PHMSA Continues Relief for Transportation of Hazardous Goods

Posted on May 18, 2020

Throughout the month of April, the Pipeline and Hazardous Materials Safety Administration (PHMSA) has worked to provide relief and streamline the movement of critical sanitation supplies by highway. While these policies do not provide full exemption to the 49CFR Hazardous materials regulations, they do in many instances, provide relief from packaging, training, labeling, and documentation.

April 2: Temporary policy for the Transportation of certain Alcohol- Based Hand Sanitizer Products

For a period of three months from the date of issuance, Alcohol-based products, such as hand sanitizers, which are typically classified as a class 3, Flammable liquid having a flashpoint below 60 c will not be regulated if they meet the following criteria.

  1. Packages contain hand sanitizer containing either ethyl or isopropyl alcohol with less than 80% concentration
  2. Packages must be leak-tight and securely closed.
  3. Contents of each package shall not exceed 8 Gal
  4. The outer packaging and any overpacks must be marked with the company name and the words “Sanitizer – Contains (Ethyl/Isopropyl) Alcohol”

This is only a temporary relief targeting small packages containing hand sanitizer but allows for shipping without UN/DOT spec packaging, training requirements, and hazard labels. This notification was also revised on April 10th,  allowing for FDA Labels to satisfy the DOT text marking guidelines and registration requirements.

April 10:. PHMSA Shipping Paper Notice Highlighting Shipping Papers and Social Distancing

               On April 10th, the PHMSA issued a notice clarifying that for hazardous materials not explicitly outlined in previous public notices that all hazardous materials documentation requirements will remain in force. As all parties must sign these forms, there were many inquiries into this requirement. PHMSA recommends exchanging shipping papers via clipboard and placing it on a table to be signed or relying on electronic transmission.

April 20: Notice of Enforcement Discretion Regarding Continued Manufacturing of Performance Oriented Packaging (POP) Designs That Have Exceeded Their Periodic Retesting Date

               PHMSA has issued a public notice that for a period of three months, it will not act against any company manufacturing UN performance-oriented packaging if they are unable to maintain their ability to retest performance every 24 months, as mandated in 49 CFR 171-180. This relief only applies to previously tested packages that have fallen out of compliance in the allotted time. Manufacturers must still maintain all possible quality standards.

April 20: Carrier MOTS Relief Notice

During the COVID-19 outbreak, the PHMSA is providing relief on the transport of sanitizers and disinfectants that would normally fall under Class 3 Flammable Liquids or Class 8 Corrosives. This relief is targeted at giving essential employees in the transportation industry better access to health and safety products that would usually be regulated. This relief only applies to transport via highway by private motor carrier in support of its principal business for use by employees and operators engaged in sorting packages, delivering goods, and loading or unloading packages. 

49 CFR

Code of Federal Regulations guiding the Handling, Storage, packaging and transportation of hazardous goods by rail and highway.


The temperature at which an organic compound gives off sufficient vapor to ignite in air.

UN Spec

UN Spec Packaging is designed to contain dangerous goods. Having been tested to a specific standard set out by the United Nations.

DOT Spec

DOT Spec Packaging is designed to contain dangerous goods. Having been tested to a specific standard set out by the US Department of transportation.

Hazard Class

Every hazardous material is assigned to one of nine hazard classes as defined in 49 CFR 172.101 and 173.

Contributor: Jacob Lane