dangerous Goods (UN Recommendations), the
International Civil Aviation Organization Technical Instructions
for the Safe Transport of Dangerous Goods by Air (ICAO Technical
Instructions), and the International Maritime Organization (IMO)
International Maritime Dangerous Goods (IMDG) Code.
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CATEGORY A AND CATEGORY B
DIVISION 6.2 INFECTIOUS SUBSTANCE
A Division 6.2 infectious substance is a material known or reasonably
expected to contain a pathogen. A pathogen is a micro-organism
(including bacteria, viruses, rickettsia, parasites, fungi) or other agent,
such as a proteinaceous infectious particle (prion), that can cause
disease in humans or animals.
CATEGORY A
Category A classifies an infectious substance as in a form capable of
causing permanent disability or life-threatening or fatal disease in
otherwise healthy humans or animals when exposure to it occurs. An
exposure occurs when an infectious substance is released outside of its
protective packaging, which may result in physical contact with humans
or animals. Classification must be based on the known medical history
or symptoms of the source patient or animal, endemic local conditions,
or professional judgment concerning the individual circumstances of
the source human or animal. Category A poses a higher health risk than
Category B.
PROPER SHIPPING NAMES AND IDENTIFICATION NUMBERS:
UN2814, Infectious substances, affecting humans
UN2900, Infectious substances, affecting animals
CATEGORY B
Category B classifies an infectious substance as not in a form generally
capable of causing permanent disability or life-threatening or fatal
disease in otherwise healthy humans or animals when exposure to it
occurs. This includes infectious substances transported for diagnostic or
investigational purposes.
PROPER SHIPPING NAME AND IDENTIFICATION NUMBER:
UN3373, Biological substances, Category B
For information on Regulated Medical Waste see page 12.
Division 6.2 materials that are excepted from the regulations can be found in §173.134(b).
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CLASSIFICATION PROCESS
SUBSTANCE FOR CLASSIFICATION
Section 173.134(b) of the HMR contains a list of scenario-based
exceptions in which some materials are not subject to the requirements
for Division 6.2 infectious substances. If a material meets all the
conditions of any scenario, it is not regulated.
The flowchart below provides a process that can be helpful when
determining if a material is infectious and/or eligible for any exceptions
from the requirements. It is important to first determine if the material
is known or reasonably expected to contain an infectious pathogen. If it
does not contain an infectious pathogen, it is not regulated. However, a
material that meets the definition of a Category A infectious substance
will not be eligible for any exceptions.
Always review §173.134(b) to carefully determine if a material meets
any of the conditional exceptions. The classification scenarios on the
following pages provide examples of possible ways to move through a
classification process.
Is the material known or reasonably expected to contain an infectious pathogen?
NO
YES
Does it meet the definition of a Category A infectious substance?
NO YES
Does it meet any of the conditions listed in §173.134(b)?
YES NO
Not subject to the
requirements of
Division 6.2 materials
UN3373, Biological
Substances, Category B
UN2814,
Infectious Substances,
affecting humans; or
UN2900,
Infectious Substances,
affecting animals
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CLASSIFICATION SCENARIOS
SCENARIO 1
APPROPRIATE CLASSIFICATION
UN2814, Infectious Substances, affecting humans
A blood sample known or
reasonably suspected to contain
EBOLA VIRUS
Does it meet the definition of
a Category A substance?
YES
UN2814, Infectious
Substances, affecting humans
SCENARIO 2
APPROPRIATE CLASSIFICATION
UN2900, Infectious Substances, affecting animals
A culture of
FOOT AND MOUTH DISEASE
Does it meet the definition of
a Category A substance?
YES
UN2900, Infectious
Substances, affecting animals
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SCENARIO 3
APPROPRIATE CLASSIFICATION
UN3373, Biological Substances, Category B
A blood sample taken from a
patient known or suspected to
have a Category B pathogen,
such as HEPATITIS B or HIV
Does it meet the definition of
a Category A substance?
NO
Is it a patient sample transported by private or contract carrier
in a motor vehicle used exclusively for these materials?
(See §173.134(b)(10))
YES
NO
Not subject to the requirements of
Division 6.2 materials
UN3373, Biological Substances,
Category B
SCENARIO 4
APPROPRIATE CLASSIFICATION
Not subject to the Hazardous Materials Regulations
A BLOOD SAMPLE
collected for routine testing
Does it meet the requirements
of §173.134(b)(11)?
YES
Not subject to the requirements
of Division 6.2 materials
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REQUIREMENTS FOR SHIPMENTS
PACKING, MARKING AND LABELING OF
CATEGORY A INFECTIOUS SUBSTANCES
Requirements for packagings of Category A infectious substances are
found in §173.196, and must:
•
meet the test standards of §178.609.
•
be a triple packaging consisting of:
-
 primary leakproof receptacle,
-
 leakproof secondary packaging, and
-
 rigid outer packaging.
•
be marked with a UN package certification mark on the outer
packaging in conformance with §178.503(f).
SAMPLE OF UN PACKAGE CERTIFICATION MARK
Infectious Substance
Division
Symbol United Nations
Package Code
Year of
Manufacture
u
n
4G/CLASS 6.2/06
USA/0000
Country
Test Facility's/ Manufacturer's Code
INFECTIOUS SUBSTANCE LABEL
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DIAGRAM OF CATEGORY A PACKAGE
Leak Proof Primary Receptacle
(Glass, Metal, or Plastic) Infectious Substance
Absorbent Packing Material
(For Liquids)
Leakproof Secondary
Packaging
Cap
List of Contents
Rigid Outer Packaging
Infectious Substance
Label
Proper Shipping Name
and UN Number
u
n
4G / CLAS USA/0000
S 6.2/ 1 6
UN Package
Certification Mark
Shipper or
Consignee
Certification
CROSS SECTION OF CLOSED PACKAGE
Leakproof
Secondary
Packaging
Rigid Outer
Packaging
Closure Requires
Positive Means
of Ensuring
Leakproof Seal
Infectious
Substance
Absorbent
Packing Material
Notes: At least one surface of the outer packaging must have a minimum dimension of
100 mm x 100 mm (3.9 inches). For liquid shipments by aircraft, the primary receptacle
or the secondary packaging must be capable of withstanding without leakage an internal
pressure producing a pressure differential of not less than 95 kPa. If multiple fragile
primary receptacles are placed in a single secondary packaging, they must be either
individually wrapped or separated to prevent contact. Follow the package manufacturer’s
closure instructions.
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PACKING AND MARKING OF
CATEGORY B INFECTIOUS SUBSTANCES
Category B infectious substances are excepted from all other
requirements of the HMR when transported in accordance with the
requirements of §173.199.
Packing of Category B infectious substances requires marking the outer
package, adjacent to proper shipping name, with “Biological substances,
Category B" and the UN3373 package marking.
UN3373 PACKAGE MARKING
The proper shipping names “Clinical Specimen” and “Diagnostic
Specimen” were previously authorized until December 31, 2006. Since
January 1, 2007, only the proper shipping name “Biological substances,
Category B” is authorized for use.
Section 173.199 has additional requirements and limitations for
hazardous materials in other hazard classes, such as dry ice and
flammable liquids. Refer to §173.199 for all requirements when shipping
Category B infectious substances.
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DIAGRAM OF CATEGORY B PACKAGE
Primary Receptacle
Leakproof or Siftproof
Secondary Packaging
Leakproof or Siftproof
(e.g. Sealed Plastic Bag)
Infectious Substance
Absorbent Packing
Material (For Liquids)
Rigid Outer
Packaging
Biological
Su bstanc e
Category B*
UN 337 3
Package Marking
Name and Telephone
Number of a Person
Responsible.
(This Information
May Instead be Provided
on a Written Document
Such as an Air Waybill)
CROSS SECTION OF CLOSED PACKAGE
Rigid Outer
Packaging
Cushioning
Material
Primary Receptacle
Leakproof or Siftproof
Secondary Packaging
Leakproof or Siftproof
(e.g. Sealed Plastic Bag
or Other Intermediate
Packaging)
Absorbent
Material
Notes: At least one surface of the outer packaging must have a minimum dimension of
100 mm x 100 mm (3.9 inches). For liquid shipments by aircraft, the primary receptacle
or the secondary packaging must be capable of withstanding without leakage an internal
pressure producing a pressure differential of not less than 95 kPa. If multiple fragile
primary receptacles are placed in a single secondary packaging, they must be either
individually wrapped or separated to prevent contact. Follow the package manufacturer’s
closure instructions.
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REGULATED MEDICAL WASTE
PACKING, MARKING AND LABELING
Packaging requirements for regulated medical waste, including detailed
inner packaging requirements for each type, can be found in §173.197
and must be marked and labeled in one of the following methods:
•
Non-bulk Packagings (<119 gallons) – UN standard packaging
conforming to the requirements of Part 178 of the HMR at the
Packing Group II performance level.
- Non-bulk packages must be marked and labeled with the
UN ID number, proper shipping name, infectious substance
label, and consignee's or consignor's name and address.
•
Large Packagings (>119 gallons) – Constructed, tested, and
marked in accordance with subparts P and Q of Part 178.
- Large packages must be marked with the UN ID number and
BIOHAZARD marking conforming to 29 CFR 1910.1030.
•
Non-specification Bulk Packaging (>119 gallons) – includes
wheeled carts or other bulk outer packaging.
- Bulk packages must be marked with the UN ID number and
BIOHAZARD marking conforming to 29 CFR 1910.1030.
PROPER SHIPPING NAMES AND IDENTIFICATION NUMBERS:
UN3291, Regulated medical waste, n.o.s.
Clinical waste, unspecified, n.o.s.
(BIO) Medical waste, n.o.s.
Biomedical waste, n.o.s.
Medical waste, n.o.s.
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CLASSIFICATION SCENARIO
A waste material that contains a Category A infectious substance must
be classified as a Category A infectious substance. The flowchart below
provides a process to determine if a material is a regulated medical
waste or a Category A infectious substance.
Does the waste, or reusable material derived from the medical treatment of an animal
or human, contain a Category A infectious substance?
YES NO
UN2814, Infectious substances, affecting
humans; or
UN2900, Infectious substances, affecting
animals
UN3291, Regulated medical waste, n.o.s.;
Clinical waste, unspecified, n.o.s.;
(BIO) Medical waste, n.o.s.;
Biomedical waste, n.o.s.; or
Medical waste, n.o.s.
BIOHAZARD MARKING
PRIVATE OR CONTRACT CARRIERS
Regulated medical waste transported by a private or contract carrier in
a motor vehicle is excepted from:
•
the requirement for an “INFECTIOUS SUBSTANCE” label if the
outer packaging is marked with a “BIOHAZARD” marking in
accordance with 29 CFR 1910.1030;
•
the specific packaging requirements of §173.197, if packaged in
a rigid non-bulk packaging conforming to the general packaging
requirements of §173.24 and 29 CFR 1910.1030, provided the
material does not include a waste concentrated stock culture of an
infectious substance. Sharps containers must be securely closed to
prevent leaks or punctures.
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EXCEPTIONS
EXCEPTIONS FOR CERTAIN AIR SHIPMENTS
According to §6.3.2.3.8 of the ICAO Technical Instructions, specimen
packages marked as “Exempt human specimen” or “Exempt animal
specimen” are not regulated under the HMR. In the United States, the
mark “Exempt Human/Animal Specimen” is an indication that there is
no infectious substance in the package. Packages bearing these marks
may be accepted by an air carrier that has made a business decision not to
accept hazardous materials.
MATERIALS OF TRADE
A Division 6.2 material, other than a Category A infectious substance, is
eligible for the Materials of Trade exception when it complies with §173.6
and it contains human or animal samples (including, but not limited to,
secreta, excreta, blood and its components, tissue and tissue fluids, and
body parts) being transported for research, diagnosis, investigational
activities, or disease treatment or prevention, or it is a biological product
or regulated medical waste is eligible for materials of trade exceptions.
Section 173.6 of the HMR describes the packaging and transport
requirements for this exception. Note that there are specific quantity
limitations and transport must meet the definition of material of trade in
§171.8.
OTHER EXCEPTIONS
Section 173.134 identifies exceptions for infectious substances and
regulated medical wastes not specifically outlined in this guide. In
addition, if a DOT special permit is required (DOT-SP) you must follow
all requirements described in the permit.
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OTHER REQUIREMENTS
CARRIAGE BY AIRCRAFT
Section 175.630 contains special requirements for Division 6.1 (poisonous)
materials and Division 6.2 (infectious substances) materials. Paragraph
(c) requires the inspection of each package, overpack, pallet, or unit load
device containing a 6.2 material for signs of leakage. If evidence of leakage
is found, the cargo compartment hold where the 6.2 material was stowed
is required to be disinfected by any means that makes the release of the
6.2 material ineffective at transmitting disease.
INCIDENT REPORTING
You must report any release of an infectious substance (Category A or B)
in any mode of transportation to the Department of Transportation. See
§171.15 for telephone reporting requirements and §171.16 for written
report requirements.
TRAINING REQUIREMENTS
Employees involved in the packaging and transport of infectious
substances are subject to the training requirements of the HMR. These
requirements vary but are found in §172.704 and include:
•
General awareness/familiarization training;
•
Function-specific training;
•
Safety training;
•
Security awareness training; and
•
In-depth security training (if subject to security plan requirements).
Employees involved in the packaging and transport of Category B
infectious substances are required to be trained on the requirements in
§173.199. Employees who perform these tasks for excepted infectious
substances, such as Materials of Trade or those listed in §173.134(b) and
(c), are required to be trained on the applicable requirements of each
exception.
SECURITY PLANS
Persons who offer for transportation or transport select agents and toxins
regulated by the Centers for Disease Control and Prevention (CDC)
under 42 CFR Part 73 or the US Department of Agriculture under 9 CFR
Part 121 must develop and implement security plans in accordance with
§172.800 through §172.804.
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EXAMPLES OF CATEGORY A: UN2814,
INFECTIOUS SUBSTANCES AFFECTING
HUMANS
MICRO-ORGANISM
Bacillus anthracis (cultures only)
Brucella abortus (cultures only)
Brucella melitensis (cultures only)
Brucella suis (cultures only)
Burkholderia mallei—Pseudomonas mallei—Glanders (cultures only)
Burkholderia pseudomallei—Pseudomonas pseudomallei (cultures only)
Chlamydia psittaci—avian strains (cultures only)
Clostridium botulinum (cultures only)
Coccidioides immitis (cultures only)
Coxiella burnetti (cultures only)
Crimean-Congo hemorrhagic fever virus
Dengue virus (cultures only)
Eastern equine encephalitis virus (cultures only)
Escherichia coli, verotoxigenic (cultures only)
Ebola virus
Flexal virus
Francisella tularensis (cultures only)
Guanarito virus
Hantaan virus
Hantaviruses causing hemorrhagic fever with renal syndrome
Hendra virus
Herpes B virus (cultures only)
Human immunodeficiency virus (cultures only)
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Highly pathogenic avian influenza virus (cultures only)
Japanese Encephalitis virus (cultures only)
Junin virus
Kyasanur forest disease virus
Lassa virus
Machupo virus
Marburg virus
Monkeypox virus (Clade I cultures only)
Mycobacterium tuberculosis (cultures only)
Nipah virus
Omsk hemorrhagic fever virus
Poliovirus (cultures only)
Rabies and other lyssaviruses (cultures only)
Rickettsia prowazekii (cultures only)
Rickettsia rickettsia (cultures only)
Rift Valley fever virus (cultures only)
Russian spring-summer encephalitis virus (cultures only)
Sabia virus
Shigella dysenteriae type I (cultures only)
Tick-borne encephalitis virus (cultures only)
Variola virus
Venezuelan equine encephalitis virus (cultures only)
Vesicular stomatitis virus (cultures only)
West Nile virus (cultures only)
Yellow fever virus (cultures only)
Yersinia pestis (cultures only)
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EXAMPLES OF CATEGORY A: UN2900,
INFECTIOUS SUBSTANCES AFFECTING
ANIMALS
MICRO-ORGANISM
African swine fever virus (cultures only)
Avian paramyxovirus Type 1—Velogenic Newcastle disease virus
(cultures only)
Classical swine fever virus (cultures only)
Foot and mouth disease virus (cultures only)
Lumpy skin disease virus (cultures only)
Mycoplasma mycoides—Contagious bovine pleuropneumonia
(cultures only)
Peste des petits ruminants virus (cultures only)
Rinderpest virus (cultures only)
Sheep-pox virus (cultures only)
Goatpox virus (cultures only)
Swine vesicular disease virus (cultures only)
These examples are provided as guidance only. For more information, refer to the
World Health Organization (WHO) guidance on regulations for the transport of infectious
substances 2019–2020 (WHO/WHE/CPI/2019.20).
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DEFINITIONS
BIOLOGICAL PRODUCT
A virus, therapeutic serum, toxin, antitoxin, vaccine, blood, blood
component or derivative, allergenic product, or analogous product, or
arsphenamine or derivative of arsphenamine (or any other trivalent
arsenic compound) applicable to the prevention, treatment, or cure of a
disease or condition of human beings or animals.
CULTURE
An infectious substance containing a pathogen that is intentionally
propagated. Culture does not include a human or animal patient
specimen as defined below.
PATIENT SPECIMEN
Human or animal materials collected directly from humans or animals
and transported for research, diagnosis, investigational activities, or
disease treatment or prevention. Patient specimen includes excreta,
secreta, blood and its components, tissue and tissue swabs, body parts,
and specimens in transport media (e.g., transwabs, culture media, and
blood culture bottles).
REGULATED MEDICAL WASTE
Regulated medical waste or clinical waste or (bio) medical waste
means a waste or reusable material derived from the medical treatment
of an animal or human, which includes diagnosis and immunization, or
from biomedical research, which includes the production and testing of
biological products. Regulated medical waste or clinical waste or (bio)
medical waste containing a Category A infectious substance must be
classed as an infectious substance, and assigned to UN2814 or UN2900.
A complete list of infectious substance definitions can be found in the HMR in §173.134(a).
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For additional information contact:
The Hazardous Materials Info Center
1-800-HMR-4922
(1-800-467-4922)
Email: infocntr@dot.gov
https://www.phmsa.dot.gov
Pipeline and Hazardous Materials Safety Administration
Outreach, Engagement, and Grants Division
East Building, 2nd Floor
1200 New Jersey Ave., SE
Washington, DC 20590
Email: training@dot.gov
202-366-4900
202-366-7342 (Fax)
checkthebox.dot.gov
PHH50-0186-0622
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