Traveling With Ethanol? Think Twice.

Any field biologist you talk to likely has pickled specimens in formalin or ethanol at some point during her career. Similarly, ask a molecular ecologist, and it’s probable that he’s preserved some tissue samples in ethanol. It’s also likely that those biologists then transported their specimens or tissues as carry-on or checked baggage on their flights home.

Ethanol and formalin, however, are hazardous materials and bringing them on a plane breaks several laws and can be punished very severely. Get caught with ethanol or formalin and you can face a civil penalty up to $25,000 for each violation as well as criminal penalty up to $500,000 and/or imprisonment for up to 5 years.

In other words, don’t take ethanol or formalin on a plane. This means you can’t pack ethanol with you on your way to the field, so you’ll need to pick non-hazardous preservation materials (e.g. RNAlater), procure supplies at your destination, ship pickling supplies to your field site, or bring back live animals to preserve in the lab. Inconvenient, at the least. Impossible, at the worst.

If you decide to use ethanol or formalin to pickle or preserve your specimens in the field, then you’ll have to ship your specimens home using a carrier like FedEx. As scientists, we are allowed to ship specimens in ethanol in small quantities under International Air Transport Association (IATA) Special Provision A180 (IATA) and the Department of Transportation (DOT) 173.4b de minimus exception. Although there are a number of steps to follow, shipping under these exceptions is straightforward.

Below is a set of instructions for shipping specimens or tissue preserved in ethanol from the Dominican Republic to the US, using FedEx as a carrier. We procured our absolute ethanol in the DR because the DR will not receive dangerous goods, at least not from individuals.

While protocols for other preservation materials (such as formalin) and for other countries are likely similar, PLEASE CHECK with your university’s Environmental Health and Safety division (or the equivalent) before shipping anything to or from the US.

Importantly, we are working with non CITES animals. That’s a whole other jar of lizards.

To ship hazardous materials, you have CLASSIFY the material correctly, PACKAGE it properly, LABEL it properly, and DOCUMENT it correctly with the shipper.

CLASSIFY: Ethanol is considered a dangerous good/hazardous material by IATA and DOT. As such, ethanol must be specially handled.

PACKAGESpecimens: Wrap specimens in cheese cloth or paper towel moistened with alcohol. Place in a bag such that there is not more than 30ml of free liquid in the bag. Heat seal this bag. Tissues: place tissues in tubes with ethanol, not exceeding 30ml EtOH per vial. Place tubes in a plastic bag and heat seal.

Place these plastic bags in a larger plastic bag with enough absorbent material to soak up any free liquid that might spill. Heat seal this larger plastic bag.

Place the large plastic bag(s) in a strong outer package with cushioning material, such that there is no more than 1L of liquid in this outer package.

Seal up the box, putting a copy of your USFWS 3-177 form and your export permits inside the box.

LABEL: On the outside of the box, write “Scientific research specimens, not restricted, Special Provision A180 and 49 CFR 173.4b apply.” Also write “USFWS Clearance Required” to make sure that FedEx clears your import once it arrives in the US.

DOCUMENT: On the FedEx waybill, check the dangerous goods option “Yes – Shipper’s declaration not required.” In the description-of-contents section, write “Scientific research specimens, not restricted, Special Provision A180 and 49 CFR 174.4b apply.” Place all your export permits and USFWS forms in the plastic sleeve with the waybill.

Pay your bill, and catch your plane.

Last, for those working in the DR, 99.95% ethanol can be procured from BDC Serralles on the corner of Avenida Abraham Lincoln and Avenida Jose Contreras for about 2000 pesos. The phone number is 809-338-8888.

About Yoel Stuart

Yoel studies evolutionary ecology of Anolis lizards. He is a graduate student at Harvard University, in the Department of Organismic and Evolutionary Biology.
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3 Responses to Traveling With Ethanol? Think Twice.

  1. Andy Bentley says:

    Nice post – one point of clarification – the DOT de minimus regulations only allow 1ml of fluid in internal package total and not the more generous 30ml of free liquid allowed by A180. Also 3.7% formalin is not regulated and can be carried – if you can get it past TSA…

    Also DOT regulations are US regulations and do not apply internationally.

  2. Yoel Stuart says:

    Do you know whether 2ml tissue tubes count as the first “internal package”? Then you can put thirty of those (assuming 1ml ethanol per tube) in the next package?

    Thanks for the comment. Has TSA given you trouble with Formalin?

  3. Andy Bentley says:

    Yes, a 2ml tube counts as an internal package and so these can be packaged into a secondary outer package and sent as such. With A180 (and the DOT and USPS letters of interpretation deeming domestic shipments non-dangerous) there is no need to use DOT de minimus though and 2ml of fluid would be just fine.

    I have never tried getting specimens through TSA in formalin but various researchers here have had success bringing specimens back from the field in that manner in checked baggage. They usually rinse the specimens before packaging as any hint of formalin fumes usually sends up red flags and in some cases formalin can be classified as a noxious Class 9 fluid which makes it fall within the realm of the discretion of the pilot as to whether he will accept it.

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