On April 2, in support of the critical need to move hazardous materials during the COVID-19 public health emergency, the U.S. Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a temporary relief notice for companies shipping hand sanitizers used for sanitation purposes.
Intended to make sanitation products readily available during the public health emergency, the relief applies to hand-sanitizer products that meet certain specifications and are shipped by highway only; shipments made by air, rail or water.
As alcohol-based products, hand sanitizers are typically classified as a Class 3 Flammable Liquid, meaning they have a flash point (the temperature at which a particular organic compound gives off sufficient vapor to ignite in air) of 140 degrees Fahrenheit, and require specific packaging, labeling and shipping procedures.
“PHMSA is aware of multiple companies throughout the country that will be producing products such as hand sanitizer and other alcohol-based products to help respond to the COVID-19 public health emergency under specific FDA (Food and Drug Administration) guidance,” the notice of relief states. “… PHMSA intends to provide temporary relief from certain HMR (hazardous material requirements) while continuing to maintain an appropriate level of safety for companies that are producing products under the FDA guidance.”
- Temporary relief is offered for shipments of hand sanitizer when the following requirements are met:
- Packages contain hand sanitizer containing either ethyl alcohol or isopropyl alcohol at a concentration not to exceed 80%.
- Packagings are leak-tight and securely closed, secured against shifting, and protected against damage.
- The material is contained in a packaging having a capacity not over 8 gallons.
- For inner packagings not exceeding 1 gallon:
- Packages are a combination package and the inner receptacle containing the liquid is placed inside an outer packaging where the inner packagings are secured and cushioned within the outer packaging to prevent breakage, leakage, and movement and inner packagings are packed with package closures in an upright orientation.
- The net contents of all inner packagings in any single outer packaging do not exceed 8 gallons (e.g., 8×1 gallon packages).
- The company name and the words “Sanitizer – Contains Ethyl Alcohol”’ or “’Sanitizer – Contains Isopropyl Alcohol”’ are marked on the outer package and, if applicable, the overpack.
- Packages exceeding a capacity of 1 gallon:
- Are overpacked in crates, cages, carts, boxes or similar overpacks.
- Packages are secured in the transport vehicle in such a way as to prevent breakage, leakage and movement. Packages are packed package closures in an upright orientation.
- The company name and the words “Sanitizer – Contains Ethyl Alcohol” or “Sanitizer – Contains Isopropyl Alcohol” is marked on the outside of the single package and the overpack.
Temporary relief guidelines for sanitizer packaged in quantities of more than 8 gallons, for example in drums, are also noted in the document.
To read the temporary notice of relief in its entirety, click here.