Infectious Substance Special Permits
When is a special permit needed to transport an infectious substance?
A special permit (SP) from the U.S. DOT is only required when, for a specific reason, a shipper or carrier is unable to comply with the Hazardous Materials Regulations (HMR) as written. The DOT carefully reviews and approves alternative actions and requirements to ensure that an equivalent level of safety to the HMR is maintained.
Ebola DOT-SP Information
Why is a special permit needed to transport suspected or confirmed Ebola contaminated waste?
Solid materials contaminated with the Ebola virus are classified as Category A infectious substances according to the Hazardous Materials Regulations (HMR). Category A infectious substances -- including the Ebola virus -- may only be transported in two scenarios; in full compliance with classification and packaging requirements of the HMR; or under the terms of a special permit. Because of the relatively large quantity of contaminated waste generated when treating patients with known or suspected Ebola Virus Disease (EVD), the available packagings authorized under the regulations governing the transport of Category A infectious substances were not large enough to meet the need. Alternative packaging designs were needed to meet safety requirements and to accommodate the large volume of waste. The emergency special permit authorizes transportation of these materials in the alternative packaging designs.
What is different about this most recent special permit from those issued to Stericycle in Texas?
This special permit is not site specific; meaning, it is applicable for use anywhere in the United States where a need arises for disposal of suspected or confirmed Ebola-contaminated waste. It also allows additional companies to apply for "party status," authorizing them to transport infected waste using the same special permit.
This permit does not require a specific type of packaging; rather, it provides for a degree of flexibility in packaging design to accommodate the needs of the collection and disposal facilities without compromising the level of safety to the public, as long as all of the performance requirements specified in the special permit are met.
How many special permits have been granted?
As of 10/28/2014, seven companies have been granted party status to transport waste under the provisions of this special permit:
- Veolia ES Technical Solutions, LLC
- Triumvirate Environmental, Inc.
- Stericycle, Inc.
- Smith Systems Transportation, Inc.
- Advanced Environmental Options, Inc.
- Clean Harbors Environmental Services, Inc.
- Daniels Sharpsmart, Inc.
Where can I find the most recent version of the special permit and how can I locate the most recent list of companies holding party status to DOT-SP 16279?
Enter "16279" on our Special Permits Search page for the most recent version of this special permit and a complete list of companies holding party status.
What is the process for obtaining party status to this special permit?
The requirements for applying for party status can be found in 49 CFR 107.107.
Does this mean that infected waste may now be transported by other modes?
Yes, transportation is now authorized by Motor Vehicle and Vessel.
Can this special permit be used at sites which are not hospitals or other medical facilities?
This special permit may be used to transport Ebola-contaminated waste originating anywhere in the U.S., which would include medical facilities or other areas where Ebola-contaminated waste has been generated and must be transported for disposal.
What role do other Federal agencies play in the transport of hazardous materials?
DOT has jurisdiction over transportation; however, we work closely with CDC, OSHA, HHS, DOD, EPA, and state and local government to assure that our respective safety missions are adequately addressed in these scenarios.
What other safety measure have been put in place by these special permits?
In addition to the conditions specified in the packaging section, the special permit requires the following key operational controls:
- The transport vehicle must be attended at all times;
- Each commercial motor vehicle and driver involved in this operation must be made available for a Commercial Vehicle Safety Alliance Level I hazardous materials inspection prior to transport;
- The carrier must maintain a written spill response plan with guidelines for protecting employees and decontaminating any released material in the event of an accident; and
- The carrier must adhere to strict packaging requirements, including a series of inner and outer packaging and the application of a disinfectant recommended by the Center for Disease Control to the inner packaging. Outer packaging must meet specified performance requirements.