A question via email on January 19, 2018 that was a follow-up to a telephone conversation:

Hi Dan,

I am following up on our phone conversation this morning on shipping combustible liquid.

Also, wondering if pharmaceutical drug products are exempt at all from regulation.

I have suggested to my client that we review the anticipated specific shipping protocols to develop specific shipping instructions – I will likely need your help with that.

Thanks so much!

I will try to provide some guidance and helpful information. See below.

To answer the question about the applicable regulations when shipping a combustible liquid by air:

• Your hazmat is a combustible liquid due to its high flashpoint.
• Per 49 CFR 173.150(f)(2), the USDOT/PHMSA HazMat Regulations do not apply to a combustible liquid in a non-bulk packaging unless a Haz Substance, Haz Waste, or marine pollutant. Note: the limitation to only ground transport is a condition of the option to re-class a flammable liquid to a combustible liquid. It is not a condition in the exception of a combustible liquid from regulation.
• Therefore, as long as it is not a Haz Substance, Haz Waste, marine pollutant or transported in a bulk packaging it is not subject to regulation within the U.S. even if transported by air.
• If transported by air, it cannot be packaged in a bulk packaging since the only type of bulk packaging recognized by IATA is the IBC and its use is limited solely to UN3077 and can’t be used for a combustible liquid.
• A combustible liquid in a single packaging up to 119 gallons is not subject to regulation within the U.S. by any mode of transport. And, a combustible liquid is not regulated by IATA.
• I am not aware of an exception from regulation for pharmaceutical products.
• There is an exception from regulation for a limited quantity of retail products containing ethyl alcohol at 49 CFR 173.150(g).

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

Conclusion:

You may be wondering about his last comment, “I will likely need your help with that.” and to what he was referring.  In addition to providing training for the transport of hazardous materials and the management of waste, I also provide consulting services.  So if you have the training you need but still have a problem, contact me for help.