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Exceptions to the Hazardous Materials Regulations for the Transportation of Aqueous Solutions of Alcohol

Exceptions to the Hazardous Materials Regulations for the Transportation of Aqueous Solutions of Alcohol

In an earlier article I discussed the exception to the Hazardous Materials Regulations of the US DOT (HMR) available for the transportation in commerce of certain alcoholic beverages that are designed for consumption and not for industrial use.  There is also an exception to the HMR available for the transportation in commerce of aqueous solutions of alcohol that are not intended for consumption and would instead – I assume – have an industrial or commercial application.

The exception for aqueous solutions of alcohol, found at 49 CFR 173.150(e), allows for two options provided the materials is an aqueous solution containing ≤24% alcohol by volume and no other hazardous material…

  1. May be re-classed as a combustible liquid.  The Combustible Liquid Exception, if you haven’t heard of it before, provides relief from all of the HMR if certain conditions are met.  This article of mine reviews the Combustible Liquid Exception to the HMR.
  2. Is not subject to the requirements of the HMR if it contains ≥50% water.

And what does “not subject to the requirements of the HMR” mean in practice?  Well, it means none of the below is necessary for your shipment:

  • Shipping papers
  • Placards
  • Labels
  • Markings
  • Specification packaging
  • HazMat Employee training
  • Registration with the PHMSA

Like many other exceptions to the HMR, this one is allowed by the US DOT because the Agency feels the transportation of this material will not pose an unreasonable risk to human health or the environment when transported in commerce.  Those materials that it determines to pose an unreasonable risk are subject to the full regulations of the HMR.  HazMat Employee training is a good way for you to learn about the transportation of hazardous materials, exceptions to the HMR, and your responsibilities as a HazMat Employer and a shipper of hazardous materials.  Contact me for a free consultation of your training needs.