Isopropanol mixture packaging

This is in response to your May 3, 2007 letter regarding the transportation of isopropanol under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if 70 percent isopropanol may be transported via air or highway transportation. In your letter you state that the 70 percent isopropanol is packaged in a combination packaging consisting of four one-gallon inner receptacles and in pre-saturated wipes.

Provided your packaging meets the applicable requirements in Parts 173 and 178, the 70 percent isopropanol (as described in your letter) may be transported by any mode of transportation; however, there are restrictions concerning passenger aircraft and passenger rail transportation. Your combination packaging contains more than five liters of isopropanol per packaging (i.e., it contains 15.14 liters). As specified in Column 9A of the Hazardous Materials Table ( 172.101 HMT), the 70 percent isopropanol may not be offered for transportation in packages exceeding five liters net quantity when intended for passenger aircraft or passenger rail. Therefore, your combination packagings, as described, may not be transported by passenger aircraft or passenger rail.

Wipes containing isopropanol are most appropriately transported under the proper shipping name "Solids containing flammable liquids, n.o.s." Special provision 47 excepts from the HMR sealed packets that contain less than 10 ml of a flammable liquid in Packing Group II or III when the liquid is completely absorbed onto a solid material.