ethanol

Q&A: What are the restrictions for transporting ethanol (>70%) from Europe to West Africa?

Q&A: What are the restrictions for transporting ethanol (>70%) from Europe to West Africa?

I get questions from all over the world. Like this one on October 19, 2020:

Hi Daniel,

I am trying to make sense of all the regulations regarding shipping dangerous goods for my PhD study and ended up on your website.
Would you perhaps be able to clarify some things for me?

Not sure if this is a problem if you specialize more in US regulations: I am looking for West/Central Africa to Europe exchanges! I am just going to start with what I hope to be a simple question: what are the restrictions for transporting ethanol (>70%) from Europe to West Africa, in terms of volume, packaging and paperwork?

I got really confused with technical details when reading up on things, so your help will be much appreciated!

Kind regards,

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

International and Domestic

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/
My reply the same day:

I can assist you. Please advise on the following:

  • Will transportation be by air or vessel?
  • If by air, what is the air carrier?
  • What is the volume of ethanol you intend to ship? Per inner packaging? Per outer packaging?

I look forward to assisting you.

More information was quickly provided:

Dear Daniel,

Thank you very much for your swift reply.

So, on the way there, right now it looks like I will have to take 5 to 6 bottles of 1L “with me” when travelling by plane to West Africa. Is that allowed, what arrangements should be made?

On the way back, it gets a bit more complicated:

  • we are looking at perhaps 5 to 10 samples of lion tissue in 50mL tubes (so ethanol < 500ml) per box
  • but with many more (~100) faecal samples in same tubes but with silica beads (I’m specifying this as I believe this will impact your answer)

Many thanks for your time,

Contact me the next time your USDOT, IATA (air), or IMO (vessel) training is due to expire.
My reply later that day:

Please see below.

  • That quantity of dangerous good you indicate: 5-6 x 1L of Ethanol, cannot be transported by air as a passenger’s checked or carry-on baggage per 2.3 of the International Air Transport Association Dangerous Goods Regulations (IATA DGR). It must be shipped as a fully-regulated dangerous good.
  • You must contact a commercial air carrier (UPS, FedEx, other) to arrange for its transport by air as a dangerous good.
  • The samples coming back may be easier as they may be transported as passenger baggage without air carrier approval if it can meet the requirements of 2.3.5.12 of the IATA DGR:
    • Non-infectious specimens.
    • Wrapped in paper or cloth and then heat-sealed bag w/ no more than 30 mL of free liquid or vials or rigid container in heat-sealed bag of no more than 30 mL free liquids.
    • Placed in another plastic bag with absorbent.
    • Finished bag placed in strong outer packagings with suitable cushioning.
    • No more than 1 L of ethanol in completed packaging.
    • Package marked: “scientific research specimens, not restricted”

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

The next day, October 20, 2020 (maybe it was the same day in Europe, I don’t know.):

Dear Daniel,

Thank you very much for all the info, this is very helpful!

Plastic sandwich bags on store shelf

Not a heat sealed bag

  • Any chance zip-lock bags can be accepted instead of heat-sealed ones? I think I know your answer but I have to ask just in case.
  • You also say no more than 1L of ethanol in completed packaging. Does this also mean that just a 1L bottle ethanol, maybe in particular packaging, in passenger baggage is fine? Just checking where the limits are.

Many thanks for your time and help,

My reply:

Please see below.

  • The regulations require a heat-sealed bag (and more) for the samples as baggage.
  • The limit of no more than 1 L of ethanol (or other flammable liquid used as preservative) is just for the samples as baggage. It requires the inner packagings within the completed package to contain no more than 30 mL of ethanol as free liquid. You may not transport a 1 L bottle of ethanol as baggage on an aircraft, no matter the packaging.
  • The 1 L bottles you intend to bring to Africa must be packaged and shipped as a dangerous good with a commercial air carrier.
  • Depending on its Packing Group it may be eligible for the limited quantity exception which will make transportation by air somewhat easier and perhaps less expensive.
    • Packing Group II may be transported as a limited quantity pursuant to packing instructions Y341.
    • Packing Group III may be transported as a limited quantity pursuant to packing instructions Y344.

Please note, my email was only a brief summary of the complete regulations. You must research and comply with the complete regulations.

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

That seemed to make things crystal clear (10.21.20):

Dear Daniel,

Thank you very much, crystal clear. This has been incredibly helpful!

Have a nice day,

Like this article?

Subscribe to my Monthly Newsletter

No marketing emails!
That should help international relations!

It’s important to remember that the transportation of hazardous materials (aka: dangerous goods) takes place all around the world. Transportation by air will likely be subject to the Dangerous Goods Regulations of the International Air Transport Association (IATA). IATA has a biennial training requirement for shippers and packers of dangerous goods.

Identification Number Recommendations for Ethanol from the Renewable Fuels Association

Identification Number Recommendations for Ethanol from the Renewable Fuels Association

A challenge for those involved in the transportation of bulk quantities of ethanol and ethanol products is the display of the correct identification number as a package mark on the bulk packaging.  The challenge is primarily due to the number of different shipping descriptions available for ethanol products depending on the concentration of ethanol in the blend.  Another factor is the difference in classification between PHMSA/USDOT and Transport Canada for the same ethanol blend.

The Renewable Fuels Association (RFA) stepped in to provide the industry with guidance for determining the proper shipping name and the identification number (usually displayed on the placard) for various concentrations of ethanol and ethanol products.  Below is a table of information provide by RFA.

Ethanol Volume % Content in Blend
(Exx)		Proper Shipping NameIdentification Number
E100
(undenatured)		Ethanol or Ethyl alcohol or Ethanol solutions or Ethyl alcohol solutionsUN1170Cargo tank truck of ethanol UN1170
E95 - E98
(ASTM D4806 denatured fuel ethanol)		Alcohols, n.o.s.UN1987Class 3 Placard 1987
E95 - E98
(Canadian transport)		Denatured alcoholNA1987Class 3 Placard 1987
E11 - E83
(ethanol fuel blends)		Ethanol and gasoline mixture or Ethanol and motor spirit mixture or Ethanol and petrol mixture, with more than 10% ethanolUN3475Class 3 placard UN3475
E1- E10
(retail fuels)		GasolineUN1203Placard and ID Number for Gasoline

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

International and Domestic

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

Ethanol Fast Facts

Economic Impact:
  • In 2014, the ethanol industry created and supported nearly 400,000 jobs.  Moving to E15 would create an additional 136,000 jobs.
  • A recent Louisiana State University study found ethanol reduces gas prices 78 cents a gallon. A consumer savings of more than 100 billion dollars annually.
  • In 2014, the ethanol industry contributed nearly 53 billion dollars to the nation’s GDP and added nearly 27 billion dollars to household income.
  • By creating a steady market for corn and other grains, ethanol helps to reduce federal farm program costs.
Environmental impact:
  • In 2014, the production and domestic use of more than 13 billion gallons of ethanol in the U.S. reduced greenhouse gas emissions by 38 million metric tons, the equivalent of removing roughly 8 million automobiles from the road.
  • Grain ethanol decreases greenhouse gas emissions by up to 57 percent compared to gasoline.
  • Cellulosic  ethanol is expected to reduce greenhouse gas emissions by 100 percent or more. Furthermore, the U.S. is home to more than 1 billion tons of available biomass that can be converted to 80-100 billion gallons of ethanol. This is a 50-state solution.
  • New technologies are improving efficiencies and allowing ethanol biorefineries to make better use of natural resources like water.
  • A recent USDA report shows ethanol is more energy efficient to produce than conventional gasoline. Every Btu put into creating ethanol yields a 2.3  Btu return.
Energy Security:
  • Every gallon of clean-burning ethanol that we produce in this country decreases the demand for foreign oil and keeps our money here at home where it can create American jobs.
  • The production of more than 14.3 billion gallons of ethanol in 2014 displaced the need for 515 million barrels of oil.
  • When the RFS when enacted in 2005, America imported 60 percent of its fuel. Today, we import 27 percent.  Switching to domestic energy sources has helped reduce our dependence on foreign oil, strengthening our national security and our economy.
  • We spend more than 300 billion dollars a year – nearly 1000 dollars for every man, woman and child in this country – on foreign oil.
Food and Fuel:
  • A 2003 World Bank study outlines how crude oil prices are responsible for at least 50 percent of the increase in food prices in 2004.
  • The real costs of putting food on the shelf are transportation, processing and packaging – all costs driven by oil.
  • The U.S. ethanol industry uses less than 3 percent of the global grain supply on a net basis.
  • Nearly one-third of every bushel of corn used in ethanol production is returned to the food chain in the form of distiller’s grains, a competitively-priced, nutritious animal feed.
  •  Since only the starch is used and distiller’s grains displace both corn and soybean meal, in reality only 17.5 percent of the net corn acres are used for renewable fuels.

Information provided by: Growth Energy America’s Ethanol Supporters

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

Q&A: Stool Samples in Ethanol

Most of the questions I receive come from industry.  A few from government.  And a few like this one on July 28, 2016:

Hi Daniel,

I am working on a small study and we will be collecting stool samples from subjects. Subjects will receive directly at their home  the  kit which includes  a small tube pre-filled with 5mL of ethanol. They will be asked to add sample to the pre-filled tube, put it back in the kit and send it via courier to our lab facility.
Researchers  sending the kit to subjects have all training for shipping hazardous materials and shipping materials meet the IATA and DOT regulation.
The question I have is regarding  patient shipping the kit back to the lab. What regulation applies to this part?

My initial reply later that day:

I will research that and get you an answer soon.

And here is my answer a long time later on October 8, 2016 (I’ve been working on my response times!):

I apologize for my delay in responding.  Hopefully my answer can still be of some use to you.  Please see below.

  • The samples may not be subject to regulation as a Division 6.2 Infectious Substance if they meet the criteria of 49 CFR 173.134(b)(11):

 (11) A human or animal sample (including, but not limited to, secreta, excreta, blood and its components, tissue and tissue fluids, and body parts) being transported for routine testing not related to the diagnosis of an infectious disease, such as for drug/alcohol testing, cholesterol testing, blood glucose level testing, prostate specific antibody testing, testing to monitor kidney or liver function, or pregnancy testing, or for tests for diagnosis of non-infectious diseases, such as cancer biopsies, and for which there is a low probability the sample is infectious.

  • The ethanol may be subject to the Excepted Quantity exception due to its volume.  If shipped as an Excepted Quantity, only a few of the DOT Hazardous Material Regulations apply (see 49 CFR 173.4a).
  • If shipped as a fully regulated hazardous material, then the shipment returned to you by the patient is subject to regulations since it is being done for a business and is therefore “in commerce”.
  • However, DOT regulations (more research will be required but I think IATA regulates it the same way) allow for more than one shipper for a HazMat.  Each shipper is responsible for the aspect of offering a HazMat for transportation that it performs.  In other words, the patient/customer is subject to the regulations for what they do and you are subject for what you do.  In that case, it is best for you to do as much as possible for the customer, e.g. shipping papers, packaging, labels, markings, directions to complete, &etc.  You then, are responsible for these aspects.  The customer is left only to package the HazMat and make final preparation for shipment.  This should be done only according to directions you provide.

In sum, I suggest you determine if what you intend to ship is excepted from regulation.  If so, its transportation should be easy.  If subject to full regulation, then provide as much information and resources as possible in order to make its return to you simple.

I hope this helps.
Please don’t hesitate to contact me with any other questions.
And that must have done it because they didn’t contact me with any other questions.
Whatever it is you need to offer for transportation and no matter how you wish to have it transported, the Hazardous Material Regulations of the PHMSA/USDOT have an option for you.  Perhaps you will have to ship it fully-regulated.  Perhaps an exception is available.  What’s important is that you research the HMR to ensure you are offering your HazMat for transportation in compliance with all regulations.

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

International and Domestic

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

Contact me to help you with this research!

Fast Facts About Ethanol and the Hazardous Material Regulations of the PHMSA

Some interesting facts about the Ethanol industry from a brochure distributed by Growth Energy

Economic Impact:
  • In 2013, the ethanol industry created and supported nearly 400,000 jobs.  Moving to E15 would create an additional 136,000 jobs.
  • A recent Louisiana State University study found ethanol reduces gas prices $.78/gallon – a consumer savings of more than $100 billion annually.
  • In 2013, the ethanol industry contributed $44 Billion to the nation’s GDP and added $31 billion to household income.
  • By creating a steady market for corn and other grains, ethanol helps to reduce federal farm program costs.
Environmental Impact:
  • In 2013, the production and use of more than 13 billion gallons of ethanol in the U.S. reduced greenhouse gas emissions by 38 million metric tons, the equivalent of removing roughly 8 million automobiles from the road.
  • Grain ethanol decreases greenhouse gas emissions by up to 57% compared to gasoline.
  • Cellulosic ethanol is expected to reduce greenhouse gas emissions by 100% or more.  Furthermore, the U.S. is home to more than one billion tons of available biomass that can be converted to 80-100 billion gallons of ethanol.  This is a 50-state solution.
  • New technologies are improving efficiencies and allowing ethanol biorefineries to make better use of natural resources like water.
  • A recent USDA report shows ethanol is more energy efficient to produce than conventional gasoline.  Every Btu put into creating ethanol is a 2.3 Btu return.
Energy Security:
  • Every gallon of clean-burning ethanol that we produce in this country decreases the demand for foreign oil and keeps our money here at home where it can create American jobs.
  • The production of more than 13 billion gallons of ethanol in 2013 displaced the need for 476 million barrels of oil.
  • When the RFS was enacted in 2005, America imported 60% of its fuel.  Today, we import 33%.  Switching to domestic energy sources has helped reduce our dependence, strengthening our national security and our economy.
    RFS The Renewable Fuel Standard (RFS) is a USA federal program that requires transportation fuel sold in the U.S. to contain a minimum volume of renewable fuels. The RFS originated with the Energy Policy Act of 2005 and was expanded and extended by the Energy Independence and Security Act of 2007 (EISA).

    Renewable Fuel Standard – Wikipedia, the free encyclopedia

    en.wikipedia.org/wiki/Renewable_Fuel_Standard

    Wikipedia
  • We spend more than $300 billion a year – nearly $1,000 for every man, woman, and child in this country – on foreign oil.
Food and Fuel:
  • A 2013 World Bank study outlines how crude oil prices are responsible for 50% of the increase in food prices since 2004.
  • The real costs of putting food on the shelf are transportation, processing, and packaging – all costs driven by oil.
  • The U.S. ethanol industry uses less than 3% of the global grain supply on a net basis.
  • One-third of every bushel of corn used in ethanol production is returned to the food chain in the form of competitively-priced, nutritious animal feed – referred to as distiller’s grains.
  • Since only the starch is used and distiller’s grains displace both corn and soybean meal, in reality only 17.5% of the net corn acres are used for renewable fuels.  Academic, government, and third party research papers single out rampant Wall Street speculators, high oil prices, and the high costs of manufacturing, packaging and transporting groceries as the major drivers of increasing commodity prices and grocery store bills.

What does this have to do with the transportation of hazardous materials?  Lots. The ethanol industry is widely distributed throughout the U.S. – with the largest concentration in the Midwest – and promises to become more so as cellulosic ethanol production creates more potential feed-stocks for the the production of fuel-grade ethanol.  All that production in the Midwest with the demand predominantly on the coasts means that a lot of hazardous materials:  Ethanol and Ethanol and fuel mixtures; must be transported from their supply to the demand. Ethanol in HMTWhether it’s by highway in a cargo tank motor vehicle, by rail in a tank car, or by vessel in a portable tank, the transportation in commerce of a hazardous material like ethanol requires compliance with the regulations of the Pipeline and Hazardous Materials Safety Administration (PHMSA). I’ve already had an opportunity to provide HazMat Employee training for the personnel of a few ethanol plants, and biodiesel plants as well.  Contact me to provide HazMat Employee training for your employees involved in the transportation of hazardous materials.

 

 

 

 

 

 

 

 

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

International and Domestic

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

 

Growth EnergyAmerica’s Ethanol Supporters777 North Capitol StreetSuite 805

Washington, D.C. 20002

202.545.4000

GrowthEnergy.org

EthanolRetailer.com

AmericanEthanolRacing.com

New Rules in the Works to Improve the Safety of Bulk Rail Transportation of Ethanol and Bakken Crude Oil

On July 23, 204 the US Department of Transportation announced two new rulemaking proposals – and a Report – issued by the PHMSA (the Pipeline and Hazardous Materials Safety Administration, one of many administrations/bureaus within the USDOT).  It is meant to improve the safe transportation of large quantities of flammable materials by rail – particularly crude oil and ethanol.  The comprehensive rulemaking includes the following:

Bakken Crude Oil by Rail

Railroad Tank Cars of Bakken Crude Oil passing through Illinois

Each of the above components of this announcement are summarized below.

Notice of Proposed Rulemaking (NPRM):

Under the NPRM, the PHMSA seeks comment on the following proposals:

  • A definition of a “high-hazard flammable train” (HHFT) as a train carrying 20 or more tank carloads of flammable liquids.  This would include both ethanol and crude oil (Bakken and others).
  • Develop and implement a written sampling and testing program – certified by the Shipper of the HazMat – for all mined gases and liquids.  This would include Bakken crude oil, but not ethanol.
  •  Carriers must perform a routing analysis for HHFTs (both Bakken crude and ethanol) that would consider twenty-seven (27!) safety and security factors and then select a route for the rail cargo based on the analysis.
  • Codify the May 2014 Emergency Order requiring the Carriers of more than one million gallons of Bakken crude by rail to notify appropriate State Emergency Response Commissions (SERCs).
  • Speed restrictions for HHFTs (both Bakken crude and ethanol) that contain any tank cars not meeting the enhanced tank car standards proposed by this rule.
  • Require enhanced brake systems for all HHFTs (both Bakken crude and ethanol).
  • Require enhanced standards for both new and existing rail tank cars used to transport flammable liquids (both Bakken crude and ethanol) as part of a HHFT.

    Hurry!  All comments must be received by September 30th.
Advanced Notice of Proposed Rulemaking (ANPRM):

Published concurrently with the NPRM, the ANPRM seeks to gain information via comments from interested parties regarding expanding oil spill response planning requirements for shipments of flammable liquids (Bakken crude, ethanol, and more) by rail.

Hurry!  All comments must be received by September 30th.
The Report:
Rail transportation of Bakken crude oil

Bakken Crude Oil Transported by Rail

Data collected from Operation Classification – a joint PHMSA and Federal Railroad Administration (FRA) effort initiated early in 2014 and specific to Bakken  crude oil – has been summarized in a report issued along with the NPRM and ANPRM.  The findings of the report indicate that Bakken crude oil is more flammable and volatile than other crude oils.  The unexpectedly higher flammability and volatility of Bakken crude is believed to the cause of its initial misclassification; the use of improper packaging; and the resulting train derailments, fires, explosions, and deaths.  In addition to the Report, Operation Classification resulted in a more robust test method for analyzing Bakken crude.  This will likely form the basis for the written sampling and testing program referenced in the NPRM.

Anyone involved in the transportation by rail of flammable liquids – and particularly the transportation by rail of Bakken crude and/or ethanol – should carefully follow, and become involved in, these notices as they proceed through the rulemaking process.

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

I can provide the training your employees need to properly classify, package, and ship any hazardous material by any means (air, rail, highway, or vessel).  Contact me for a free training consultation.