Packing and transporting clinical waste
This fact sheet provides information on the packing and transport of clinical waste in accordance with dangerous goods transport legislation and the Australian Dangerous Goods Code.
It will assist employers, employees, controllers of premises or workplaces, and all persons involved with the handling and transport of clinical waste.
This fact sheet only covers general clinical waste classified as UN3291.
Safety standards are applied to the packing and transport of clinical waste in order to minimise the possibility of spills that could endanger employees in the medical or waste industries, members of the emergency services or the public and the environment.
This information should be read in conjunction with the following documents:
- Australian Dangerous Goods Code Edition 7.3 (ADG Code)
- Dangerous Goods (Road and Rail) Transport Act 2008
- Dangerous Goods (Road and Rail) Transport Regulation 2014 (the Regulation)
- Biohazard Waste Industry Code of Practice for the Management of Biohazardous Waste (including Clinical and Related Wastes), 7th Edition (BWI Code)
- This fact sheet does not describe additional obligations that may exist under other legislation such as the Protection of the Environment Operations (Waste) Regulation 2005.
- This fact sheet applies in NSW – some other states may not regulate clinical waste under dangerous goods legislation.
Classifying clinical waste
Clinical waste is a Division 6.2 dangerous good (Infectious Substances) and is identified by the number UN3291.
Not all hospital or medical waste can be classified as UN3291 clinical waste. A waste stream may only be classified as UN3291 if it does not meet the criteria for more hazardous infectious substances UN2814 or UN2900.
Clinical waste classifications are determined by the level of infection not the type of waste item.
Full details on classification of clinical waste are available in section 2.6.3 of the ADG Code:
- 18.104.22.168.1 Medical or clinical wastes containing Category A infectious substances must be assigned to UN2814 or UN2900 as appropriate. Medical or clinical wastes containing infectious substances in Category B must be assigned to UN3291.
- 22.214.171.124.2 Medical or clinical wastes which are reasonably believed to have a low probability of containing infectious substances must be assigned to UN3291. For the assignment, international, regional or national waste catalogues may be taken into account.
Packing in portable and mobile bins
The ADG Code contains simplified requirements for packing and transporting UN3291 clinical waste. These requirements allow for the use of portable bins (20 L to 80 L capacity) and mobile bins (50 L to over 600 L capacity).
You can find detailed requirements in packing instruction P62A in the ADG Code, which applies to the land transport of clinical waste within Australia.
UN3291 clinical waste can be packed in portable and mobile bins under P62A as long as each bin complies with each of the following requirements:
- Rigid construction with a lid that is able to be secured during transport.
- Designed to be easily handled or moved.
- Strong enough to withstand manual or mechanical handling and shocks and loadings normally encountered during transport, including trans-shipment between vehicles and warehouses.
- Able to retain liquid under normal conditions of transport.
- Easily identifiable by its colour.
- Has the correct labelling and symbols indicating that it contains UN3291 clinical waste.
Note that P62A sets out additional requirements for bins that are intended to contain sharp objects such as broken glass and needles.
Marking, labelling and placarding bins
Portable and mobile bins containing UN3291 clinical waste must be marked, labelled and placarded as required by chapters 5.2 and 5.3 of the ADG Code.
Each bin up to and including 500 L capacity must bear the Division 6.2 label (see right), and be marked with the number UN3291, as well as one of the following permitted proper shipping names:
- CLINICAL WASTE, UNSPECIFIED, N.O.S.
- (BIO) MEDICAL WASTE, N.O.S.
- REGULATED MEDICAL WASTE, N.O.S.
Each bin with a capacity exceeding 500 L must be placarded with Emergency Information Panels (EIPs) – see below.
Bins of all sizes must be marked with the name and address of the manufacturer or consignor of the clinical waste, or their agent.
It is generally an offence to consign or transport packages or receptacles that do not contain dangerous goods, but which are labelled as if they do. However, cleaned and disinfected bins being returned to the waste generator are permitted to retain their markings as long as:
- are identified as such in transport documentation, or
- are tagged to indicate that they are clean and ready for re-use
Transporting clinical waste
UN3291 clinical waste may be transported in portable and mobile bins under P62A as long as the transport vehicle is dedicated to the transport of clinical waste and it has a body that is:
- separate to the cabin
- totally enclosed, of strong, rigid, weatherproof construction with lockable doors
- leak proof, bunded or configured to contain spillages.
In addition, the vehicle must carry a spill kit that complies with the BWI Code.
The transport of UN3291 clinical waste must also comply with all other requirements of the ADG Code, relating to:
- transport documentation
- emergency information
- vehicle placarding, including:
- displaying class labels or EIPs, depending on the capacities of bins transported
- removing vehicle placards when the load consists of only empty, clean bins
- safety equipment, including fire extinguishers, and protective equipment
- driver and vehicle licensing
Other infectious substances
Dangerous goods other than UN3291 must be packaged and transported in accordance with the ADG Code and the Regulation. Such substances may involve higher hazards and include:
- infectious substances affecting humans or animals (UN2814/UN2900)
- cytotoxic waste (where classified and transported as UN2810)
- genetically modified organisms (UN3245/UN3373)
Substances which are not classified as UN3291 cannot be packed and transported under P62A. They are not covered by this fact sheet and will need to comply with the full packing and transport requirements of the ADG Code.
Other substances may be transported on the same dedicated clinical waste vehicles as UN3291, however there are likely to be additional/different vehicle placarding requirements for such combined loads and these are not covered in this fact sheet.
- The National Transport Commission's Australian Dangerous Goods Code
- NSW Government's Dangerous Goods (Road and Rail Transport) Act
- NSW Government's Dangerous Goods (Road and Rail Transport) Regulation
- EPA (transport related matters): www.epa.nsw.gov.au/dangerousgoods/index.htm
- WorkCover (classification matters): www.workcover.nsw.gov.au
- Biohazard Waste Industry Australia & New Zealand: www.clinicalwaste.org
Catalogue No. WC01666