Shipping hand sanitizer
This temporary relief has now expired as of October 31, 2020 and includes not only highway but rail transport as well. See the official notice.
Shipping hand sanitizer never got much attention until now. As everybody on the planet knows alcohol solutions of 60% or greater are able to kill the coronavirus that causes COVID 19.
Because these products are flammable in that percentage they are regulated as hazardous materials by all modes of transport.
There has been some relief offered until the end of October 31, 2020 by the US DOT for ground shipments and you can see the temporary relief order here.
Under these temporary stop-gap DOT measures, hand sanitizers must be packed based upon one of three methods: (1) SMALL packagings – less than 1-gallon per inner receptacle and less than 8-gallons total per package; (2) NON-BULK packagings of not more than 119-gallons (such as 55 gallon drums – which must be UN approved); or (3) BULK packagings of more than 119-gallons (such as a 250-gallon tote or portable tank).
Beyond the DOT special exception period, you will need to be trained and certified to ship these products by all modes (air, highway, rail and ocean), and this includes people handling the products as well as those classifying them or filling out paperwork.
If you are hazmat trained and certified, you can continue to ship hand sanitizers via ground (highway or rail) under the limited quantity exception if the shipment meets several basic requirements: (1) use of combination packaging; (2) inner packagings of not more than 1 L each; and (3) the gross weight of the package is 30 kg or less (66 pounds). No paperwork is required for ground shipping a limited quantity shipment, and the package need only be marked with the limited quantity mark, package orientation arrows on two sides and the name & address of the shipper or consignee.
You must ship the hand sanitizers as fully regulated dangerous goods (not limited quantity), including the use of UN specification packaging and a complete shipping paper, if the package is: (1) not a combination packaging (i.e., it is a single or composite packaging); (2) the inner packagings exceed 1 L; (3) the package exceeds 30 kg gross weight.
Below are two diagrams that show the differences in the consignment procedures. The first diagram is for limited quantity and the second for fully regulated, Class 3 (flammable liquids).