Skip to content

Temporary Policy for Transportation of Alcohol-Based Hand Sanitizer Products

The U.S. Pipeline and Hazardous Materials Safety Administration (PHMSA) announced  that it will be providing temporary relief to Truckers from some requirements when transporting alcohol-based hand sanitizers on highways as defined by the Hazardous Materials Regulations (HMR) under 49 CFR Parts 171-180

Alcohol-based products, such as hand sanitizers, are typically classified according to the HMR as a Class 3, Flammable Liquid. The HMR defines Flammable Liquids as a liquid having a flash point of 60 °C (140 °F) or below (see 49 CFR 173.120).

The provisions of the HMR include requirements applicable to classifying the material, selecting an appropriate packaging, and communicating the hazard through labeling, marking, placarding, and shipping papers.

Please note that the requirements that apply vary depending on the concentrations of alcohol and the quantity and form of the product.

The announcement was made in response to the significant increase in the demand for products used for sanitization purposes, of which many contain alcohol and therefore are considered a hazardous material for transportation. 

Specifically, the PHMSA is providing temporary enforcement to enable more businesses to respond to the coronavirus outbreak.  Therefore, PHMSA will not take enforcement action for violations of the HMR when the following procedures are followed:

  1. Packages contain hand sanitizer containing either ethyl alcohol or isopropyl alcohol at a concentration not to exceed 80 percent.
  1. Packagings are leak tight and securely closed, secured against shifting, and protected against damage.
  2. Material is contained in a packaging having a capacity not over 8 gallons.
  3. Inner packagings not exceeding 1 gallon:

    a. 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.

    b. Net contents of all inner packagings in any single outer packaging do not exceed 8 gallons (e.g., 8 x 1 gallon packages).

    c. 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.


  1. Packages exceeding a capacity of 1 gallon:

    a. Are overpacked in crates, cages, carts, boxes, or similar overpacks.

    b. 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.

    c. 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.


  1. Transportation of larger quantities of hand sanitizers, containing more than 8 gallons but not more than 119 gallons of sanitizer:

    a. Packaging contains hand sanitizer containing either ethyl alcohol or isopropyl alcohol at a concentration not to exceed 80 percent.

    b. Packagings is leak tight and securely closed, secured against shifting, and protected against damage.

    c. Material is be contained in a packaging having a capacity not over 119 gallons.

    d. Packaging must be DOT or United Nations (UN) specification packaging (drums, jerricans, etc.) as described in §173.202 meeting the Packing Group (PG) II performance standard.

    e. Packages are be secured to prevent breakage, leakage, and movement during the course of transportation.

    f. Registration requirements found in 49 CFR Part 107 Subpart G, will not apply.

    g. Offerers 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.

    h. Each package is labeled with a flammable liquid label (see § 172.419).

    i. Bill of lading or shipping paper includes the following basic description:
    I. ”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 each).

    j. Copy of the Emergency Response Guidebook Guide (ERG) # 127 accompanies the shipment. (See Appendix Below)
    k. 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).

    l. All motor carriers comply with §177.804.



Appendix 1 – GUIDE 127 – Flammable Liquids (Polar / Water-Miscible)


Fire or Explosion

·       Highly Flammable: Will be easily ignited by heat, sparks or flames.

·       Vapors may form explosive mixtures with air.

·       Vapors may travel to source of ignition and flash back.

·       Most vapors are heavier than air. They will spread along ground and collect in low or confined areas (sewers, basements, tanks).

·       Vapor explosion hazard indoors, outdoors or in sewers.

·       Those substances designated with a ‘P’ may polymerize explosively when heated or involved in a fire.

·       Runoff to sewer may create fire or explosion hazard.

·       Containers may explode when heated.

·       Many liquids are lighter than water.



·       Inhalation or contact with material may irritate or burn skin and eyes.

·       Fire may produce irritating, corrosive and/or toxic gases.

·       Vapors may cause dizziness or suffocation.

·       Runoff from fire control may cause pollution.


·       CALL Emergency Response Telephone Number on Shipping Paper first. If Shipping Paper not available or no answer, refer to appropriate telephone number listed on the inside back cover.

·       As an immediate precautionary measure, isolate spill or leak area for at least 50 meters (150 feet) in all directions.

·       Keep unauthorized personnel away.

·       Stay upwind.

·       Keep out of low areas.

·       Ventilate closed spaces before entering.

Protective Clothing

·       Wear positive pressure self-contained breathing apparatus (SCBA).

·       Structural firefighters’ protective clothing will only provide limited protection.




Large Spill

·       Consider initial downwind evacuation for at least 300 meters (1000 feet).


·       If tank, rail car or tank truck is involved in a fire, isolate for 800 meters (1/2 mile) in all directions; also, consider initial evacuation for 800 meters (1/2 mile) in all directions.




Caution: All these products have a very low flash point: Use of water spray when fighting fire may be inefficient.

Small Fire

·       Dry chemical, CO2, water spray or alcohol-resistant foam.

Large Fire

·       Water spray, fog or alcohol-resistant foam.

·       Use water spray or fog; do not use straight streams.

·       Move containers from fire area if you can do it without risk.

Fire involving Tanks or Car/Trailer Loads

·       Fight fire from maximum distance or use unmanned hose holders or monitor nozzles.

·       Cool containers with flooding quantities of water until well after fire is out.

·       Withdraw immediately in case of rising sound from venting safety devices or discoloration of tank.

·       Always stay away from tanks engulfed in fire.

·       For massive fire, use unmanned hose holders or monitor nozzles; if this is impossible, withdraw from area and let fire burn.

Spill or Leak

·       Eliminate all ignition sources (no smoking, flares, sparks or flames in immediate area).

•    All equipment used when handling the product must be grounded.

•    Do not touch or walk through spilled material.

•    Stop leak if you can do it without risk.

•    Prevent entry into waterways, sewers, basements or confined


•    A vapor suppressing foam may be used to reduce vapors.

•    Absorb or cover with dry earth, sand or other non-combustible

      material and transfer to containers.

•    Use clean non-sparking tools to collect absorbed material.

Large Spill

·       Dike far ahead of liquid spill for later disposal.

·       Water spray may reduce vapor; but may not prevent ignition in closed spaces.

First Aid

•    Move victim to fresh air.

•    Call 911 or emergency medical service.

•    Give artificial respiration if victim is not breathing.

•    Administer oxygen if breathing is difficult.

•    Remove and isolate contaminated clothing and shoes.

•    In case of contact with substance, immediately flush skin or eyes

           with running water for at least 20 minutes.

•    Wash skin with soap and water.

•    In case of burns, immediately cool affected skin for as long as

           possible with cold water. Do not remove clothing if adhering to


•    Keep victim warm and quiet.

•    Ensure that medical personnel are aware of the material(s)

      involved and take precautions to protect themselves.


Related Resources 

  1. Guide for Handling Household Chemicals

Things you can do to make your home safer.

  1. US DOT Hazardous Materials Table 49 CFR 172.101

An on line version of the USDOT’s listing of hazardous materials from 49CFR 172.101. This table can be sorted by proper shipping name, UN/NA ID and/or by primary hazard class/division.

  1. S. DOT Hazardous Materials Transportation Placards

Hazardous materials placards (DOT placards) are required when shipping hazardous materials in the United States, Canada and Mexico. These pages provide US DOT definitions for each hazmat placard.

  1. Chemical Database

This database focuses on the most common chemical compounds used in the home and industry.

  1. PHMSA Hazardous Materials Information Center

PHMSA’s Hazmat Information Center provides live, one-on-one assistance with the Hazardous Materials Regulations

Monday through Friday from 9 a.m. – 5 p.m.

Call: 1-800-467-4922

Email: [email protected]



Complete Innovations Inc. (hereinafter referred to as “Fleet Complete”) makes no representations or warranties about the accuracy or suitability of any information contained within the Ask the Expert blogs (the “Blogs”) or materials referenced therein (“Related Materials”) – and all such information and Related Materials is provided to Blog readers on an “as is” basis. Fleet Complete hereby disclaims all liability for any claims, losses, or damages in connection with the use, application, accuracy or suitability of any information in any Blog and Related Materials.  Fleet Complete does not recommend, guarantee, warrant, or endorse the products or services of any firm, organization, or person, or contents of the third-party site(s).  The information contained in the Blogs and Related Materials is not intended to constitute legal advice or the rendering of legal, consulting, or other professional services of any kind. Readers of the Blogs and Related Materials should not in any manner rely upon or construe the information or resource materials included therein as legal, or other professional advice and should not act or fail to act based upon the information in these Blogs and Related Materials without seeking the services of a competent legal or other professional.