PPB October 2020

In environments with high exposure to alcohol, alcohol can cause skin and eye irritation. Ingesting alcohol can cause drowsiness and dizziness and potentially damage internal organs. Alcohol also poses an inhalation risk. With these known hazards, hand-sanitizer labels should include the following warnings: • For external use only • Do not use on open skin wounds • Avoid contact with eyes • May be harmful if swallowed • Keep out of the reach of children • For use by children only under adult supervision • Do not use on children less than twomonths of age • Flammable: keep away from flame and heat Additionally, all hand sanitizer should be marked with a lot code or batch number and expiry date. Managing Chemical Hazards In Manufacturing The Occupational Safety and Health Administration (OSHA) provides guidance to industry for managing risk associated with chemical hazards, such as those associated with ethyl alcohol. For manufacturing and storage facilities where hand sanitizers are either manufactured and the finished product or the ingredients for the product are stored, in addition to cGMPs, the facility should be climate-controlled and properly ventilated. No open flames or smoking should be permitted in areas where alcohol is stored or used in the production process. Employees engaged in manufacturing operations in the areas where ingredients are mixed or pre-mixed solution is transferred to subcontainers should be provided with appropriate personal protective equipment (PPE) that may include gloves, safety glasses and respirators. Labeling all bulk containers of ethyl alcohol with Safety Data Sheet labels ensures employees are aware of the contents and the necessary precautions to be taken. (See Figure 2 ) Shipping Dangerous Goods During The COVID Pandemic The Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) regulates the transportation of hazardous substances known as Dangerous Goods, a global standard for hazardous materials established by the United Nations. Due to fire hazards posed by ethyl alcohol, packages containing alcohol-based hand sanitizer are restricted fromair freight and limited in how theymay be packed for surface transport. 49 CFR § 173. 150(g) permits transportation of products containing nomore than 70-percent ethyl alcohol by volume for liquids. The outer package, in addition to the company’s name, must be labeled with a Dangerous Goods label identifying the contents as sanitizer containing ethyl alcohol, a flammable liquid. Packagingmust be leak-tight and securely closed, with interior contents protected fromdamage. During the pandemic, PHMSA has issued the Temporary Policy for the Transportation of Certain Alcohol-Based Hand Sanitizer Products During the Public Health Emergency (COVID-19). Find it here: www.phmsa.dot.gov/sites/ phmsa.dot.gov/files/2020-04/ PHMSA%20Hand%20Sanitizer%20 Relief%20Notice.pdf. Figure 2 Labeling all bulk containers of ethyl alcohol with SafetyData Sheet labels ensures employees are aware of the contents and the necessary precautions to be taken. 84 | OCTOBER 2020 | THINK