（Renewed Question on Hand Sanitizers as Carry-on baggage.）
Q.
There was a query on Hand Sanitizers containing alcohol as carry-on cabin baggage in the Apri 2020 Q&A column. The answer given at that time was; “Since alcohol is dangerous goods (UN1987 Alcohols, n.o.s. Class 3), you will have to remove the alcohol from the sanitizer to carry them as luggage. The quantity (of the sanitizer) must be within the volume limits for cabin baggage. You will purchase the alcohol at your destination, and load the Hand Sanitizer for application.”
According to DGR Table 2.3.A Provisions for Dangerous Goods carried by Passengers or Crew, it says: “Non-radioactive medicinal or toiletery articles (including aerosols) such as hair sprays, perfume, colognes and medcines containing alcohol, and Non-flammabe, non-toxic (Division 2.2) aerosols with no subsidiary hazard, for sporting or home use” are permitted both as carry-on and as checked baggage without the operator’s approval and without the need to make NOTOC. It appears carriage of alcohol is permitted. Kindly explain the disparity with the comments made in April. (30 Jun 20)
A.
DGR Table 4.2 List of Dangerous Goods indicate alcohols as follows:
UN3065 Alcoholic beverages Volume of Alcohol 70% or less but more than 24% Class 3 PG III
SP A9 (Packed in receptacle 5L or less – Not Restricted), SP A58 (Less than 24% - Not Restruicted)
UN3065 Alcoholic beverages Volume of alcohol more than 70% Class 3 PG II
---------- Alcoholic beverages Volume of alcohol 24% or less (Not Restricted)
UN1987 Alcohols, n.o.s. ★ Class 3 PG II と PG III
SP A3 (Does not meet defined criteria – Not Restricted), A180 (Used for forwarding specimens, quantity less than 1L – Not Restricted).
The volume of Alcohol used in Hand Santizer is far greater than 70%, almst close to pure alcohol. The flammability is severe and particularly when applied in mist form, a small flame can easily ignite the mist and cause fire. At the early stage of the coronavirus pandemic, due to shortage of alcohol, wine brewers were producing high alcohol degree liquor to supplement the supply of alcohol. Passengers are not expected to use the hand sanitizer in flight, and when loaded in the cargo compartment it may produce a leakage. DGR 2.3.5.1 “Medicinal or Toiletery Articles and Aerosols in Division 2.2” does indicate the presence of alcohol but reading the exampes given, the alcohol content is very small or negligible. Therefore, Hand Sanitizers loaded with alcohol are not suitable as passenger baggage both for carry-on and checked. The April comments, quoted “Since alcohol is dangerous goods (UN1987 Alcohols, n.o.s. Class 3), you will have to remove the alcohol from the sanitizer to carry them as luggage. The quantity (of sanitizers) must be within the volume limits for cabin baggage. You will purchase the alcohol at your destination, and load the Hand Sanitizer for application.” still stand correct.
Copyright (C) 2003 Kinoshita Aviation Consultants All rights reserved.