Ethanol solution (“sanitiser”) is considered to be dangerous goods because it’s highly flammable.
Most dangerous goods packages need to be tested in accordance with Chapter 6.1.5 of the ADG Code (the Australian Code for the Transport of Dangerous Goods by Road & Rail). However, there is some discussion as to whether or not a box containing bottles of sanitiser needs to be tested.
The argument goes:
‘Boxes containing sanitiser don’t require testing, provided that the inner packages are small enough to be Limited Quantities.’
And this is true. So, what’s the Limited Quantity for sanitiser?
The Limited Quantity for sanitiser
The below section is taken from the ADG Code. It shows that sanitiser can be defined as either a packing group II or III substance. This defines the severity of the dangerous good (packing group II being the more dangerous).
The section states that the Limited Quantity allowance of the inner containers may be:
no more than 1L for packing group II sanitiser; but
no more than 5L for packing group III sanitiser.
So, which packing group is your sanitiser?
Determining the packing group of sanitiser
It’s all about the classification of the sanitiser’s flammability.
Using the below table, each type of sanitiser needs to be assessed for its flash point. If it’s less than 23°C, then the sanitiser is packing group II; however, if it’s between (or equal to) 23°C and 60°C, then the sanitiser is packing group III.
This information should be available in the sanitiser’s Material Safety Data Sheet (MSDS). Otherwise the flash point may be determined by a laboratory in accordance with AS 2106–series, Methods for the determination of the flash point of flammable liquids (closed cup).
Companies supplying sanitiser must abide by the ADG Code. This is a legal requirement as per the Dangerous Goods Act 1985.
You don’t have to get testing on a box containing bottles of sanitiser, provided that the inner bottles are small enough to be Limited Quantities (as per Chapter 3.4 of the ADG Code).
If the inner bottles are larger than Limited Quantities, then the box and the bottles need to be tested by a NATA laboratory in accordance with Chapter 6.1.5 of the ADG Code.
Limited Quantity packages must abide by Chapter 3.4 of the ADG Code.
Some useful information
Is there more testing? Does the inner bottle need to be tested independently of the assembled box?
Yes. This is required by the current edition of the ADG Code (7.6), as per Chapter 126.96.36.199. However, it’s worth saying that this may be removed in the new edition of the code which will be released late in 2020.
Here is a copy of the current ADG Code, Edition 7.6
Here is a publicly available MSDS on 70% ethanol. The flash point is 12°C which makes it packing group II. This means that the Limited Quantity allowance is 1L inner bottles.
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