3 Combustible Liquid Shipping Examples

Posted on 7/20/2020 by Winter Rosen

Liquids that have a flash point up to 140oF are considered hazardous materials and regulated as Class 3 Flammable Liquids under both international and domestic standards.

For US shippers, the US DOT takes it one step further. Under DOT’s Hazardous Materials Regulations (HMR), “combustible” liquids are those with a flash point greater than 140oF but less than 200oF that do not meet the definition of any other hazard class [49 CFR 173.120].
Need hazmat training? Help satisfy DOT's 3-year training mandate for hazmat employees when Lion presents the Recurrent Hazmat Ground Shipper Certification webinar on August 11. 

Are Combustible Liquids Exempt from the HMR?

When you ship combustible liquids, you may be able to take advantage of some unique reliefs.

Combustible liquids transported in non-bulk packages are entirely exempt from US DOT’s HMR unless they also meet the definition of a hazardous substance, hazardous waste, or a marine pollutant [49 CFR 173.150(f)(2)].

Shipping Combustible Liquids: Example 1

For example, let’s say you have a diesel fuel that has a flash point of 165oF, making it a combustible liquid. The diesel fuel does not meet the definition of a hazardous substance, hazardous waste, or marine pollutant. If you were to ship your fuel in a non-bulk packaging (e.g. a 55-gallon drum), the shipment would not be a regulated under the HMR.

Remember, a non-bulk packaging is one with a maximum capacity of 450 L (119 gals) or less for liquids. Anything with a maximum capacity greater than that is considered a bulk packaging [49 CFR 171.8].

What Hazmat Regs Do Apply to Combustible Liquids?

Combustible liquids are regulated as hazardous materials only when they are also a hazardous substance, a hazardous waste, or a marine pollutant, or when they are being transported in bulk packages.

Even when hazmat regulations do apply to combustible liquids, these materials receive a lot of regulatory reliefs. In fact, regulated shipments of combustible liquids are exempt from all the requirements of the HMR except those pertaining to:
  • Shipping papers
  • Emergency response information
  • Marking of packages
  • Displaying identification numbers
  • Placarding
  • Incident reporting
  • Certain packaging requirements
  • Registration requirements
[see 173.150(f)(3)]

Shipping Combustible Liquids: Example 2

Let’s go back to our diesel fuel example. This time, instead of shipping it in 55-gallon drums, you are now shipping it in a cargo tank. Since the diesel fuel is now being shipped in a bulk package, the shipment is now regulated and subject to the applicable requirements under the DOT HMR.

Combustible Liquids and International Regulation

Now you might be wondering: How do international hazmat regulations like the IATA DGR and IMDG Code handle combustible liquids?

Short and sweet answer: They don’t. Combustible liquids are simply not recognized internationally and thus not regulated under either IATA DGR or IMDG Code standards. For international transport, the flash point range for flammable liquids ends at 140oF, and that’s that.

Which brings us to our third and final example.

Shipping Combustible Liquids: Example 3

Let’s say that our regulated cargo tank shipment of diesel fuel from example 2 will be transported from New York to England. During ground transportation, the cargo tank is regulated and subject to all the applicable DOT HMR requirements. This means that the tank must bear a combustible placard for this portion of transport.

But because combustible liquids are recognized in the US only, the placard must be removed when the cargo tank arrives at the port and is loaded onto a vessel. Otherwise, the unfamiliar markings could cause confusion and mislead supply chain personnel about the hazards of the material.

Online Hazmat Training: Live or Self Paced

online hazmat trainingJoin a full time Lion instructor for an engaging hazardous materials learning experience when Lion presents the Recurrent Hazmat Ground Shipper Certification Webinar

See the full 2020 schedule. 

This one-day instructor-led webinar guides you through the latest updates to the 49 CFR Hazardous Materials Regulations (HMR). Join us to develop in-depth hazmat shipping expertise. This course is designed to help meet US DOT PHMSA's hazmat training mandate at 49 CFR 172.704. 

Or learn at your own pace with a convenient online course. Lion's courses are packed with interactive exercises and robust resources that enrich your online learning experience and help you retain more of what you learn.

Hazmat Ground Shipper Certification
Recurrent Hazmat Ground Shipper Certification 

Tags: Class 3, DOT, hazmat shipping

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