From a previous Onsite Training customer on January 30, 2018:

Good morning Daniel,

Hate to bother you but if you can find just a moment, our folks are making some changes to our labeling program and wanted me to confirm some information regarding the combustible liquid exception. Specifically –

• Small quantities – correct that they are not subject to any hazmat regs? Is this true even if they are not in combo packaging?
• Drum quantities – diamond required on drum (‘Combustible – 3’)?
• If small quantity containers and drums are marked with our standard product label, which includes DOT shipping information and HMIS marking, do they need to also display the diamond?

Again, sorry to bother you but I wanted to be positive! Thanks for any guidance!

My reply that same day:

Thank you for contacting me. Please see below.

• If your hazmat meets all of the requirements for a combustible liquid you may then take advantage of the combustible liquid exception.
• A non-bulk packaging (capacity of no more than 119 gallons) of a combustible liquid – meeting all other requirements of the exception – is not subject to USDOT regulations. I assume this is what you mean by “small quantities”. The type of packaging, i.e., combination, single, composite… does not matter as long as it is non-bulk packaging and all other requirements of the exception are met.
• A drum quantity (55 gallons) is still a non-bulk packaging and is not subject to USDOT regulations if all of the conditions of the combustible liquid exception are met. The HazMat label “diamond…” is not required if the combustible liquid exception is used.
• If you are taking advantage of the combustible liquid exception the non-bulk packaging should not display any of the USDOT hazard marks or labels. HMIS or GHS hazard communication required by OSHA may still remain. The hazard communication requirements of OSHA do not impact USDOT regulations.

I hope this helps. Please contact me with any other questions.

Another satisfied customer:

Thanks again Daniel, I really appreciate all the information.

And one more thing…

• Under the combustible liquid exception a bulk packaging does not enjoy full relief from regulation as does the non-bulk packaging, but on advantage is this: A DOT specification packaging is not required for a bulk packaging of a combustible liquid.

A combustible liquid in a non-DOT specification bulk packaging

• It is an option to display the white-bottomed placard for transport of combustible liquid by highway. It is required for rail transport. Read: The White Bottom Placard for Combustible Liquids