Sanitisers are classified as biocides and consequently, unlike cosmetics or pharmaceuticals, require compliance with CLP/GHS supply pictograms and rules.
Not surprisingly, faced with the demands of the Covid-19 pandemic, a wide range of companies are turning to the manufacture and supply of hand sanitisers.
Enquiries to ADR Express have increased seeking advice on the handling and transportation of ingredients and finished products. Many are unfamiliar with the transport rules or the requirements of Safety Data Sheets – some simply stating “not tested” or providing insufficient information in Section 14, where the transport description and information is required. Companies that usually supply cosmetics or pharmaceuticals may not be familiar with the Supply-GHS Regulations that cover sanitisers, which, strictly speaking, are classified as biocides, and consequently unlike cosmetics or pharmaceuticals require compliance with CLP/GHS supply pictograms etc.
Sanitisers will usually be based on denatured alcohol and will be classified for transport as one of the following:
i) UN1170, ethyl alcohol solution or ethanol solution containing at least 60% ethanol by volume, but not more than 80% ethanol by volume, Class 3 PG II;
ii) UN1219, isopropyl alcohol or isopropanol containing at least 60% isopropanol by volume, but not more than 80% isopropanol by volume, Class 3 PG II;
iii) UN1987, alcohols, NOS( containing at least 60% ethanol and/or isopropanol by volume, but not more than 80% ethanol and/or isopropanol by volume, Class 3 PG II;
iv) UN1993, flammable liquid, NOS Class 3 PG II
There are a number of exemptions from the transport regulations that some shippers may seek to use:
1) SP144 – the alcohol content is less than 24%
2) SP601 – the exemption for pharmaceutical products which applies to medicines packages for retail sale or distribution. Sanitisers are not classified as medicines.
3) Viscous exemption, which allows viscous gel-type flammable liquids to be exempt, although this only applies when the flashpoint exceeds 23 degrees C (sanitisers are usually much lower).
4) The flammable liquid does not support combustion, which requires a test to be undertaken.
5) “We ship alcohol and have an exemption up to 250-litre capacity containers” (SP145) which applies to UN3065 beverages but not otherwise.
Most sanitisers will be for domestic supply so subject to ADR (road). Sanitisers will often be for use by individuals and be in containers that do not exceed 1-litre capacity, so qualify under (ADR/IMDG) Limited Quantity provisions.
Therefore, the bottles/containers that do not individually exceed 1 litre must be packed into a combination package strong enough to withstand the rigours and stresses of transport and do not exceed 30 kgs gross assembled weight of the package, display the Limited Quantity mark on the side, and if, the inners exceed 125ml capacity, affix orientation arrows on two opposite sides. (For a shrinkwrapped tray, the gross assembled weight shall not exceed 20kgs).
If a number of packages are assembled as a palletised load or within a unit load and the package marks are not visible, then the LQ mark/orientation arrows must appear on the outer surface of the assembled load with the statement “OVERPACK” in 12 mm characters.
For road (ADR) distribution, a transport document/dangerous goods note is not required, but the carrier MUST be advised that the consignment comprises of dangerous goods in limited quantity and the gross weight.
For seafreight/ferry (IMDG) journeys, the packing/marking procedures are identical but a signed dangerous goods note must be supplied to the haulier/carrier that must include the statement “LTD QTY” after the basic dangerous goods description.
Containers/receptacles that exceed 1-litre capacity are fully regulated dangerous goods and the packages must comply with the ADR/IMDG packing requirements. Either the product containers will be certified, such as Plastic Jerrican, or they will be packed as “combination” packs inside, for example, a fibreboard box. The LQ mark is now replaced with the hazard Class 3 red diamond label and the package will be marked with the respective UN number (ADR) and the UN number and Proper Shipping Name by sea (IMDG). If packages are assembled as an OVERPACK, the same reproduction of marks and labels as with limited quantities applies. When supplied in IBC’s, the respective IBC packing instructions and additional marks and label shall be applied.
Documentation such as a dangerous goods note must be supplied to the carrier as loads over 333 litres (Transport Category 2) will be subject to full ADR/segregation when sent by ferry and quantity restrictions when sent through Eurotunnel (250 Litres per transport unit).
Companies that pack, (un)load, transport and due to changes in ADR 2019, “consign” dangerous goods by road that exceed the load threshold of ADR 184.108.40.206, must appoint a DGSA who should be advising on procedures to ensure compliance with the transport regulations.
ADR Express has its own in-house DGSA to support its transport services. Should you require further guidance, please contact Beccy directly on 07973442354.