DOT Issues Notice Facilitating Hand Sanitizers for Carrier Staff

As we struggle through the new world of quarantine and working from home, the US Department of Transportation (DOT) recognizes that many workers can’t do that in our transportation system. Obviously, truck drivers and other carrier personnel can’t work from home. But they’re entitled to the safest possible working conditions.

The DOT has taken a number of steps to assist during the pandemic. For example, they’ve developed a new system for shipping non-bulk packages of hand sanitizer with reduced requirements. Smaller packages (not exceeding 8 gallons) will not be required to be in UN specification packaging, and hazard communication requirements are significantly reduced. But a new Notice from the Pipelines and Hazardous Materials Administration (PHMSA) has taken a step further in a novel way to the access of carrier staff who don’t actually drive but may handle contaminated packages, to hand sanitizers and disinfectants. This plan uses the Materials of Trade exemption in 49 CFR section 173.6.

Of course, the previous notice allowed carriers to transport hand sanitizers with fewer requirements to their customers. But carriers are in a unique situation. As an essential business, they must handle packages from the public and industry which may carry the virus. It’s believed that the novel coronavirus can live for up to 24 hours on cardboard surfaces, and longer on non-porous ones such as metal. Clearly, safety of these workers requires access to hand sanitizers and disinfectants, and plenty of them. This has led PHMSA to create their newest notice, which makes it easier for carriers to transport sanitizers and disinfectants for their own staff.

The notice sounds in many ways like the standard provisions that already exist for Materials of Trade in section 173.6. The provisions apply to road shipment only, and the substances (mostly Class 3 for sanitizers and Class 8 for disinfectants) must meet thee hazard class, quantity, packaging, hazard communication, and aggregate gross weight requirements specified in that section. However, instead of being intended for use by the driver only, materials under this notice can also be used by “employees who directly support the operations of the carrier, such as by sorting packages, loading and unloading packages, and driving delivery vehicles.” It’s a subtle distinction, but it recognizes that the overall term “carrier” can extend to many more workers than the drivers themselves, and they all need to be protected.

The Notice is valid for 90 days (unless the emergency is deemed to end before then) and can be found in full at https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2020-04/Carrier%20MOTS%20Relief%20Notice.pdf

Did you know ICC the Compliance Center is an “essential business”? We remain open to provided needed support to the transport industry. You can order any supplies on our website, or call us here at 888-442-9628 (U.S.) or 888-977-4834 (Canada). We can take your order and ship it to you safely and quickly. And of course, our regulatory staff is still on the job, ready to assist with any questions you may have about transportation or labelling requirements.

We have all the products you need to ensure you’re safely transporting dangerous goods.
Shipping Hazardous Materials by Ground (US) and Air, Online Training
Shipping Dangerous Goods by Air using IATA Regulations, Online Training
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Barbara Foster

Barbara Foster

Barbara Foster graduated from Dalhousie University with a Master’s degree in Chemistry and a Bachelor’s degree in Education. As one of ICC Compliance Center’s most senior employees, she has worked in the Toronto office for the past three decades as a Regulatory Affairs Specialist and Trainer. She is fluent in various US, Canadian, and international regulations involving transportation, including TDG, 49 CFR, ICAO, IMDG, and the ADR/RID. She also specializes in the hazard communication standards of OSHA, WHMIS, CCCR, and the Globally Harmonized System for Classification and Labelling (GHS). Barbara is the author of ICC’s TDG Clear Language Driver and Handler’s Guide. Currently, she is a participant on the Canadian General Standards Board committee where she creates training standards for transportation of dangerous goods in Canada and is a past Chair of the Dangerous Goods Advisory Council.