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.

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.

The question came to me on April 25, 2018:

Hi,

I found your website when researching hazmat and transportation rules for alcohol wipes and saw your article about them not being subject to Hazardous Material Regulations of PHMSA/USDOT as long as there is no loose liquid in the packet.

The question I have is with regards to the SDS for this kind of item; how would it look and what transportation and packing class would it be under?

Any help would be greatly appreciated.

Thanks,

My reply was a few days later on May 1, 2018:

I am terribly sorry for my delay.  Please see below.