A question asked on December 09, 2020:

Hello,

I found your article The Classification of Alcohol Wipes, and was hoping you could clarify for me:

We currently have these classified as a class 4.1 packing class II. We have been requiring our driver to placard when this item is over 1000 lbs.

I think I am reading your article correctly, that since these are in sealed packages, AND there is no free liquid, it is not regulated by the DOT. Is that correct? If so, there may be very little free liquid in the package, would that change it?

One more thing, does the size of the sealed roll change anything?

I greatly appreciate your help on this.

Thanks,

My reply the same day:

Thank you for contacting me. Please see below.

• If your product is classified as UN 3175, Solids containing flammable liquid, n.o.s., 4.1, II and meets the conditions of the special provision 47 it is not subject to USDOT regulations for its transportation within the U.S. No placards or any other hazard communication required.
• Special provision 47 requires:
  • Small inner packagings consisting of sealed packets and articles.
  • Sealed packets or articles contain less than 10 mL of a Class 3 Flammable Liquid, e.g., ethanol, isopropanol, in Packing Group II or III.
  • Class 3 Flammable Liquid is absorbed onto a solid material (i.e., the wipe).
  • No free liquid in the packet.
• Free liquid in the packet – even “very little” – does not meet the conditions of the special provision which requires: “…no free liquid”
• The special provision does not limit the size of the inner packaging, only the amount of liquid it contains (10 mL).

I hope this helps. Please contact me with any other questions.

Conclusion:

A good example where a shipper of a hazardous material is complying with the USDOT/PHMSA Hazardous Materials Regulations (HMR), but is doing more than is required. Compliance is necessary, but if an exception to full regulation is available – as is the case here – then the shipper may be able to save significant amounts of money by taking advantage of that exception. Don’t miss out on the exceptions to the HMR available to you! Contact me with questions.