Infectious substances and pathogens are regulated by both the US DOT and OSHA due to the unique hazards they pose, namely causing disease in humans or animals. The DOT and OSHA regulations vary in scope because the two programs have different goals: the former seeks to ensure the safety of hazmat transported on public roads, while the latter protects employees from these hazards in the workplace.
Infectious Substances as DOT Hazmat
The US DOT regulates infectious substances in its Hazardous Materials Regulations (HMR; 49 CFR Parts 100-185) along with explosives, poisons, and other dangerous chemicals. Materials known (or reasonably expected) to contain a “pathogen” are classified as Division 6.2 Infectious substances. Pathogens are microorganisms or other agents that can cause disease. Among the materials that may contain pathogens are human tissue or body fluids, soiled linens and medical waste, and bacterial cultures. These materials are considered hazmat under US DOT rules and should be prepared for transport accordingly.
Shipping Division 6.2 Infectious Substances
The US DOT separates Division 6.2 Infectious substances into two categories: A and B. Category A materials are capable of causing permanent disability or life-threatening or fatal disease. Category B materials, while still hazardous, are not expected to cause disability or sickness as severe as Category A materials.
For more information about shipping Division 6.2 materials, see Lion’s July 15 article, Hazmat in Healthcare.
Bloodborne Pathogens Safety
With respect to biohazards, OSHA’s goal is to protect the health and safety of workers at hospitals, doctor’s offices, clinics, and other workplaces where employees may be exposed to blood or other potentially infectious materials. These workplaces must comply with OSHA’s Bloodborne Pathogens Standard at 29 CFR 1910.1030. The Standard lays out expansive definitions of “exposure” and “other potentially infectious material.” In essence, any physical contact with blood or other human body fluid or tissue is assumed to be exposure to infectious material.
OSHA’s Bloodborne Pathogens Standard includes requirements to control workers’ exposure to these materials: a written plan, engineering controls, work practices, personal protective equipment (PPE), rules for designated sharps containers, hazard communication, recordkeeping, and more.
Intersection of DOT and OSHA Rules
When it comes to packaging and shipping biohazards, the DOT and OSHA regulations intersect. One popular option for containing biohazards in the workplace is to use a biohazard “red box.”
Hazmat shipments packaged in the red box and affixed with the correct OSHA label are exempted from many of the US DOT’s Hazardous Materials Regulations (49 CFR 173.134).
49 CFR Shipper Training for Medical Hazmat and Waste
For hazmat shippers in the medical industry, Lion offers online training for both Shipping Infectious Substances (and Dry Ice) and Shipping Regulated Medical Waste. Learn the US DOT regulations for classifying, naming, packaging, marking, labeling, loading, unloading, and documenting these hazmat shipments. The US DOT requires training for all hazmat employees once every three years, and fines for hazmat shipping mistakes are now as high as $75,000 per day, per violation.