Manufacturing or Shipping Hand Sanitizer or Disinfectants?

COSTHA has initiated conversations with PHSMA to provide necessary regulatory relief on sanitizing and disinfecting products that contain alcohol. Specifically, we are discussing the ability to expand the LQ provisions for 4 UN numbers (UN1170 – ethanol, UN 1219 – Isopropanol, UN1987 – Alcohols, n.o.s., UN1230 Methanol) permitting single packagings to 5 gallons. PHMSA and COSTHA are looking for additional information on the following areas:

  • Need
    • Are packagings available if relief is granted? (non-DOT specification single packaging up to 5 gallons that would be considered strong packaging*)
    • Do consignees need sanitizers/disinfectants in single packagings greater than 1 liter and up to 5 gallons (current limit for LQ for flammable liquids in PG II)?
  • Impact
    • Would such provisions improve the movement and availably of sanitizers and disinfectants to areas in need?
    • Are there any negative impacts that would result that are not outweighed by the need for the products?

*            Strong outer packaging means the outermost enclosure that provides protection against the unintentional release of its contents. It is a packaging that is sturdy, durable, and constructed so that it will retain its contents under normal conditions of transportation. In addition, a strong outer packaging must meet the general packaging requirements of subpart B of part 173 of this subchapter but need not comply with the specification packaging requirements in part 178 of the subchapter. For transport by aircraft, a strong outer packaging is subject to §173.27 of this subchapter. The terms “strong outside container” and “strong outside packaging” are synonymous with “strong outer packaging.”

Subpart B of part 173, §173.24 General requirements for packagings and packages.   

(b) Each package used for the shipment of hazardous materials under this subchapter shall be designed, constructed, maintained, filled, its contents so limited, and closed, so that under conditions normally incident to transportation—

(1) Except as otherwise provided in this subchapter, there will be no identifiable (without the use of instruments) release of hazardous materials to the environment;

(2) The effectiveness of the package will not be substantially reduced; for example, impact resistance, strength, packaging compatibility, etc. must be maintained for the minimum and maximum temperatures, changes in humidity and pressure, and shocks, loadings and vibrations, normally encountered during transportation;

(3) There will be no mixture of gases or vapors in the package which could, through any credible spontaneous increase of heat or pressure, significantly reduce the effectiveness of the packaging;

(4) There will be no hazardous material residue adhering to the outside of the package during transport.

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