PHMSA – Page 2 – Expert Hazmat Help since 1993

August 11, 2020August 11, 2020

2020 Emergency Response Guidebook

The 2020 Emergency Response Guidebook (ERG) has been released. This is the small orange book that should is used by emergency responder during a hazmat incident. The 2020 ERG replaces the 2016 edition.

For those of you who cannot wait until you have this book in your hands. There is an app or you can download a copy below.

For the App, search the App Store for ERG 2020 by the National Library of Medicine and you can download for free.

Files to download. The ERG is available in English, Spanish and French.

2020 ERG – English

2020 ERG – French

2020 ERG – Spanish

2020 ERG Windows Software – download here

Additional ERG files as well as a video showing how to use the ERG can be found at https://www.phmsa.dot.gov/hazmat/erg/erg-data-files.

Stay Safe!

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.

April 14, 2020June 8, 2020

PHMSA notice on shipping papers

On April 10, 2020, PHMSA issued the following on existing options for hazmat shipping papers.

“Notice Highlighting Existing Options Related to Hazardous Materials Shipping

Papers and Social Distancing during the COVID-19 Public Health Emergency

The U.S. Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) has received inquiries regarding the requirements of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the exchange of shipping

papers. Many of these inquiries have focused on the need to maintain social distancing between shippers and carriers.

Under the HMR, no physical contact between parties is required for the purposes of shipping papers. Shippers and carriers may therefore meet all requirements for hazardous materials

shipping papers and maintain necessary social distancing. Shippingpapersmaybe exchanged, for example, by physically attaching the document to a clipboard and placing it on a table and stepping away while the paper is signed, or sending the document via email or other means of electronic transmission.

Concerns have specifically been raised about the shipper’s certification statement. Section 172.204(d) states that the shipper’s certification on a shipping paper: ”…[m]ust be legibly

signed by a principal, officer, partner, or employee of the shipper or his agent; and … [m]ay be legibly signed manually, by typewriter; or by other mechanical means.” A shipper may ask a person to sign on its behalf, i.e., to entei’the shipper’s name as the signature for the shipper’s certification on the shipping paper. The request may be made verbally or in writing, and may be electronically transmitted (e.g., text message or email).

Using the methods outlined above, PHMSA believes carriers and shippers may satisfy the safety requirements of the HMR while maintaining appropriate social distancing during the COVID-19 public health emergency.”

A copy of the notice can be found here.

April 9, 2020July 14, 2020

Shipping Hand Sanitizer? PHMSA is offering some temporary relief

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.

PHMSA issued temporary relief for hand sanitizer shipped in the US

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.

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
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%.

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.