Shipping Hand Sanitizers – DOT Exceptions No Longer Apply
By Terry Poland, Principal Instructor and Consultant
With the US DOT ending exceptions for shipping hand sanitizers as of March 31, 2021, we immediately encourage shippers to get fully trained in the appropriate modal course (air, ocean, highway or any combination thereof) and follow the standard shipping requirements for these materials to avoid any potential violations.
Generally, hand sanitizers contain a flammable alcohol base that can be extremely dangerous when exposed to heat, sparks or open flames – especially when contained in temporary packagings used during transportation.
Prior to transport, these materials must be identified and classified by the shipper in a manner that most closely and accurately describes the nature of the hazards of the material. Below is a short list of the most common descriptions recognized by the US DOT:
- UN1170, Ethyl Alcohol Solutions
- UN1219, Isopropyl Alcohol
- UN1987, Alcohols, N.O.S.
- UN1993, Flammable Liquids, N.O.S.
Although all of these descriptions fall under Class 3, Flammable Liquids, if the flash point of the material is less than or equal to 60 C (140 F), they must be further classified into one of three Packing Groups (PG) based on the danger level present:
- PG I = Class 3 material with an initial boiling point less than or equal to 35 C (95 F)
- PG II = Class 3 material with flash point less than or equal to 23 C (73 F) and an initial boiling point greater than 35 C (95 F)
- PG III = Class 3 material with a flash point less than or equal to 60 C (140 F) and an initial boiling point greater than 35 C (95 F)
Regardless of the proper shipping name and UN number, most hand sanitizers fall under PG II or III. The PG can be easily determined by checking Section 9 (Chemical Properties) or Section 14 (Transportation) in the product Safety Data Sheet (SDS) or Material Safety Data Sheet (MSDS).
Furthermore, for UN1993, Flammable Liquid, N.O.S., the name of the primary chemical constituent(s), referred to as the “Technical Name” must be added to the proper shipping name in parenthesis when describing the material on the shipping paper and package markings. The same rule applies to UN1987 for air and ocean transport. See examples below of the “basic description” to be used on the shipping paper:
- UN1993, Flammable Liquid, N.O.S. (contains ethyl alcohol), Class 3, PG II
- UN1987, Alcohols, N.O.S. (contains isopropyl alcohol), Class 3, PG III
Properly documented and packaged shipments of hand sanitizers may be shipped by air, ocean or highway, and the shipper can use UN specification packaging or, for smaller quantities per receptacle and package, opt to ship these under the Excepted Quantity (EQ) or Limited Quantity (LTD QTY) exceptions.
TDG has courses to teach students the entire process of shipping hand sanitizers under all these regulatory requirements. See our program catalog here.