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Shipping hand sanitiser and complying with dangerous goods regulations


Sanitisers are classified as biocides and consequently, unlike cosmetics or pharmaceuticals, require compliance with CLP/GHS supply pictograms and rules


Not surprisingly, faced with the demands of the Covid-19 pandemic, a wide range of companies are turning to the manufacture and supply of hand sanitisers. Enquiries to Dangerous Goods Safety Advisors


(DGSA) have increased from shippers, forwarders and carriers seeking advice on the handling and transportation of ingredients and finished products. Many are unfamiliar with the transport rules or the requirements of Safety Data Sheets – some simply stating “not tested” or providing insufficient information in Section 14, where the transport description and information is required. Companies that usually supply cosmetics or pharmaceuticals may not be familiar with the Supply-GHS regulations that cover sanitisers which, strictly speaking, are classified as biocides, and consequently unlike cosmetics or pharmaceuticals require compliance with CLP/GHS supply pictograms etc.


Derogations Countries such as the USA and Canada are issuing derogations from various aspects of the regulations (including permission to use internal postal systems, unlike the UK where sanitisers remain prohibited through the postal network). At present, the EU has only drafted a partial derogation which will require additional documents to be carried by drivers. In summary, these are the requirements that


consignors or their agents will need to address when offering these products for carriage. Sanitisers will usually be based on


denatured alcohol and will be classified for transport as one of the following: i) UN1170, ethyl alcohol solution or ethanol solution containing at least 60% ethanol by volume, but not more than 80% ethanol by volume, 3,II


ii) UN1219, isopropyl alcohol or isopropanol containing at least 60% isopropanol by volume, but not more than 80% isopropanol by volume, 3,II


iii) UN1987, alcohols, NOS (ethanol*) containing at least 60% ethanol and/or


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(which probably makes it ineffective as a sanitiser).


2) SP 601 – The exemption for pharmaceutical products which applies to medicines packaged for retail sale or distribution. Sanitisers are not classified as medicines.


3) Viscous exemption, which allows viscous gel- type flammable liquids to be exempt, although this only applies when the flashpoint exceeds 23ºC (sanitisers are usually much lower).


4) The flammable liquid does not support combustion, which requires a test to be undertaken.


5) “We ship alcohol and have an exemption up to 250-litre capacity containers” (SP145), which applies to UN3065 beverages but not otherwise.


isopropanol by volume, but not more than 80% ethanol and/or isopropanol by volume;


iv)UN1993, flammable liquid NOS (isopropanol*), 3,II (*the technical name must be entered within


brackets for these NOS identifications) There are a number of exemptions from


transport regulations which some shippers may seek to use: 1) SP 144 – The alcohol content is less than 24%


Regulatory requirements So, we are left with the regulatory requirements for transport. Most sanitisers will be for domestic supply so


subject to ADR (road). Sanitisers will often be for use by individuals and be in containers that do not exceed 1-litre capacity, so qualify under (ADR/IMDG) Limited Quantity provisions. Briefly, the “bottles/containers that do not


individually exceed 1 litre” must be packed in a combination pack that is strong enough to withstand the rigours and stresses of transport, stacking and handling and not exceed 30 kg gross assembled weight of the package, display the LTD QTY diamond mark on one side and, if the inners exceed 125 ml capacity, orientation arrows on two opposite sides. (There is a shrink- wrap tray option gross assembled weight not exceeding 20 kg). If a number of packages are assembled as a


palletised load or within a unit load and the package marks are not visible, then the LQ mark/ orientation arrows must appear on the outer surface of the assembled load with the statement “Overpack” in 12 mm characters. For road (ADR) distribution, a Transport


Document /Dangerous Goods Note is not required, but the carrier must be advised that the consignment comprises dangerous goods in limited quantity and the gross weight. For seafreight/ferry (IMDG) journeys, the


packing/marking procedures are identical but a signed Dangerous Goods Note must be supplied to the haulier/carrier that must include the statement “LTD QTY” after the


June 2020


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