A good question from someone looking to classify a hazardous material (April 4, 2017):
Was wondering if you could answer this question. How do you choose whether a material mixture should be called “Flammable liquid corrosive n.o.s.” or “Corrosive liquid Flammable n.o.s.” I noticed both exist. regards
Thank you for your question, I will do my best to answer below.
- It is the responsibility of the shipper of a hazardous material to classify it per the PHMSA/USDOT Hazardous Materials Regulations (HMR).
- At 49 CFR 172.101(c)(10) the HMR indicates the procedure for classifying a solution or mixture. One option is to choose a generic shipping name: Flammable liquid, corrosive, n.o.s. (primary hazard class 3. Subsidiary hazard class 8) or Corrosive liquid, flammable, n.o.s. (primary hazard class 8. Subsidiary hazard class 3).
- To determine the primary and subsidiary hazard class the shipper must first determine the packing group for each hazard class (Class 3 at 49 CFR 173.121. Class 8 at 49 CFR 173.137).
- With the packing group determined for each hazard class (3 & 8), shipper must proceed to 49 CFR 173.2a and refer to the Precedence of Hazard Table.
- Using the table the shipper can determine the primary and subsidiary hazard class. This, then, can be used to determine the correct proper shipping name.
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Short answer: Use the Hazardous Materials Regulations to determine if it is primarily corrosive or primarily flammable and then choose the correct proper shipping name.