Shipping hazmat internationally can be a challenge, especially when the U.S. DOT’s hazmat regulations differ from international standards like the IATA Dangerous Goods Regulations or the IMO’s IMDG Code. “Combustible liquids,” for example, are regulated as hazardous in the United States but are considered non-hazardous under international shipping rules. Because of this discrepancy, marking, labeling, and documenting these shipments for international transport can be problematic.
International regulators and the U.S. DOT both consider liquids with a flash point up to 140°F to be Class 3 flammable liquids. The U.S. DOT rules include a unique provision under which liquids with flash points between 140° and 200°F that do not meet the criteria for any other hazard class are classified as “combustible liquids.” In certain cases, a Class 3 flammable liquid with a flash point as low as 100°F (some paints and adhesives) can be reclassified as a combustible liquid under the Hazardous Materials Regulations.
Materials classified as combustible liquid are entirely exempt from the U.S. DOT’s Hazardous Materials Regulations (HMR; 49 CFR Parts 100-185) when shipped in non-bulk packages and partially exempt when transported in bulk packages. [49 CFR 173.150(f)]
More Codes, More Problems
However, as the combustible liquids hazard class is NOT recognized by the IMDG Code or other international regulations, its use can complicate your import-export shipments. For example:
If you have a liquid with a flash point of 195°F packed in a cargo tank, and are shipping it from Iowa to France, you must have a combustible placard on the tank between your plant and the port, but no placards are allowed on the tank once it’s loaded on the vessel.
If you have a liquid with a flash point of 125°F, reassigned to the combustible liquids hazard class, packed in drums, and are shipping it from Oregon to Thailand, then no marks, labels, or shipping papers are required between your plant and the port, but once it’s on the vessel it’s a Class 3 hazmat again and needs full marks, labels, shipping papers, etc.
Being unaware of this and other important differences between 49 CFR and the international regulations can result in costly delays and miscommunications during transport.
Some Solutions for Shipping
Taking a look at the two examples above, you have a few options for shipping combustibles.
We’ll first start with combustibles with a flash point between 140° and 200°F. The easiest method is to ship them in non-bulk packaging. In this scenario, the shipment is not regulated by DOT or by the IATA/IMDG rules, so we do not have to worry about any hazmat regulations.
The other option is to send them in bulk packaging. When shipped in bulk packaging by ground, combustibles are subject to DOT rules. [49 CFR 171.22(c)] Once the shipment reaches the port, the package must be shipped as non-dangerous goods. In this situation, many shippers choose to hire an agent to remove all hazard communications and placards to ready the package for international shipment at the port.
Next, let’s take a look at “re-classed” combustibles (which are certain flammable liquids with a flash point between 100° and 140°F). We do not have to spend much time discussing bulk shipments of these since they are regulated by both DOT and IATA/IMDG. Just ship these under all applicable hazmat rules.
That means we are left with the non-bulk packages. Though re-classed combustibles are not subject to DOT regulation when shipped by ground, many shippers choose to ship these materials as fully regulated through the entire cycle of transportation (including ground) to minimize compliance errors. A more complicated approach involves shipping the non-bulk packages under relaxed 49 CFR rules to a freight-forwarder agent in the port area and paying that agent to forward the consignment, as azmat, to the foreign destination. This method still calls for re-doing the packing/labeling/documentation halfway through the shipment, but it’s planned instead of unexpected.
Ensure you are following all of the DOT and international shipping regulations with comprehensive hazmat training. At Lion Technology’s Multimodal Hazmat Shipper Certification Workshops, you’ll learn all of the rules for classifying, packaging, marking, labeling, and documenting your hazmat shipments in full compliance with the DOT, IATA, and IMO rules.
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