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Q&A: Reclassifying a Flammable Liquid to a Combustible Liquid

Q&A: Reclassifying a Flammable Liquid to a Combustible Liquid

A question from a customer of mine after I had provided them with training:

Hi Daniel.  I just need clarification from what you had told us regarding reclassifying our product from Flammable to Combustible.  Do we need to change the Transport information on our SDS?  This is what is currently listed.

Section 14: Transport Information
UN number  3295
  • UN proper shipping name  Hydrocarbons, Liquid, N.O.S., 3, PG III
  • ICAO/IATAUN3295, Hydrocarbons, Liquid, N.O.S. 3, III
  • IMO/IMDG  UN3295, Hydrocarbons, Liquid, N.O.S. 3, III, (39.4°C)
  • ADR/RID  UN3295, Hydrocarbons, Liquid, N.O.S. 3, III, ADR
Not a good time for me.  I had to put them off:

I am about to begin a Webinar and am then preparing for transportation tomorrow morning.  I will get you an answer as soon as I can.

It took me a few days but I finally got them an answer:
My answers to your question is below.
  • While section 14 of the Safety Data Sheet is required to be completed, its information is for guidance purposes only as its content is not regulated by either OSHA (whose regulations require the SDS) or USDOT/PHMSA:

The SDS must also contain Sections 12 through 15, to be consistent with the UN Globally Harmonized System of Classification and Labeling of Chemicals (GHS), but OSHA will not enforce the content of these sections because they concern matters handled by other agencies.

  • But of course you want the information on your SDS to be as accurate as possible.
  • Describing the material as a Class 3 Flammable Liquid is correct since its flashpoint is below 140 degrees fahrenheit and its re-classification to a Class 3 Combustible Liquid and using the Combustible Liquid Exception are options, not mandatory.
  • If you wish to clarify why your SDS indicates it is a Flammable Liquid and you are shipping it as a Combustible Liquid, you may include language in Section 14 as follows:  Pursuant to 49 CFR 173.120(b)(2) and 49 CFR 173.150(f) a flammable liquid with a flash point at or above 100 degrees fahrenheit may be reclassed as a combustible liquid for transportation within the U.S. by motor vehicle or rail only.
I hope this is not too late to help.  Please don’t hesitate to contact me with any other questions.

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

International and Domestic

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It’s not uncommon for a customer to follow up with questions after Onsite Training or a Webinar.  And I’m only too happy to oblige.