Category: Regulations

Due to COVID-19, more companies are offering alcohol based hand sanitizer for transportation. PHMSA has issued a notice offering temporary relief from some of the hazardous materials regulations for products that are being produced under the FDA’s guidance.

This relief has been extended until October 31, 2020. The extension notice can be found here.

This relief

• applies to highway transportation only.

• will expire when the health emergency is over or 3 months from the issue date (April 2, 2020), whichever is sooner. EXTENDED UNTIL OCT. 31, 2020. NOTICE FOUND HERE.

• states that PHMSA will not take enforcement action for violations of the hazardous materials regulations if the procedures in the notice are followed.

The required provisions will depend on the amount to be shipped. See the provision summaries below.

PACKAGING UP TO 8 GALLONS of hand sanitizer containing ethyl alcohol or isopropyl alcohol with an alcohol content not exceed 80%. The requirements to be followed are based on the container size of the hand sanitizer. If 1 gallon or less, refer to number 1 below. Over 1 gallon, refer to number 2 below.

1. Combination packaging – inner packaging up to 1 gallon each and outer packaging cannot exceed 8 gallons total (e.g. 8 x 1 gallon packages)
   • PACKAGING REQUIREMENTS
     • Leak tight packagings must be securely closed. Protected against damage and secured against shifting.
     • Package closure in an upright orientation
   • MARKING ON OUTER PACKAGE AND OVERPACKS
     • Company name
     • The words “Sanitizer – Contains Ethyl Alcohol” or “Sanitizer – Contains Isopropyl Alcohol”
   • NOT REQUIRED TO:
     • apply flammable liquid hazard class label
     • apply any additional marking(s)
     • placard vehicle
     • prepare hazmat documentation
       
2. Packagings – exceeding 1 gallon capacity
   • PACKAGING REQUIREMENTS
     • Packages are overpacked in crates, boxes, cages, carts, etc.
     • Secured in transport vehicle to protect against damage, leakage and movement.
     • Package closure in an upright orientation
   • MARKING ON PACKAGE AND OVERPACKS
     • Company name
     • The words “Sanitizer – Contains Ethyl Alcohol” or “Sanitizer – Contains Isopropyl Alcohol”
   • NOT REQUIRED TO:
     • apply flammable liquid hazard class label
     • apply any additional marking(s)
     • placard vehicle
     • prepare hazmat documentation

PACKAGING OVER 8 GALLONS of hand sanitizer containing ethyl alcohol or isopropyl alcohol with an alcohol content not exceed 80%.

1. Packagings – exceeding 8 gallon capacity but not more than 119 gallons
   • PACKAGING REQUIREMENTS
     • DOT or UN specification packaging is required.
       • Must be X or Y performance level packaging
     • Leak tight packagings must be securely closed.
     • Protected against damage and secured against shifting.
   • LABELING
     • Class 3 flammable liquid label must be on all packages
   • DOCUMENTATION
     • Bill of lading must include the following:
       • Basic description “UN1987, Alcohols, n.o.s., Class 3, PG II”
       • Number, type and capacity of packages offered (e.g. 25 drums – 119 gallons ea.)
   • EMERGENCY RESPONSE GUIDE 127 must accompany the shipment
     • Click here for a copy of Guide 127
   • PLACARDS – FLAMMABLE LIQUID
     • Required if aggregate gross quantity in vehicle exceeds 1001 lbs.
   • PHMSA REGISTRATION not required
   • EMPLOYEE TRAINING
     • Required for all shippers and carriers of this materials
     • PHMSA has provided training materials
       • Presentation slides from PHMSA can be downloaded here
       • Craft Spirits Assoc. Webinar on shipping alcohol based hand sanitizers can be found here. This is a 50 minutes webinar.
   • All motor carriers must comply with 49 CFR 177.804

A copy of this notice from PHMSA can be found here.

If you have any questions on shipping hand sanitizer or any other hazardous materials, please let us know. Email us at hello@hazmathelp.com or call us (704) 573-0955.

Stay safe and healthy!

Christine Holloway-Clare is the Vice President of Safety Specialists, Inc. She has been assisting customers comply with the hazardous materials regulations for over 20 years.

Safety Specialists, Inc. offers a wide range of hazardous materials transportation training and consulting options. Online training is available. Monthly online classes for DOT, IATA and IMDG available. Join one today.