Table of Contents
- Standards to Consider
- 49CFR 173.150 (g)
- PHMSA’s Temporary Relief for Hand Sanitizer
- Non-Bulk Quantities
- The FDA’s Recommendations for Temporary Compounding of Hand Sanitizer
- Things to Consider When Shipping Flammable Liquids
- Carriers That Can Ship Hand Sanitizer (USPS, UPS, FedEx, etc.)
- How to Package Hand Sanitizer Shipments Properly
- Can You Send Hand Sanitizer Internationally?
- DOT Hazmat Training and Certification
Hand sanitizer is a popular commodity, great for keeping hands clean at home and on the go. It’s also vital for health care workers, who use it to keep their hands germ-free between washes and while working with patients. Hand sanitizer has been of particular concern lately, with the COVID-19 health emergency raising the demand for alcohol-based hand rubs and cleaners, causing shortages. Many businesses have stepped up to begin offering alcohol-based sanitizers to help combat this shortage. As a result, many new people need to understand the rules and guidelines for hazmat shipping.
Shipping liquids is already complicated because they must be packaged to avoid spillage. Since disinfecting hand gel is alcohol-based, it’s highly flammable and needs more precautions during transport. This guide breaks down the basics of shipping hand sanitizer following hazmat guidelines.
Standards to Consider
Several hand sanitizer shipping regulations will apply to any company wishing to transport alcohol-based flammable liquids. The Pipeline and Hazardous Materials Safety Administration (PHMSA), an agency of the U.S. Department of Transportation (DOT), oversees hazardous materials. Their standard, 49CFR 173, governs the general requirements for shipping and packaging hazardous materials and contains a section dedicated to ethyl-alcohol-based liquids. The Food and Drug Administration (FDA) also has some guidance to account for.
49CFR 173.150 (g)
PHMSA’s 49CFR 173.150 discusses flammable and combustible liquids, including alcoholic beverages. If you are a distillery now shipping antimicrobial hand gel during the coronavirus pandemic, you should note that hand sanitizer is classified separately from beverages within 173.150. Hand sanitizer falls under subsection g, “limited quantities of retail products containing ethyl alcohol.” Any retail product containing no more than 70% ethyl alcohol is exempt from Hazardous Materials Regulations (HMR) if it meets certain conditions.
If the liquid hand sanitizer has non-glass inner packaging, the volume cannot exceed 0.47 liters or 0.125 gallons. For volumes above 0.47 liters or 0.125 gallons, not exceeding 3.8 liters or 1 gallon, list your company name and the words “Contains Ethyl Alcohol” on the package.
If the liquid hand sanitizer has glass inner packaging, the volume should not exceed 0.23 liters or 0.063 gallons. For volumes above 0.23 liters or 0.063 gallons up to 0.47 liters or 0.125 gallons, your company name must appear on the package alongside the label “Contains Ethyl Alcohol.”
According to these rules, you may ship several bottles in the same outer package, so long as the net liquid content of all containers does not exceed 5.6 liters or 1.5 gallons per box. You must make sure you secure and cushion the bottles to prevent breakage, leakage and movement.
If the liquids contain more than 70% ethyl alcohol, they can also be exempt from HMR if each bottle’s contents do not exceed 0.23 liters or 0.063 gallons. The outer package cannot exceed 5.6 liters or 1.5 gallons when the net liquid volume of each bottle is added together.
The gross weight of each package shipped under this exception cannot exceed 29.9 kg (or 66 pounds).
Finally, when shipping by passenger or cargo aircraft, each inner packaging bottle cannot exceed 0.47 liters or 0.125 gallons.
PHMSA’s Temporary Relief for Hand Sanitizer
Due to the increase in demand for hand sanitizing gel during the COVID-19 pandemic, PHMSA has lifted some restrictions on shipping hand sanitizer. The temporary relief will last until October 31, 2020, unless the health emergency ends beforehand and applies only to shipment via highway. Shippers can now package up to 8 gallons of hand sanitizer containing up to 80% ethyl alcohol or isopropyl alcohol.
If the individual bottles are 1 gallon or less, you must meet these conditions:
- The items must be packed in a combination packaging, and the inner items must be securely closed, protected against damage and secured against movement.
- The inner must be placed in an upright position inside of the outer packaging.
- The outer package states the company name and either “Sanitizer — Contains Ethyl Alcohol” or “Sanitizer — Contains Isopropyl Alcohol.”
If the inner packaging exceeds 1 gallon, you must also meet these conditions:
- Packages are overpacked in crates, cages, boxes or carts.
- Containers are secured in the transport vehicle to avoid damage, leakage or movement.
- Both the package and the overpack must be marked with the company name and the words “Sanitizer — Contains Ethyl Alcohol” or “Sanitizer Contains Isopropyl Alcohol,” as appropriate.
In both cases, you are also exempt from:
- Flammable liquid hazard labeling.
- Any additional markings.
- Placarded vehicle transportation.
- Hazmat documentation.
Non-bulk quantities qualify as anything exceeding 8 gallons and not exceeding 119 gallons. You can ship them via a private carrier, contract carrier or common carrier. Non-bulk cargo is exempt from most DOT hazmat regulations if it follows the correct classification, packaging and hazard communication guidelines. Ethanol or isopropyl alcohol formulations for consumer or health care use can all be classified as UN ID number 1987, Proper Shipping Name (PSN) Alcohols, n.o.s., Hazard Class 3 and Packing Group PGII.
Non-bulk shipments must have leak-tight closures and be secured against movement or damage in the vehicle. They need a Class 3 flammable liquid label and a shipping paper that communicates its classification along with the number and type of packages and the total quantity in pounds, liters or gallons. The shipment must also include emergency response information. The vehicle must be placarded if the weight exceeds 1,001 pounds when loaded on the truck. In addition, the DOT generally requires several areas of training, including:
- General awareness and familiarization training.
- Function-specific training.
- Safety training.
- Security awareness training.
Any shipment above 119 gallons is considered bulk freight and is subject to all DOT hazmat regulations, including training and proper labeling. These shipments must be handled by a fully trained shipper of hazardous materials.
The FDA’s Recommendations for Temporary Compounding of Hand Sanitizer
While PHMSA’s regulations are mandatory, the FDA offers some nonbinding best practices you may want to consider. As recommended by the FDA, your product should contain either 80% ethanol in a liquid solution, denatured according to Alcohol and Tobacco Tax and Trade Bureau (TTB) regulations, or 75% isopropyl alcohol in a liquid solution. The compound shouldn’t contain any other ingredients except for:
- Hydrogen peroxide.
- Sterile distilled water or boiled cold water.
Ensuring the active ingredient is correct and used in the right amount is crucial. Recent testing has uncovered the substitution of methanol for ethanol or isopropyl alcohol, causing serious health concerns. The compounder must also label the hand sanitizer using the appropriate labeling system. There are different labels required for ethyl and isopropyl alcohol, as well as hand rubs used for health care personnel and consumers.
Things to Consider When Shipping Flammable Liquids
Before you are ready to ship out your antimicrobial hand gel, consider a few details to ensure you’re following the correct guidance.
What Are You Actually Making?
Many companies that are new to hand sanitizers are converted distilleries. They are using their existing setup to create high proof ethanol. From there, some distilleries ship out the product to another company to compound the hand gel. Others are bringing in all the ingredients to compound the product in-house. Shipping ethanol needs a different classification than shipping hand sanitizer ready for use, and you’ll need to research different packaging and shipping requirements.
What Are You Adding?
Hand sanitizer can be made with either isopropyl alcohol or ethanol. Depending on the amount being shipped, you will likely have to label the outer packaging with the active ingredients.
Carriers That Can Ship Hand Sanitizer (USPS, UPS, FedEx, etc.)
Should you send hand sanitizer in the mail? Can you ship it? You can send hand sanitizer in the mail. USPS conditionally accepts small shipments of hand sanitizers. Each carrier (e.g. USPS, UPS FedEx) has its own policies regarding hand sanitizer. Comply with your carrier’s acceptance criteria to ensure that your sterilizing hand rub reaches its final destination safely and on-schedule.
How to Package Hand Sanitizer Shipments Properly
Exactly how you package your hand sanitizer shipment will depend on the carrier you use. While all will require the leak-proof packaging and cushioning to prevent shifting en-route, each carrier may impose some additional packaging requirements. It’s crucial to contact your carrier to see what is appropriate before packaging your shipment.
Can You Send Hand Sanitizer Internationally?
While international shipping gets a bit more complicated, you can send hand sanitizer overseas when you use the right methods. USPS, for example, prohibits the shipment of flammable sanitizing gel or wipes internationally. So, for those wondering if you can send hand sanitizer overseas in a care package, the answer is no.
Companies that can contract larger orders with a private carrier can send commercial shipments of disinfecting hand rub via land and air. The international transfer of dangerous goods is regulated by the International Air Transport Association (IATA). So, while USPS only supports domestic shipping for hand sanitizer, your business can ship it internationally with the help of an IATA member carrier. Both UPS and FedEx are IATA members and can support international shipping for hand sanitizer.
DOT Hazmat Training and Certification
Any hazmat employee must receive training in several areas to be qualified to ship hazardous materials in large quantities. Any employer that transports hazmat in commerce or deals with packaging for use in the transportation of hazmat needs to have relevant employees trained. The DOT-required hazmat training must include:
- General awareness and familiarization.
- Function-specific training.
- Security awareness.
- In depth-security training, when a security plan is required.
- Driver training for employees who will operate motor vehicles.
The employer must also keep records of all employee training. Using a hazmat training program that provides certification for successful completion allows an employer to keep records of all necessary hazmat training and know exactly who is qualified to handle hazmat for transportation.
Get DOT Hazmat Certified at Hazmat School
Hazmat School offers various DOT hazmat training courses, including all the information required to ship hand sanitizer and other class 3 flammable liquids. Hazmat poses a risk to both employees and the environment, which is why comprehensive training is crucial for anyone involved in transporting these goods.
We make it easy for any organization to become compliant and any employee to get certified in shipping hazardous materials. Our affordable courses are 100% remote and online, letting students learn at their own pace. We even offer discounts to government employees and groups. Our courses provide access to 24/7 remote instructors to help students with questions.