Flattening the COVID-19 curve requires commitment from everyone in the community. Washing hands and using hand sanitizer are important components to stop the virus’s spread according to Centers for Disease Control and Prevention.
Distilleries have identified a way they can contribute: their ethanol production capabilities can be implemented as a solution to the shortage of hand sanitizer amid overwhelming demand.
Because hand sanitizer is regulated by the Food and Drug Administration as an over-the-counter drug, it requires special licensing, product labeling and laboratory testing. Distillery plants that begin producing hand sanitizer – without taking proper action and seeking adequate protections – have the potential of unforeseen legal and safety consequences.
Consider these product liability, workers’ compensation and property-related concerns and best practices before manufacturing or distributing hand sanitizer products:
- Providing a product free of charge does not eliminate potential product liability.
- Labels are part of the product: Manufacturers cannot state a hand sanitizer kills specific viruses or bacteria without testing verification and FDA approval.
- Product labels and containers should be reviewed by an attorney familiar with FDA requirements and regulations.
- Product compounding, production, packaging and labeling must comply with FDA guidelines. See the FDA's temporary guidelines for compounding during the COVID-19 crisis; the link is available under Important Resources at the end of this article.
- Provide adequate ventilation to reduce ignitable vapor using mechanical ventilation, windows and open doors.
- Remove all ignition sources in the immediate area of any ethanol production and distribution, such as non-classified standard electrical appliances including lights, radios and extension cords.
- Avoid plastic intermediate bulk containers for flammable liquid storage; metal bulk containers are safer.
- Avoid filling small plastic containers provided by patrons as these increase the risk of spills and static ignition.
- Reduce the risk of static discharge ignition by implementing bonding and grounding measures on all flammable liquids stored and distributed in metallic containers.
- Ensure fire protection systems are maintained and active; keep fire extinguishers readily available.
- Workers may be exposed to combustible vapor during manufacturing.
- Proper personal protective equipment can prevent skin irritation.
Please contact your local independent agent if you have questions or concerns you would like to discuss with your Cincinnati Insurance loss control representative about the production of hand sanitizer.
Alcohol and Tobacco Tax and Trade Bureau Guidance
FDA Label and Formula Guidance
Our loss control service is advisory only. We assume no responsibility for management or control of customer loss control activities or for implementation of recommended corrective measures. These materials were gathered from trade services and public information. We have not tried to identify all exposures. We do not warrant that this information is consistent with Cincinnati underwriting guidelines or with any federal, state or local law, regulation or ordinance.