Steve,

The information we have received back is an SDS is required for hand sanitizers under the current FDA guidance if distributing the product. The SDS will be required for any shipments and to inform of the constituent materials to interested parties or for shipment purposes. There are a couple of 49 CFR exemptions to the labeling and packaging requirements if under 5 L total quantity per secondary packaging. However, we received push back from Department of Transportation and FEDEX, as our sanitizer contains Hydrogen Peroxide, albeit a only 0.1254% (v/v) which is below certain GHS guidelines for reporting.

Regards,

Brian Alexander
R&D Sr. Principal Chemist / R&D Safety Manager
BAE Systems Ordnance Systems Inc.
Holston Army Ammunition Plant

T: +1(423) 578 6304å |å M: +1(423) 782 7599å |å F: +1(423) 578 6098å |å E: brian.t.alexander**At_Symbol_Here**baesystems.com
BAE Systems, Holston Army Ammunition Plant, 4509 West Stone Drive, Kingsport, TN 37660-1048 USA
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-----Original Message-----
From: ACS Division of Chemical Health and Safety On Behalf Of Steven Nelson
Sent: Friday, April 3, 2020 9:44 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: [DCHAS-L] SDS for Hand Sanitizer

Are organizations which produce and distribute the hand sanitizer produced under FDA temporary guidance required to supply a SDS? Our School of Pharmacy plans to produce hand sanitizer for our medical clinic. Labeling would be in accordance with the FDA guidance for temporary compounding of alcohol based hand sanitizer. But do they need to create a SDS to distribute with the product?

https://www.federalregister.gov/documents/2020/03/23/2020-05959/policy-for-temporary-compounding-of-certain-alcohol-based-hand-sanitizer-products-during-the-public

Steve Nelson
Auburn University, Risk Management and Safety

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