DG Digest: PHMSA & Transport Canada ease transport rules on hand sanitizer

The ongoing COVID-19 crisis continues to dominate regulatory activity.  Several new actions dealing with it were promulgated during the last week and we’ll cover them below.  Labelmaster continues to serve the DG logistics chain during this time when it’s become even more important.  We’re working safe and doing everything we can to be a positive contributor to the response we all need to share in.  Meanwhile, it’s important to remember to be safe yourself, follow all the recommended guidelines, and also to try hard to continue to find pleasant and happy ways to enrich your life within the present restrictions.  All of us face additional stress, but we can do this.  The crisis will eventually pass; the virus will be defeated, and we will all be better for having faced and overcome it together.  Each dark night is followed by a new dawn, so stout hearts, all.   Here is the latest update:    

COVID-19 Specific News

PHMSA

By now most people are aware of the severe shortages of hand sanitizer at both the retail and commercial/industrial/medical levels.  As such, many companies that are not typical producers of such materials have turned their efforts towards doing so to help in the present need.  However, much of that new-to-the-product manufacturing base is unfamiliar with the usual dangerous goods regulations governing its transport that our community takes for granted.  As such and given the desperate need, PHMSA has put forth a new set of temporary rules that will offer relief to those entities that are not typical users of the DG transport chain and critically, do not have the normally required training otherwise required by the HMR.  Here are the details:

PHMSA will not take enforcement action for violations of the HMR for highway transport only when the following procedures are followed:

  1. For smaller quantities of hand sanitizer (<8 gallons/package) –Packages contain hand sanitizer containing either ethyl alcohol or isopropyl alcohol at a concentration not to exceed 80 percent.
  2. Packagings are leak tight and securely closed, secured against shifting, and protected against damage.
  3. The material is contained in a packaging having a capacity not over 8 gallons.
  4. For inner packagings not exceeding 1 gallon:
    • Packages are a combination package and the inner receptacle containing the liquid is placed inside an outer packaging where the inner packagings are secured and cushioned within the outer packaging to prevent breakage, leakage, and movement and inner packagings are packed with package closures in an upright orientation.
    • The net contents of all inner packagings in any single outer packaging do not exceed 8 gallons ( e.g., 8 x 1 gallon packages).
    • The company name and the words ”Sanitizer – Contains Ethyl Alcohol” or ”Sanitizer – Contains Isopropyl Alcohol” are marked on the outer package and, if applicable, the overpack.
  5. Packages exceeding a capacity of 1 gallon:
    • Are overpacked in crates, cages, carts, boxes, or similar overpacks.
    • Packages are secured in the transport vehicle in such a way as to prevent breakage, leakage, and movement. Packages are packed package closures in an upright orientation.
    • The company name and the words ”Sanitizer – Contains Ethyl Alcohol” or ”Sanitizer – Contains Isopropyl Alcohol” is marked on the outside of the single package and the overpack.

For larger quantities of hand sanitizer (8 to 119 gallons per package)

PHMSA will not take enforcement action for violations of the HMR for shipments of packagings by highway only containing more than 8 gallons but not more than 119 gallons of sanitizer, if the following procedures are followed:

  1. The packaging contains hand sanitizer containing either ethyl alcohol or isopropyl alcohol at a concentration not to exceed 80 percent.
  2. Packagings are leak tight and securely closed, secured against shifting, and protected against damage.
  3. The material is contained in a packaging having a capacity not over 119 gallons.
  4. The packaging must be DOT or United Nations (UN) specification packaging (drums, jerricans, etc.) described in§ 173.202 meeting the Packing Group (PG) II performance standard.
  5. The packages are be secured to prevent breakage, leakage, and movement during the course of transportation.
  6. The registration requirements found in Subpart G of Part 107 will not apply.
  7. Offerors and transporters of this material provide their employees handling this material with the applicable training materials prepared by PHMSA, in lieu of the training required by 49 CFR Part 172, Subpart H.
  8. Each package is labeled with a flammable liquid label (see § 172.419).
  9. The bill of lading or shipping paper includes the following basic description ‘‘UN 1987, Alcohols, n.o.s., Class 3, PG II” and indicate the number, type, and capacity of packages offered (for example, 25 drums – 119 gallons ea.).
  10. A copy of the Emergency Response Guidebook Guide number 127 accompanies the shipment.  (A copy of this is in the linked document for the use of shippers)
  11. If the aggregate gross quantity in a transport vehicle or freight container exceeds 1,001 pounds, the vehicle is placarded as required by the HMR (see 49 CFR Part 172, Subpart F for placarding requirements).
  12. All motor carriers comply with § 177.804.

Here is a link to the full guidance.  This will provide expanded information and links to further federal information resources as well.

Labelmaster also produced a blog article last week that covers aspects of shipping this now vital commodity.  It’s well worth reviewing also.  Here’s a link to it:

Transport Canada

Canada’s counterpart to PHMSA published relief and guidance very similar to PHMSA’s above in reference to highway only shipment of hand sanitizer this week as well.  Like PHMSA, Transport Canada offers the same critical relief from normal training requirements. Find all of the Canadian details here.

FEMA

The agency announced that it will accept donation of relevant supplies (like masks, sanitizer, etc.) from private companies via its voluntary donation program. Here is information on how to contribute.

IATA

The association has established a web page with all the latest updates regarding its actions during this global crisis.  This will include action related to dangerous goods.  Here’s the link.

The association published a guidance document for operators governing ground handling and various actions related to passengers and in-cabin cargo during the COVID-19 outbreak.  This is intended to get carriers on the same page in terms of how they treat issues related to the pandemic.  See the linked document here.

IATA also published a document outlining the current relaxation of certain recurrent training requirements related to dangerous goods certification for air.  See the document, which provides links to the actions taken by various competent authorities.

ICAO

The organization has established a clearinghouse web page devoted to operational safety measures related to the COVID-19 outbreak.  The site asks members states to contribute new information affecting air operations as they arise.  See the page here.

IMO

Much like IATA and ICAO, the IMO has also established a web page to serve as a clearinghouse for COVID-19 related activity affecting the organization and its member states.  The page features very extensive links to many member states’ own COVID-19 web resources.  See the page here.

E.U. ADR

The UNECE continues to be responsive to the COVID-19 outbreak.  In the “In Focus” section on the linked page, you can find specific information about the actions various member states have taken to address issues like recurrent training requirements, inspection and recertification of cylinders and portable tanks, and other issues that due to social distancing measures have been heavily impacted in comparison to before the pandemic.  The section provides links to the various multilateral agreements and the national actions related to them.  See the page right here.

The UNECE has also and unsurprisingly cancelled the meeting of the Subcommittee of Experts for the Transport of Dangerous Goods that had been scheduled for mid-May.  Other future meeting schedules will be addressed on a developing basis as the crisis evolves. See the notice here.

Other News

EPA

EPA is announcing the availability of and soliciting public comment on the draft Toxic Substances Control Act (TSCA) risk evaluation of asbestos. EPA is also submitting the same document to the TSCA Science Advisory Committee on Chemicals (SACC) for peer review and is announcing that there will be two virtual public meetings of the TSCA SACC, with participation by phone and webcast only, and no in-person gathering.  The first meeting is April 7thSee the link for full details.

Labelmaster is a full-service provider of products, shipping and training software, and professional consulting services to assist the DG and HS&E professional to comply with national and international regulations.  See our full line of solutions at www.labelmaster.com.

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