PHMSA Protocols 8 & 9
October 2, 2014
PHMSA 9 Protocols: Form 14 – 22 Elements (Protocols 10,11 & 12)
October 2, 2014

PHMSA & Ebola – What’s the Connection?

PHMSA shapes the daily activity and regulatory compliance decisions of every organization in and related to the energy industry. However, PHMSA also has a global impact capable of establishing best practices for safely handling infectious substances, such as Ebola (also known as Ebola Virus Disease or EVD) contaminated items.

On June 1, 2006, PHMSA published a final ruling (effective beginning October 1, 2006) revising the classification criteria and packaging requirements to consistently align with United Nations Recommendations of Dangerous Goods for Category A and Category B Infectious Substances. Category A: Infectious Substance is defined as an infectious substance in a form capable of causing permanent disability or life-threatening or fatal disease in otherwise healthy humans or animals when exposure to it occurs. Ebola is considered a Category A: Infectious Substance.

Ebola can be transmitted through infected materials, infected individuals, and infected animals. Therefore, transport of infected Personal Protective Equipment (PPE), infected individuals, and infected animals is regulated by PHMSA under 49 CFR, Parts 171-180. (To review the regulation specifics, visit www.phmsa.dot.gov) Generally, these regulations apply to the medical industry. However, individuals in other industries, such as the oil and gas industry, and the general public can greatly benefit from awareness to and knowledge of appropriate responses to encountering in-transit infected materials, infected individuals, and infected animals. Any container transporting a Category A: Infectious Substance, such as Ebola, must be marked with an approved and distinctive shipping label. The Infectious Substance label is used for domestic transport, and UN3373 label is used for international transport, under approved conditions.

Although the OQ Rule officially became a mandate in 1999 for the oil and gas industry specifically, the energy industry, in general, began self-regulating in the 1800s. Since the 1800s, the energy industry has established a long history of self-regulation and development of best practices to promote safety and protection to human life and property, established methods for quality workmanship and continuous improvement to develop a qualified workforce, and trained individuals to effectively recognize and react to Abnormal Operating Conditions (AOC). Properly identifying and reacting to encountering an infectious disease would qualify as an abnormal operating condition.

Safety first is a true priority with the oil and gas industry, PHMSA, and the DOT. The energy industry has a wealth of knowledge, experience, and proven effective best practices related to safety and the development of operational safety regulations. This is just another way the best practices and safety experiences of the oil and gas industry is continually improving the lives of people both here and around the globe.

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