Due to the increase in Monkeypox cases in the U.S., FMCSA has been receiving questions regarding how Monkeypox samples and hazardous waste should be transported.
PHMSA has worked with the CDC to provide guidance on this matter, especially regarding two frequently asked questions.
“I’ve been informed that DOT require West African clade wastes to be transported as “Category B UN3373”. This is incorrect. Pursuant to Appendix F-2 of our updated Guidance Document Planning Guidance for Handling Category A Solid Waste | PHMSA (dot.gov), a waste or reusable material derived from the medical treatment of a human patient with West African monkeypox can be considered UN3291 Regulated Medical Waste. Patient and laboratory samples of West African monkeypox can be transported as UN3373, Biological substance, Category B. See our updated table at the end of Transporting Infectious Substances Safely | PHMSA (dot.gov) which states that monkeypox virus is a Category A substance, except for the West African clade.
“MPX wastes can be handled as RMW UN 3291, unless there is a suspicion the case may be Congo Basin. Is this correct and in accord with DOT regs?” Pursuant to 49 CFR 173.134(a)(1)(i), classification of waste as a Category A substance for transportation must be based on the known medical history or symptoms of the patient, endemic local conditions, or professional judgment concerning the individual circumstances of patient. If a clinician or their public health authority determine that a patient does not have known epidemiological risk for the Congo Basin clade of monkeypox, and recognizing that the current DOT guidance is to treat the West African clade as excepted from Category A, it is reasonable to manage waste from suspected monkeypox patients as UN3291 Regulated Medical Waste. However, if epidemiological risk factors indicate a risk for Congo Basin clade, waste should be managed as a suspected Category A infectious substance pending clade confirmation.