Interesting: Airlines Need Permission To Offer Hand Sanitizer

Filed Under: Travel

This makes perfect sense when you think about it, though it’s probably something that most people wouldn’t even consider.

More airlines are offering masks & hand sanitizer

Airlines are going great lengths to make people feel more comfortable about flying again. This comes in many forms, from requiring passengers to wear face masks, to introducing new cleaning protocols, to providing passengers with hand sanitizer.

We’ve seen some airlines introduce hygiene kits for passengers, containing items like hand sanitizer, face masks, disinfecting wipes, and more.

Emirates’ new travel hygiene kit

What many people may not realize is that US airlines offering some of these amenities goes beyond just cost considerations and procurement logistics — it also requires permission from the DOT.

Why airlines need permission for hand sanitizer

A May 19 letter from the Department of Transportation to American Airlines’ Certificate Management Office shows the process that airlines have to go through in order to get permission to distribute hand sanitizer gel and sanitizing wipes to customers.

What this comes down to is that alcohol-baed sanitizers (whether gel or wipes) are classified as flammable liquids, and that comes with many restrictions when it comes to air transport. In small quantities this shouldn’t be an issue, though precautions still have to be taken, with considerations like storage, quantity, packaging, and more.

Just to give a sense of what the considerations are, here are the first two paragraphs of the letter from the DOT to American Airlines:

This letter is in response to your submission, dated May 19, 2020 in which you requested approval to provide personal use quantities of hand sanitizer gel and sanitizing wipes to customers prior to boarding and/or distributed during flight. The wipes/sachets consist of less than 1 ounce (28 grams) of hand sanitizing gel containing 60-70% alcohol (depending on manufacturer) per wipe/sachet. Members of your team met with inspectors in the American Airlines (AA) Certificate Management Office (CMO) and the Office of Hazardous Materials Safety assigned Principal HazMat Inspector on May 14, 2020 and May 18, 2020 to discuss the14 CFR part 5 required safety risk assessment that AA calls a Risk Management Worksheet (RMW) for these changes.

49 CFR §175.10 provides passengers and crewmembers with the ability to carry certain dangerous goods in personal use. 49 CFR §173.150(g) provides shippers with exceptions for retail products containing up to 70% alcohol by volume for up to 0.125 gallons (0.47 liters) for liquids and 1 lb. (0.45 kgs) for solids. 49 CFR §175.8 (a)(4) provides that other items of company hazardous materials may be carried and used by the operator with approval of the Administrator of the Federal Aviation Administration. AA has specified that it will not transport case quantities of hand sanitizer for replacement in the cabin but that longer flights may have double quantities provisioned for use on the return flight. AA has further provided information that shows all quantities will be prepared in accordance with the CFR limitations noted above and are to be dispersed throughout the catering carts to minimize concentration in any one location.

As you can see, some of the main considerations are that they don’t store unnecessary amounts of these on planes, that they spread out storage of them throughout the plane, and that they keep the quantities limited.

Based on the inspection, it was decided that American Airlines mitigated risk appropriately, and that the process described meets FAA requirements. If any changes are made to the process, American will once again need permission for that.

Now, in fairness, American is a bit behind the curve here, and this is supposed to be a pretty quick approval process. The airline only went through the approval process in mid-May, arguably well over two months after it was obvious that this might become necessary.

Delta’s amenity kits have featured “hand cleanser” for a long time.

Delta’s amenity kit (with hand sanitizer)

It’s my understanding that this contained less than 50% alcohol, so didn’t need the same permission. Delta has also had to get updated permission to offer hand sanitizer on a more widespread basis.

Delta’s new care kits

While a bit more extreme, let me just give an example of when something flammable that was brought onboard a plane became an issue. In 1999 a Uni Air MD-90 had an explosion on landing, as a passenger had been carrying bottles of flammable liquid, which ignited with a motorbike battery in a nearby overhead bin. Again, that’s not exactly the same thing, but it gives you an idea of the risk that can be posed by flammable items in the cabin.

Bottom line

It makes perfect sense that airlines would need to have protocols for alcohol-based hand sanitizer approved, even if it’s something we might not otherwise think about.

While this is unlikely to pose a threat in small quantities, you’re better safe than sorry. After all, you don’t want airlines storing an unnecessary amount on planes, and that potentially leading to problems…

(Tip of the hat to View from the Wing)

  1. This is something taught to every junior check-in agent and ramper on the first day during their DGR familiarisation. If you don’t know these regulations off the top of your head, you shouldn’t be working near an aircraft.

  2. Bottles of flammable liquid and Motorbike battery? Bottles? and a battery? Sorry for my French

  3. In February check-agents (in Asia) already specifically asked that passengers not to pack hand sanitizers in check in luggage. This comes as a good reminder for all of us.

  4. My Air India amenity kit had a lemon scented hand sanitizer. Smells nicer than Purell and it now sits in my car for use after grocery store trips.

  5. Passengers and crew are already allowed to bring up to 12 ounces apiece without issue.

    And the FAA studied on board sanitizer a decade ago and found it safe (“burning hand sanitizer presents no significant risk to commercial transport aircraft fire safety, given the present cabin material flammability requirements”)

    So no I’m not actually sure that it “makes perfect sense that airlines would need to have protocols for alcohol-based hand sanitizer approved.”

  6. Please note that the Delta One kits have something labeled hand cleanser (as demonstrated in the picture), not hand sanitizer.

    It is recommended that you use hand sanitizer with at least 60% alcohol. The old Delta hand cleansers that I have do not specify the percentage of alcohol, but list water as the first ingredient, so presumably the alcohol content is less than 50%.

  7. Good to know! I’d think travelers nowadays will bring his/her own travel-size hand sanitizer or wipes when traveling on a plane or train or bus.

  8. @Gary Leff – passengers and crew may BRING their own for personal use, but that does not cover provisioning of these on the aircraft by the airline. Anything provisioned on the aircraft is classified as “aircraft stores” and has a separate DG classification for obvious reasons.

  9. Airlines need to allow people to buy blocks of 9 seats. It would be very expensive, something I don’t like doing. However, I will pay. With AA having over 50% load recently, this will be increasing impossible. I want to buy my own social distancing. (Even 6 feet might not be enough but will do)

  10. @Sean M – I understand that the procedure is required by regulation, however it seems to me for a substance that is allowed on board (even > 250 pounds of it brought on by passengers and crew) that the FAA has studied extensively and concluded poses no material risk for the airline to provision that multiple meetings, with different FAA offices, and seeking of formal permission is indicative of a larger problem.

  11. @Gary Leff – that is more of an FAA issue than anything else. ICAO regulations permit variation to be issued by member states at any time. Our local regulator issued this variation months ago to exempt alcohol based hand sanitizer up to 70% alcohol in containers up to 500ml and up to 2 liters per passenger in hand luggage.

  12. Overly nervous flyers might try to use an alcohol-based sanitizer to set fire to any other passenger that comes within 6 feet. This is probably the real concern.

  13. @NK3

    S***, I didn’t notice this before. I was using this stuff right before Delta grounded most international flights. Time to trash that thing.

    On a side question, will TUMI still monogram the old kits? I was digging my old kits for these and uncovered some of the classic hard shell monogram kits.
    I wished DL would bring back those kits. More useful that the current ones. I still wish they had kits with a 2nd purpose in mind. Like older kits that doubles as hanging toiletry bag (anyone old enough to remember when they had mirrors in those kits). Or the old AA F tablet case which perfectly fits iPad.

  14. @Eskimo

    Well, I am sure “hand cleanser” is better than nothing, but yeah, it (likely) does not meet recommended guidelines for use as a hand sanitizer. On the upside, hand sanitizer does seem to be more readily available these days, compared to late March/early April. When I go to the store, they usually have some random type/size of it.

    I thought the newest iteration of Tumi kits could hold an iPad mini? I’m not 100% sure, cuz I have a full size iPad, and the kit is not that big. I liked the hard shell ones because people actually seemed to want them, so I could give them away as presents.

  15. Yes sanitizers are different from cleansers. Also be careful with hand soap. Many hotels (especially the luxury ones) only offer “high-end” hand soap that promotes its good smell but says nothing about the hygiene effect.

  16. @NK3

    It can hold the new iPad mini without any case. If you have some case, even the slim ones, might not fit the Tumi pouch, mine doesn’t fit with case on. The old AA one is much more padded too. I liked the hard shell too, I actually like the older one without the monogram, it looks more “Tumi” than copying idea of another mini suitcase.

    Government should set a price on hand sanitizers too.
    I’ve seen dozens of new brands pop up that make them look like designer or boutique hand sanitizers and sell them for $10. Mean while dollar stores also sell them for $1. It’s really just alcohol.

  17. This is actually utter rubbish. There is simply no harm in everyone being given their personal hand sanitizer. The fact is that in this day and age many carry a quantity with them. I’m not surprised to hear this type of news come out from the States – the land of obvious health and safety guidelines. More so, why on earth was a motorcycle battery allowed on board? Just god damn nuts.

  18. Ummmm…I wonder how much alcohol is being stored in the form of Jack Daniels or Titos.

  19. The onboard alcohol will work as hand sanitizer. One to drink and one to sanitize. Make mine Jack Daniels.

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