Waste That May Contain Category A Material

Human pathogens and toxins must be disposed of appropriately in order to prevent any accidental release that could pose a threat to public health and safety. Several facilities are subcontracting third parties for off-site decontamination of waste containing biological material . Waste containing biological material for decontamination by a third party can range from small to large amounts of contaminated liquid or solid waste. Waste can be composed of biological material that is regulated by the Public Health Agency of Canada under the following:

• Human Pathogens and Toxins Act ;
• Human Pathogens and Toxins Regulations ;
• Health of Animals Act ; and
• Health of Animal Regulations

Regulated parties must ensure that they also comply with the Transportation of Dangerous Goods Act and Regulations , administered by Transport Canada, when conducting any of the following activities that involve sending waste containing biological material to third parties for off-site decontamination:

• classifying
• packing
• labeling
• shipping

To ensure compliance with the Transportation of Dangerous Goods Act and Regulations, as detailed in the Shipping infectious substances bulletin, waste containing biological material known or reasonably believed to contain viable micro-organisms, or other agents, known or reasonably believed to cause disease in humans or animals, is to be shipped under Class 6.2, Infectious Substances, using the appropriate shipping name, depending on its content:

• UN2814 – INFECTIOUS SUBSTANCE, AFFECTING HUMANS, if they contain Category A infectious substances affecting humans
• UN2900 – INFECTIOUS SUBSTANCE, AFFECTING ANIMALS only, if they contain Category A infectious substances affecting animals, but not humans
• UN3291 – CLINICAL WASTE, UNSPECIFIED, N.O.S., or (BIO) MEDICAL WASTE, N.O.S., or REGULATED MEDICAL WASTE, N.O.S., if:
• the medical or clinical waste contain Category B infectious substances, or
• the medical or clinical waste are reasonably believed to have a low probability of containing infectious substances
• UN3549 - MEDICAL WASTE, CATEGORY A, AFFECTING HUMANS, solid, or MEDICAL WASTE, CATEGORY A, AFFECTING ANIMALS only, solid
• Note: UN3549 is a new classification. This classification is for solid medical waste containing Category A infectious substances generated from the medical treatment of humans or veterinary treatment of animals; liquid waste or waste generated from biological research should not be assigned to UN3549.

Packaging of medical or clinical waste must comply with the Transportation of Dangerous Goods Regulations based on the category of infectious material.

As per the Canadian Biosafety Standard, third edition , all regulated waste generated at containment level 3 and 4 must be decontaminated at the containment barrier. At containment level 2, we recommend decontamination of any materials containing Risk Group 2 Category A infectious substances, such as a culture of enterohemorrhagic Escherichia coli , prior to off-site transportation to a third-party biohazardous waste disposal facility, along with the other Category B infectious substances. Doing so will allow it to be shipped under UN3291. Any inadvertently produced Risk Group 3/Risk Group 4 Category A infectious substances, such as inadvertently produced Brucella melitensis, must be decontaminated prior to off-site transportation to a third-party biohazardous waste disposal facility . If on-site decontamination isn’t possible, the waste would still be considered as Category A infectious substances, and therefore would require off-site transportation under UN2814, UN2900 or UN3549 to a regulated party holding an appropriate Pathogen and Toxin licence (for inadvertently produced Risk Group 3/Risk Group 4 material) or to a third-party biohazardous waste disposal facility (for Risk Group 2 material).

• Refer to Transportation of Dangerous Goods Regulations APPENDIX 3 Guide to Category A and Category B Assignment for Category A and B infectious substances lists.
• If an infectious substance is not found on this list, contact pathogens-pathogene@phac-aspc.gc.ca for assistance in determining the appropriate category under which it should be considered.

For additional details regarding transportation of infectious substances, consult Transport Canada’s bulletin Shipping infectious substances . Failure to comply with the Transportation of Dangerous Goods Act and Regulations may lead to fines and/or imprisonment.

Furthermore, regulated parties may also be held civilly or criminally liable if improper disposal of human pathogens or toxins results in harm or risk to public health, safety or security. Negligence, such as failing to follow proper disposal protocols or ignoring safety regulations, can lead to significant legal liabilities.