Alcohol for Use as a Research Chemical

PPD-0103

The Virginia Institute of Marine Science (VIMS) has licenses from both the Commonwealth of Virginia, Department of Alcoholic Beverage Control/Alcohol Beverage Control Board and the U. S. Department of Treasury, Alcohol and Tobacco Tax and Trade Bureau that allow the purchase of alcohol (specifically, punctilious ethanol) free of excise taxes.  The Dean and Director of VIMS is the named licensee.  The tax free ethanol is to be used for scientific purposes only and must not be used for human consumption. 

Individuals needing to purchase, use, transport, or ship tax-exempt ethanol should contact either the Dean and Director or the Associate Dean of Research and Advisory Services who, in turn, will refer the individual to the person currently delegated to manage the tax-exempt-alcohol program.

In order to qualify for the tax-exempt status, the Institute must adhere to specific federal regulations governing the storage and dispensation of ethanol and must maintain specific records of these activities.  As the financial savings that accompany the waiver of the excise taxes are great and the penalties for not complying with the regulations potentially are large, it is important that there be strict compliance with the pertinent regulations.  Federal regulations explicitly forbid the transfer of tax-exempt ethanol to any other person or agency, whether by gift, loan, or sale even if that person or agency is licensed to procure and use ethanol.  Giving or loaning alcohol to colleagues at the Williamsburg campus are included in this prohibition.  The only exception to the prohibition on transfers is a medical emergency due to a major disaster. 

Persons desiring to transport ethanol from the VIMS campus to any off-campus site for VIMS research must conform with the limits on allowable quantities stipulated by the state of Virginia.  These regulations also expressly forbid the transfer of ethanol across state boundaries and limit the volume an individual may bring back into the state to one gallon.  Researchers with programs that need alcohol in another state must arrange for the original delivery to be in that state.   It is the responsibility of the individual investigator to comply with the pertinent regulations of the other state.  Under the existing regulations, transportation of ethanol within the state of Virginia (off the VIMS campus) is limited to 3 gallons, "provided that not more than one gallon ...[is] in containers holding less than one-fifth of a gallon."

In addition to the regulations concerning alcohol as a specific product, alcohol falls under EPA and other regulations concerning hazardous chemicals.  This set of regulations imposes a complementary set of requirements on the storage, handling, shipment or transportation, and conditions of use of alcohol whether or not it qualifies for the tax-exempt status.  The Office of Safety and Environmental Programs can provide guidance concerning these matters.