A question November 17, 2020:

Hi Daniel,

I came across your site via this page: The Classification of Alcohol Wipes

Very interesting, and complex stuff, I really thought your analysis was great and very informative.

Can I ask you, how would you classify large-format buckets of alcohol wipes? I am starting a new venture to export buckets of 1000 alcohol wipes to the USA and I would be interested to have your opinion on this – in each bucket we are putting about 1500 mL of solution in to saturate the wipes, which are then heat-sealed in a bag, and then sealed in a bucket. The solution is 75% alcohol in water.

Many thanks,

My reply:

Thank you for contacting me. Please see below.

• If the alcohol wipes are not subject to the exception I refer to in my article, then they are subject to full regulation as a hazardous material (HazMat).
• What you describe would likely be classified as: UN3175, Solids containing flammable liquid, n.o.s., 4.1, PG II
• If to be imported to the U.S. it’s transportation will also likely be subject to international regulations for its transport by air and/or vessel. Under those regulations as well it will likely be a fully-regulated HazMat.

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

Conclusion:

The Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA) exist in order to ensure the safe transportation of HazMat to, from, or through the U.S. In some situations safety can be maintained even though an exception to the HMR is available, e.g., the exception for small packets of alcohol wipes. But if safety can’t be ensured, such as when large quantities of Class 3 Flammable Liquids are present, then the full regulation of the HMR must remain in place.