by Brad Plummer, Editor, Distiller Magazine

As urgency around the global coronavirus pandemic has intensified, consumers across the country shopping for one of the most basic personal hygiene products — hand sanitizer — have been met with empty shelves.

In response to these alarming shortages, craft distilleries in the US have begun taking action by pivoting operations to make hand sanitizers in-house, using one of the key ingredients they have in abundance — ethyl alcohol.

Media coverage of this trend has proliferated over the last week as well, which is good news for an industry eager to contribute as society otherwise grinds to a halt, clouded in fear and uncertainty. (See below for a partial list of links.) But while it may seem like an obvious way for spirits producers to contribute to the growing pandemic response, there are a range of safety and regulatory concerns to consider first.

For distilleries looking to get involved in hand-sanitizer production, it is important to first understand your state and local regulations. In California, for example, there are several license types held by distilleries — some licenses allow for production of hand sanitizer, but not distribution, while other types are the opposite. Regardless of your best intentions, it’s best to first check with your state regulators before venturing into sanitizer production and distribution, rather than risking your licensing privileges altogether.

In late January, in response to the burgeoning pandemic and emerging hand-sanitizer shortages, the US Food and Drug Administration (FDA) released temporary guidelines for licensed alcohol businesses wanting to help out. This document includes, among other information, a basic recipe for manufacturing hand sanitizer, according to an approved formula disseminated by the World Health Organization (WHO) and sanctioned by the FDA. The Distilled Spirits Council of the United States (DISCUS) has also issued a document compiling current regulatory guidelines for distilleries making hand sanitizer.

Safety, as always, is paramount when undertaking alcohol production of any kind, and making hand sanitizer is no exception. All federal and state regulations generally stipulate that ethyl alcohol used in hand-sanitizer products must be denatured, as to render it a non-consumable form of alcohol. However, the most common recommended denaturant, hydrogen peroxide, can be very dangerous when added at even mild concentrations directly to high-proof alcohol. Careful and informed process methods are key here. Consult with a chemical engineer if possible before moving forward with a production plan.

The current regulatory trend seems to be moving in the direction of temporarily loosening production and distribution restrictions in response to the recent pandemic, but again this will vary by state. Today the federal Alcohol and Tobacco Tax and Trade Bureau (TTB) formally released guidelines and exemptions for distilleries looking to produce hand sanitizer. We will keep you posted as further updates arise.

WHO’s detailed guide for making hand sanitizer:
https://www.who.int/gpsc/5may/Guide_to_Local_Production.pdf

Recent related media coverage:

New York Times article (paywall)
https://nyti.ms/2x9lip9

https://www.forbes.com/sites/larryolmsted/2020/03/17/hand-sanitizer-from-craft-distillery-could-be-useful-trend/

https://www.cnn.com/2020/03/16/us/distilleries-hand-sanitizer-coronavirus-trnd/index.html

https://www.ft.com/content/e7c02232-67a5-11ea-800d-da70cff6e4d3

https://www.breitbart.com/health/2020/03/17/distilleries-make-hand-sanitizer-for-people-in-need-during-coronavirus-outbreak/

https://www.eater.com/2020/3/16/21181423/liquor-distilleries-create-high-alcohol-proof-hand-sanitizer-to-combat-coronavirus-covid-19

https://apnews.com/e43f2aea014e70abe3de23f9d79df8b1