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Air Shipment of Samples with Ethanol

Air Shipment of Samples with Ethanol

Not every question I receive comes from an industrial facility embedded on the outskirts of some major city or from a busy transportation hub in the nation’s heartland.  Some, like this one on March 14th, 2015, come from exotic locations I can only hope to visit some day.

Hi Daniel,

I am currently on a research cruise and accumulated a large amount of samples preserved in 95% ethanol. By the end of the cruise I will have around 20 samples of 250 ml of ethanol for a total of 5L. The samples need to be shipped in dry ice (preferably by air) from San Diego to Hawaii. I was wondering if you knew of a way to do this. It clearly exceeds the excepted and limited quantity, and I don’t have access to a trained haz-mat officer at port.
Thank you in advance for your help.
You can tell I was impressed (3.14.15):
Wow!  What an interesting question.  I happen to be in the office today (it’s Saturday morning here in Illinois) so I will do my best to shoot you an answer later today.
Here’s what I sent to him later that day.  (Yeah, I work Saturdays.):
First of all, I made the determination based on the available information that the ethanol is a Class 3, Packing Group II.  Also, I assume you intend to ship this per the IATA Dangerous Goods Regulations even though the transportation you describe could be subject solely to PHMSA/USDOT regulations if you could find an air carrier that does not require compliance with the IATA DGR.
Note from Dan:  The domestic transportation of a hazardous material is always subject to the Hazardous Material Regulations of the the PHMSA/USDOT.  A domestic shipper of HazMat by air will likely also have to comply with the Dangerous Goods Regulations of IATA; this depends on your air carrier since most - but not all - require compliance with the IATA DGR.  The international transportation of a HazMat (called dangerous goods) by air must comply with the IATA DGR.  The direct transportation of a HazMat from San Diego, CA to Hawaii is not international transportation and therefore is only required to comply with the HMR unless the carrier requires compliance with the IATA DGR as well.  Got it?
Based on that assumption and the information you provided, I agree with you that the total quantity of 5 L exceeds the limits for shipping Ethanol, PG II as a Limited Quantity (max net quantity of 1 L) and as an Excepted Quantity (max inner packaging of 30 g/30 ml and max outer packaging of 500 g/500 ml) and therefore may not take advantage of those exceptions.  It is within the quantity limits for shipment as fully regulated dangerous good on a passenger aircraft and, of course, on cargo aircraft.
Special Provision A180 (Column M of the List of Dangerous Goods) reads as follows:

A180 Non-infectious specimens, such as specimens of mammals, birds, amphibians, reptiles, fish, insects and other invertebrates containing small quantities of UN 1170, UN 1198, UN 1987, or UN 1219 are not subject to these Regulations provided the following packing and marking requirements are met:

(a) specimens are:

1. wrapped in paper towel and/or cheesecloth moistened with alcohol or an alcohol solution and then placed in a plastic bag that is heat-sealed. Any free liquid in the bag must not exceed 30 mL; or

2. placed in vials or other rigid containers with no more than 30 mL of alcohol or an alcohol solution;

(b) the prepared specimens are then placed in a plastic bag that is then heat–sealed;

(c) the bagged specimens are then placed inside a another plastic bag with absorbent material then heat sealed;

(d) the finished bag is then placed in a strong outer packaging with suitable cushioning material;

(e) the total quantity of flammable liquid per outer packaging must not exceed 1 L; and

(f) the completed package is marked “scientific research specimens, not restricted Special Provision A180 applies”.

The words “not restricted” and the special provision number A180 must be included in the description of the substance on the Air Waybill as required by 8.2.6, when an Air Waybill is issued.

Note here that the total quantity of flammable liquid per outer packaging cannot exceed 1 L which is less than your proposed total quantity of 5 L and the max allowed quantity of ethanol inside the package is 30 mL which also exceeds your 250 mL/vial.
It appears that you will be required to ship the samples as a dangerous good subject to full regulation under the IATA DGR unless you can reduce the size of both the inner and outer packaging.
Also, must follow packing instruction 954 for the Dry Ice.
I wish I had better news for you.  If you could just collect smaller samples, they might not be subject to the regulations and then the dry ice would not be either.
As for shipping it as a dangerous good, that should not be too difficult.  Contact Fed Ex or UPS.
Please don’t hesitate to contact me with any other questions.
He fired back on March 16th:
Hi Daniel, I apologize for the ongoing requests for advice.So would it help if I don’t use dry ice AND reduce the sample volume
from 250ml of ethanol per bottle to 30ml of ethanol per vial?How would I have to pack this then? Can I place 30 vials with 30ml
ethanol in a bag with absorbent material, then place the bag into a
box, and then place that box into another box that is aligned with
absorbent material and a plastic bag?

Thank you for your help.

A quick reply the same day:
If you are able to reduce the volume of ethanol in each vial to 30 ml and you don’t use dry ice, then I believe your best option is to meet the packaging requirements of Special Provision A180 (read them carefully, what you propose is not quite what the regulations require).  If you are able to do this, then your consignment is not subject to the Dangerous Goods regulations of IATA.

A problem I just discovered is that – based on a quick review of the regulations – USDOT does not recognize the same Special Provision for UN1170 as IATA.  It appears that even at 30 ml/vial you would need to ship it as a Limited Quantity which provides some relief from the HazMat regulations, but not as much as SP 180 offers.  If you are shipping to, from, or w/i the U.S. you must comply with USDOT regulations.
I don’t mind the questions, keep them coming.
Whatever you decide, please keep me in mind the next time you need HazMat/IATA/IMO training.
Some more information was needed (3.17.15):
Hi Daniel,

thank you for the detailed answer. I really appreciate it.
Ok, so what are the packing regulations for Limited Quantity (30mL vials for up to 1L)? I hate to ask these trivial things, but the internet in the middle of the Pacific is not the greatest and hence it is quite hard to google these things.
This cruise is called ABYSSLINE cruise and its onboard the R/V Thomas Thompson. We have 3 different cruise blogs:
You can also follow all the activities under the twitter hashtag #AB02
We are currently at 12deg 01.642′ N , 117deg 19.513′ W.
Thanks for the help.
My reply that same day:
Packaging requirements for a Limited Quantity of ethanol can be found at 49 CFR 173.150 and are fairly simple:

  • Non-bulk packaging (i.e. <119 gallons).
  • Combination packaging (i.e. inner packaging and outer packaging).
  • “strong outer packaging”
  • Limits on volume of inner packaging based on packing group of HazMat.
  • Shipment by air has additional general packing requirements.
  • Shipment by air requires labels and markings in addition to Limited Quantity marking.

However, you will likely also have to comply with requirements of IATA Dangerous Goods Regulations (depending on the requirements of your air carrier).  I have access to those regulations but cannot print and send them as I can the USDOT.  IATA regulations are similar to USDOT but may have more restrictions and may also have Carrier variations not included in USDOT.

I am sharing this email with someone (Ron Harvey of Echelon Environmental) who may be able to help you out with the actual shipment of this HazMat.
Thanks for the information about your cruise.
And that’s where my involvement ended.  My inquisitor contacted Ron who assisted him through the final steps of packaging and shipping the hazardous material/dangerous good.

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

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Please don’t hesitate to contact me with your questions about the transportation of dangerous goods/hazardous materials.