When these materials are transported, Department of Transportation (DOT) Hazardous Materials Regulations may apply and are extremely complex in nature. Laboratory personnel must properly package, transport, and handle any Infectious substances which are used in their research Labeling using the universal biohazard symbol is also required for any infectious biological materials in order to prevent accidental exposure to unsuspecting personnel who may be exposed to the biological material (e.g., couriers, administrative staff, and janitors).
The following packaging requirements apply to all ground transport of infectious substances prepared for transport either on-grounds or off-grounds irrespective of the mode of transportation (excludes hand-carry, see section C):
Category A: must NEVER be transported by ground in a motor vehicle. Materials may only be shipped by air or hand carried from building to building.
NOTE: Contact EHS (982-4911) before planning to ship any Category A Infectious Substance.
Off-site ground transport is NOT permitted!
These shipments MUST be consigned by air with a commercial carrier (e.g., FedEx, DHL).
Category B: must follow the IATA/DOT requirements for Packaging Instruction, PI 650.
Exempt Patient/Animal Specimens1: should be triple-packaged (i.e., as in Category B with leak proof primary and secondary containers2, absorbent material for liquids, and a rigid outer container). A biohazard symbol must be placed on either the secondary container or the outer container to meet OSHA compliance (29 CFR 1910.1030) if materials are human.
The following are means by which Infectious Substances may be legally transported within and around the University. The DOT Hazardous Material Regulations (49 CFR Parts 171-180) regulates the movement of Division 6.2 Infectious Substances and are regulated when carriage is considered to be "in commerce".
Transport in Personal or University Vehicle
In general, movement or ground transport of regulated materials is covered by the HMR only when they are considered to be “in commerce.” Division 6.2 Infectious substances transported in a personal or university (i.e., government) vehicle for use in university activities (projects, research, etc.) is generally not considered to be “in commerce.” However, these personnel must 1) have a valid driver’s license, 2) be authorized to use a University vehicle, 3) should use a University vehicle when available, 4) use the proper containment and packaging materials en-route and 5) be trained and authorized to handle and transport hazardous materials within University property.
EHS encourages the use of university-owned vehicles rather than personal vehicles when transporting materials off grounds to another UVA facility or collaborator*. Accidents during movement or transportation of any of these materials can result in serious harm to persons and property. Release and spills of these materials may involve police and HazMat responders including clean-up and cost of recovery.
*Note: If using a personal vehicle to transport the individual should consult with his/her personal insurance policy regarding liability and coverage in this instance.
Under NO circumstances may public transportation (e.g. UVA or City of Charlottesville buses, trolleys, private taxis, etc.) be used for transport of work-related Hazardous Materials.
Transport by contracted carrier
Commercial or Private carriers (i.e., commercial transport companies) are subject to the HMR. These include companies such as FedEx, DHL as well as medical couriers LabCorp, Quest, etc.). Transport of infectious substances to other institutions or entities such as another university, a waste disposal facility, or a return to the manufacturer should only be done by DOT licensed hazardous materials carriers to another location via a public thoroughfare. When Principal Investigators leave an institution, the research gets transferred to the new institution, which then becomes the owner; however, the original institution is legally responsible for the shipment to the new institution. Contact EHS (982-4911) for consultation.
PIs are strongly encouraged to consult with EHS (982-4911) before selecting a carrier. Category A and Category B Infectious Substance should be consigned by air (patient specimens are exempt) or assurance from the carrier must be given that DOT regulations are being met.
As of October 1, 2006 the DOT regulations state that Materials of Trade or (MOTS, see 49 CFR §173.6) exceptions only apply to patient specimens or those samples that would be otherwise considered Category B that are contained in a human (patient) or animal sample (no cultures). Therefore personal or dedicated vehicle transport in addition to carrier transport can only use a MOTS exception for Patient Specimens.
Transport (hand-carry) between University labs or buildings through public areas
Infectious substances must be transported or moved between laboratories in way as to prevent spills and accidental exposure or release including:
1DOT’s "Patient Specimen" definition and exemption differs from the IATA definition when materials are shipped by air. Contact EHS Biosafety for more information if shipping by air.
2Pressure-tested (i.e., 95 kPa) secondary containers not required for ground transport
The handling and movement of hazardous materials within a building between rooms is governed by:
29 CFR 1910.1030, Bloodborne Pathogens Standard
29 CFR Part 1910.1200, Hazard Communication
29 CFR Part 1910.1450, Occupational Exposure to Hazardous Materials in Laboratories
40 CFR Part 262, Standard Applicable to Generators of Hazardous Waste.
The ground (vehicle) transport of hazardous materials between buildings or off-site to other entities is governed by:
49 CFR Parts 171-180, Hazardous Materials Regulations
171.1 (d) Functions not subject to the requirements of the HMR.
The following are examples of activities to which the HMR do not apply:
(5) Transportation of a hazardous material in a motor vehicle, aircraft, or vessel operated by a Federal, state, or local government employee solely for noncommercial Federal, state, or local government purposes.
(6) Transportation of a hazardous material by an individual for non-commercial purposes in a private motor vehicle, including a leased or rented motor vehicle.Air transport is regulated by the IATA Dangerous Good Regulations, 49th Ed. 2008.
Federal Aviation Administration, Dangerous Goods Program
Federal Motor Carrier Safety Administration, US Department of Transportation
Federal Railroad Administration Hazardous Materials Program, US Department of Transportation
International Air Transport Association
Office of Research Services, National Institutes of Health - Shipping Hazardous Materials Safely
Research and Special Programs Administration, US Department of Transportation
United States Coast Guard, Marine Protection and Environmental Safety