The relief exemption to the existing Limited Quantity exemption, and some other DOT Hazardous Materials Regulations based on the volume of material being transported. The relief offers additional exemptions to the classification, packaging and hazard communication that would typically be required. And while these materials can be shipped either through a private or common carrier, they are only giving relief by highway; normal rail, water and air transportation regulations still are applicable. These offerors/shippers would not be required, during this relief, to register with PHMSA, but they would still be responsible for placarding offerings with an aggregate weight of over 1,001 pounds, and the transporters must adhere to standing safety requirements.
The relief is for combination packaging (inner packaging in an outer container/box) for inner containers of less than one (1) gallon and between one and eight (1 and 8) gallon(s). The primary packaging requirement for these shipments include ensuring that the containers are leak tight, securely closed and are packaged to prevent shifting and damage during transit – this may require cushioning to prevent breakage. It also requires that both the individual inner packages, as well as the outer container/box be appropriately marked with the words “sanitizer – contains ethanol” or “sanitizer – contains isopropyl alcohol”.
There are also additional training considerations for those offerors/shippers. These include ensuring that their employees have a general awareness/familiarization with the DOT HazMat Regulations (HMR), that they have function specific trainings such as the loading/unloading and storage requirements for hazardous materials, they have safety awareness around emergency response and security awareness both while the material is in transit as well as stored at the facility. This training should also include any company specific polices around hazardous materials (i.e., OSHA, RCRA).
While there are also relief provisions for larger containers of hand sanitizer being offered by the DOT (containers between 8 gallons and 119 gallons), most DOT HMR packaging, marking/labeling and shipping paper requirements still apply. Additionally, as there are businesses that may decide to continue to manufacture or package alcohol-based hand sanitizer past the relief notice period, it is important to remember that standard DOT Hazardous Materials Regulations will apply. That will require: the potential registration of the offeror/shipper with PHMSA; ensuring training requirements for all employees that have responsibilities with in the HMR to be trained, meeting packaging, marking/labeling, shipping paper, placarding; safety and potential security requirements. (https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/Hazmat_Transportation_Training_Requirements.pdf)
It is imperative that should you consider using the FDA temporary policy for the preparation of alcohol-based hand sanitizer, or take advantage of the Limited Quantity temporary relief for the highway transportation of the alcohol-based hand sanitizer, that you understand the requirement of the policies. Heritage Environmental Services offers a free, on-demand webinar that walks thru the basics of these provision. Additionally, Heritage will be moving its in-person compliance trainings for both RCRA and DOT to webinar-based platforms for the remainder of the 2020 calendar. For more information, please go to https://www.heritage-enviro.com/services/training/#schedule.