Q&A: How do I classify a Class 3 Combustible Liquid for both international and domestic transport?

International Air Transportation Association (IATA), International Maritime Organization (IMO), International Transportation of Dangerous Goods, PHMSA HazMat Transportation Regulations

Q&A: How do I classify a Class 3 Combustible Liquid for both international and domestic transport?

Daniel Stoehr
February 4, 2020
This e-mail was sent from a contact form on Daniels Training Services (https://danielstraining.com) on December 05, 2019

Hello,

I am trying to name a chemical for transport. It has a flashpoint of 81 C. It is not a US DOT marine pollutant, but it is an IMDG marine pollutant. We ship in both bulk and non-bulk packaging, both domestically and internationally. I believe the US DOT name would be NA1993, combustible liquids, n.o.s. (name), 3, III -is that correct?

I am having a hard time with the IATA and IMDG name. Would those still be the NA1993? I know that NA1993 isn’t recognized internationally, so I am little confused as how this should be named. Any help you can provide with the naming would be greatly appreciated!!

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My reply December 10th:

Thank you for contacting me.  I apologize for my delay. I will review and reply.  Please advise on the below.

  • What is the chemical? Do you have an SDS?
  • What makes it an IMDG marine pollutant?
  • What is the expected capacity of the packaging: <5 L / 5 kg? <119 gallons? >119 gallons?
  • Does transport begin or end in the U.S.?

Thank you and please advise.

Answer:

Hello Daniel,

Thanks for taking the time to help me with this!!

  • The product is a blend of basic epoxy resin (casRn 25085-99-8) and Oxirane, 2-(butoxymethyl)- (casRn 2426-08-6); flash point 81 °C
  • No, we do not have a SDS. We are trying to make one and the SDS author asked me to assist in the naming.
  • It is IMDG marine pollutant because it meets the UN model regulation criteria for classification as a Chronic Aquatic Toxicity Cat 2.
  • When we make a SDS, we include the names for each package type and mode of transport. We ship 1L to 20L/5 gallon samples, 55 gallon drums, and 275 gallon totes
    • 1L to 5 gallon samples ship by ground or air both domestically and internationally
    • 55 gallon drums and 275 gallon totes ship by ground domestically and by vessel internationally
  • Transport begins in the US

Thanks,

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It was after Christmas, (12.27.19) but I got him an answer:

I will try to answer you questions.  Please see below.

  • Based on the flash point it is a Class 3 Combustible Liquid per USDOT regulations.
  • A material with a flash point higher than 60 degrees C is not subject to international regulations (IATA or IMO).
  • Based on your information it is not a marine pollutant per USDOT regulation but is a marine pollutant per international regulations.
  • A combustible liquid is not subject to USDOT regulation if transported by highway or rail within the U.S. and in a non-bulk packaging (and other conditions).
  • A non-bulk packaging of this material is not subject to USDOT regulations within the U.S. In a bulk packaging it is a Class 3 Combustible Liquid.  NA1993, combustible liquids, n.o.s. (name), 3, III may be the proper shipping description if a more specific name is not available.  There may be other shipping names that are more descriptive of the HazMat.
  • The material is subject to international regulation as a marine pollutant unless subject to the marine pollutant exception (packaging of less than 5 L or 5 Kg).
  • USDOT regulations allow a non-HazMat to be classified as a marine pollutant within the U.S. if subject to international regulation as a marine pollutant.

Also:

  • Section 14 of the SDS is not required to be completed within the U.S.
My suggestion:
  • Classify as marine pollutant for all transport.
  • Classify as Class 3 Combustible Liquid only when in bulk packaging within the U.S.  All other transport is non-HazMat.

Contact me the next time your USDOT, IATA (air), or IMO (vessel) training is due to expire.

Read:

I hope this helps.  Please don’t hesitate to contact me with any other questions.

His reply December 30th:

Thanks Daniel! This was very useful!!