Caroline Raine discusses the carriage of clinical waste in bulk.

Clinical waste is classified as Class 6.2 Infectious substances. ADR defines clinical, and medical, wastes as “wastes derived from the medical treatment of animals or humans or from bio research”.

Clinical waste is assigned to UN 3291 with one of three proper shipping names (PSN) being possible, as appropriate:




A second line entry exists for the same UN number and PSNs, but the lower case descriptive text in this entry indicates that it is for such wastes when carried in refrigerated liquid nitrogen. Both entries are assigned to Packing Group II.

UN 3291 carried in refrigerated liquid nitrogen is outside the scope of this article, and the following categories do not apply either.

Clinical waste can be carried as:

  • bulk carriage — loose loading of plastics bags into the back of a vehicle

  • a package — bags loaded into a bin.

The rest of this article is concerned with clinical waste carried in bulk only.

Authorisation for carriage in bulk

Chapter 7.3 of ADR specifies that goods may not be carried in bulk unless there is a special provision (identified by the code BK in column 10, or by a VV code in column 17).

UN 3291 is assigned the special provision BK2 (ADR in column 10 or VV11 (ADR 7.3.3) in column 17.

The DfT has not approved any BK containers for UN 3291, so in Great Britain carriage in bulk currently has to be under the terms of VV11.

Special provision VV11

Special provision for carriage VV11 is found in ADR 7.3.3 and states:

“Carriage in bulk is permitted in specially equipped vehicles and containers in a manner which avoids risks to humans, animals and the environment, eg by loading the wastes in bags or by airtight connections.”

Thus VV11 sets a standard, but does not prescribe how that is to be achieved.

The conditions set out in apply to carriage under the BK2 provisions, and the Health and Safety Executive (HSE) guidance indicates that if the conditions in (other than sub-para (c)) are met, then compliance with VV11 should be achieved.

Conditions to be applied

ADR specifies the requirements for carriage in bulk in containers of UN 3291 and, applied mutatis mutandis to vehicles, requires that the following conditions be met.

  • Vehicles and their openings must be leak-proof by design, have non-porous interior surfaces, and be free from cracks or other features which could damage packagings inside, impede disinfection or permit inadvertent release.

  • Wastes of UN 3291 shall be contained within the vehicle in UN-type tested and approved sealed leak-proof plastics bags tested for solids of Packing Group II and marked in accordance with Hence bulk carriage of UN 3291 is normally in yellow or orange bags loosely loaded into the back of a vehicle.

  • The plastics bags must be UN-approved and capable of passing the tests for tear and impact resistance according to ISO 7765-1:1988 Plastics film and sheeting — Determination of Impact Resistance by the Free-falling Dart Method — Part 1: Staircase Methods and ISO 6383-2:1983 Plastics — Film and sheeting — Determination of Tear Resistance. Part 2: Elmendorf Method.

    Since January 2009 manufacturers have been expected by the DfT/VCA to mark bags carrying a UK-authorised mark stating whether they meet that standard or not (this is not an ADR requirement).

    Typical bag marking will begin “5H4/Y */S” (where “*” is the maximum allowed gross weight of the bag in kg). However, the maximum net mass of each plastic bag shall not exceed 30kg.


    Despite being in UN-type approved bags, and usually showing the Class 6.2 label, the bags are not an acceptable form of package for clinical waste.

  • Wastes of UN 3291 that contain liquids must be carried in plastics bags containing sufficient absorbent material to absorb the entire amount of liquid.

  • Wastes of UN 3291 containing sharp objects shall not be carried as bulk in bags (ie shall only be carried in UN-type tested and approved rigid packagings).

  • Rigid packagings must be properly secured to prevent damage during normal conditions of carriage. Wastes carried in rigid packagings and in plastics bags in bulk together in the same vehicle shall be adequately segregated from each other.

  • Wastes of UN 3291 in plastics bags shall not be compressed in a vehicle so that bags may no longer be rendered leak-proof.

  • The bulk vehicle shall be inspected for leakage or spillage after each journey. If any wastes have leaked or been spilled, the vehicle shall not be re-used until it has been thoroughly cleaned and, if necessary, disinfected or decontaminated.


The transport document must be in accordance with ADR, and Instructions in Writing must also be present on the vehicle.

Driver training

For carriage in bulk the driver has to be ADR-trained and examined and certified, other than in tanks, at least for class 6.2, as set out in ADR 8.2.2. There is no "small load" exemption for bulk carriage.

General training under ADR 1.3 is also required for all others who may be involved in the carriage of the goods.

Vehicle equipment

The vehicle will need to carry one minimum size 2kg dry powder fire extinguisher. This is because Special Provision for Carriage (Operation) Sin Column 19 is applied to Class 6.2 entries derogating from the requirement for vehicles carrying only Class 6.2 substances to have further extinguisher(s) in relation to the vehicle size for loads exceeding the threshold.

All other equipment specified in ADR 8.1.5 must be carried, wheel chock, high visibility jacket and portable light for each crew member, two warning signs and eye rinsing liquid. Note that there is no requirement for a shovel, a drain seal or a “collecting container”.

Further information

More information can be found in the HSE Dangerous Goods manual. Clinical waste has its own section.

Last reviewed 15 August 2012