If I told you that you should rub hazmat on your skin to protect your health, what would you say?
Don’t answer just yet!
Whether we notice it or not, hazardous materials play a major role in our everyday lives. From the fuel in our cars to batteries in our phones and so much more, hazmat improves our lives in ways that many of us take for granted.
In fact, many of us have grown accustomed to applying one specific hazardous material to our bodies quite regularly in 2020. We keep containers of this material readily available in our purses, jacket pockets, and car consoles. Lately, we use it just about everywhere that we go and before and after everything we do.
Any guesses? Does ethyl alcohol solution ring a bell? Isopropyl alcohol? Perhaps you‘re more familiar with a brand name like Purell. That’s right! Our everyday hand sanitizer is a regulated hazardous material.
Why is Hand Sanitizer a Hazardous Material?
Because alcohol is a key ingredient in hand sanitizer, most of the ones we use meet the definition of a Class 3 Flammable Liquid. Flammable liquids are those with a flash point less than or equal to 140oF [49 CFR 173.120].
The Hazardous Materials Regulations (HMR) break Class 3 Flammable Liquids into three Packing Groups:
PG I: Class 3 Flammable Liquids with an initial boiling point less than or equal to 95oF
PG II: Class 3 Flammable Liquids with a flash point less than 73oF and an initial boiling point greater than 95oF
PG III: Class 3 Flammable Liquids with a flash point greater than or equal to 73oF but less than or equal to 140oF and an initial boiling point greater than 95oF
[see 49 CFR 173.21]
Typically, hand sanitizers fall into Packing Group II or III.
Shipping Hand Sanitizer as Hazmat
When transported, all hazardous materials must be assigned an UN identification number and Proper Shipping Name. Listed below are some common entries associated with regulated hand sanitizers:
- UN1170, Ethyl alcohol solutions
- UN1219, Isopropyl alcohol
- UN1987, Alcohols, n.o.s.
- UN1993, Flammable liquids, n.o.s.
It is important to remember that it is the shipper’s responsibility to select the most fitting and specific name that accurately describes and matches the hazards of their material. [49 CFR 172.101(c)]
3 Basic Rules to Name Hand Sanitizer for Transport
To help a shipper determine the Proper Shipping Name (PSN), there are three basic rules:
1.Choose a Name from Column 2 of the 49 CFR 172.101 Hazardous Materials Table that is in “Roman type,” not in italics.
2.Be accurate.You must pick a name that describes what your material actually is. For example, if your hand sanitizer contained only Isopropyl alcohol, you would not select Ethyl alcohol solutions as your PSN. Being accurate also means that you select a name that not only matches the hazard class, but also matches the packing group.
3.Be specific.There might be more than one “accurate” name for material, however, you are required to select the most specific one.
The DOT’s order of specificity is:
i. Technical names
ii. Chemical group or family names
iii. Specific end use names
iv. Generic end use names
v. Hazard class names
So, if UN1987, Alcohols, n.o.s. and UN1993, Flammable liquids, n.o.s. are both accurate names for your hand sanitizer – you would select UN1987, Alcohols, n.o.s. because it's a chemical group/family name which is more specific than the hazard class name of UN1993, Flammable liquids, n.o.s.
Packaging, Marks and Labels for Hand Sanitizer
The packaging, marking, labeling, and documentation requirements for your product will vary depending on the hand sanitizers classification, the amount being shipped (e.g., limited quantity, non-bulk, bulk), and the mode of transport.
Due to the pandemic causing an increased demand, shipping hand sanitizer may be new for your company. A temporary US DOT PHMSA policy provides relief for ground shipments of hand sanitizer during the COVID-19 public health emergency.
PHMSA recently extended the policy through October 31, 2020.
Identifying products as regulated hazardous materials is the first step toward compliance with US DOT hazmat shipping standards. Like the combustible fuel that keeps us moving on the highway and the energy-dense lithium batteries that power our electronics, hand sanitizer is a material with properties that make it both effective and hazardous.
DOT Hazmat Training – Live on October 20—21
Hazmat Ground Shipper Certification Webinar
Get training required to ship hazmat by ground using the 49 CFR Hazardous Materials Regulations (HMR).
This new two-day webinar guides you through Lion’s 10 Steps for compliant hazmat shipments. You will learn where to find the rules you need to classify, package, mark, label, handle, and document your hazardous materials shipments for highway transport.
Ship by air and vessel too? Our Hazmat Air Shipper Certification and Hazmat Vessel Shipper Certification webinars cover the current IATA DGR and IMDG Code rules you must know.
