Combustible liquid

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

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,

Interested in site specific training at your site that covers this topic, and more!

Ask me about my Onsite Training
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!!

Q&A: Are placards required for a bulk packaging with less than 119 gallons of HazMat?

Q&A: Are placards required for a bulk packaging with less than 119 gallons of HazMat?

An email question on April 8, 2018:

Sir,

We have tank trailers with a 1000 gallon volume of diesel fuel.  If the tank has 100 gallons or less, do they need to be placarded during transport?

Thank you,

My reply the next day (04.09.19):

Thank you for contacting me.  I will try to answer your question below.

I hope this helps.  Please 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

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/
Grateful but with some clarification still necessary:

Thank you very much

We didnt know if it was the size of the container or the quantity @ 118 gallons was the tipping point from ok to move tank vs haz mat and all safety to be followed.

Thanks again

Class 3 Combustible Placard on Cargo TankAnd me with some final guidance:

I understand the confusion.  A bulk packaging is defined by the capacity of the packaging, not what it actually holds.  The threshold for a bulk packaging is one with a capacity of more than 119 gallons.

Please let me know if I can be of any further assistance.

Perhaps some of your employee require HazMat Employee training?

Contact me anytime with questions.

Q&A: How can I ship a Class 3 Combustible Liquid by air?

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!

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/
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.

Q&A: How can I ship a combustible liquid by air?

A question from the regulated community (10.24.17):

Good afternoon Daniel. I am shipping a combustible liquid and wanted to know if I can ship overnight by air if it falls under excepted quantity. It has a flashpoint of 80 Celsius. Will it require dangerous goods paperwork and placarding? If under 500mL I can ship by excepted quantity without placarding and paperwork correct? If over 500mL would it have to go ground only? I do not see combustibles in section 4.2 in the IATA book.

Thanks for your help sir.

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

International and Domestic

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

I knew this was going to be a tough question to answer because it referenced a classification unique to the U.S. (Combustible Liquid), a complicated packaging exception (excepted quantity), and two distinct sets of regulations (the USDOT/PHMSA Hazardous Materials Regulations for transport within the U.S. and the IATA Dangerous Goods Regulations for transport by air).  So, I asked for more information and more time:

Thank you for contacting me.

This is a very tough question which is taking me some time to research. If you can provide some additional information, that would be helpful:

  • What is the material? Does it have a classification other than combustible liquid?
  • Is the maximum net quantity of the inner packaging no more than 30 g or 30 ml?
  • Is the maximum net quantity of the outer packaging no more than 500 g or 500 ml?

Thank you and please advise.

He replied the next day (10.25.17):

Here is the SDS (SDS was attached to the email). Inner packaging would be 500mL. Maximum net quantity of the outer packaging would be 500mL.

The following relevant data was obtained from the SDS:

  • Contains: 95% N-MethylAminoPropylTriMethOxySilane and <5% Methanol
  • Flash point: 82 °C (179.6 °F)
  • Section 14 indicates classification as UN1993, Combustible liquid, n.o.s.
  • No classification per international regulations (IATA or IMO) is indicated.
  • No other information in SDS indicates material meets defining criteria of other HazMat / dangerous good.

Ball was back in my court.  I replied later that day:

I think I have an answer for you. Please see below.

  • Based on the SDS it is a hazardous material (HazMat) as defined by USDOT/PHMSA as a Class 3 Combustible Liquid.
  • The international regulations – including IATA – do not have a classification for, and do not regulate, a Combustible Liquid. Therefore, this material is not regulated per IATA.
  • 49 CFR 171.22(c) of the Hazardous Materials Regulations (HMR) requires a HazMat not subject to international regulations – e.g., a Class 3 Combustible Liquid – be subject to the HMR when transported to, from, or through the U.S. regardless of international regulations. This USDOT letter of interpretation confirms it (LOI 13-0020).
  • A Combustible Liquid transported within the U.S. is subject to the combustible liquid exception if it is not transported in a bulk packaging and is not classified as a hazardous substance, hazardous waste, or marine pollutant.  Based on the information provided I presume this HazMat is none of those.
  • To be be eligible as an excepted quantity per USDOT/PHMSA and IATA regulations the maximum net quantity of the inner packaging must be no more than 30 g / 30 mL and the maximum net quantity of the outer packaging must be no more than 500 g / 500 mL. Based on your earlier email your HazMat exceeds the maximum net quantity for the inner packaging and therefore can’t be transported as an excepted quantity.

In summary:

Based on the information provided the material as described is not subject to the regulations of either USDOT/PHMSA or IATA when transported within the U.S. or internationally by any mode as long as the requirements of the Combustible Liquid Exception are met.

I hope this helps.

Please don’t hesitate to contact me with any other questions.

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That appeared to satisfy him.

Great! Thanks Daniel. Some of these chemicals can be tricky when shipping.

Conclusion:

The transport of a hazardous material (aka: dangerous good) within the U.S. while subject to international regulations can be a challenge! The classification of a Class 3 Combustible Liquid and the application of the Combustible Liquid Exception are only two examples where international and domestic regulations must be made to work together. Other shipping challenges include: marine pollutants, hazardous substances, & lithium cells or batteries to name a few.  And of course, all regulations require periodic training for applicable personnel to ensure knowledge and compliance.

Daniels Training Services, Inc.

815.821.1550

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Q&A: How may I transport red diesel in a frac tank?

Q&A: How may I transport red diesel in a frac tank?

A question from someone in the HazMat transportation business (06.02.17):

The company I work for hauls frac tanks recently we had a tank that was used to store red diesel heating oil when we went to pick up the tank there was a gallon or two residual left in tank are we allowed to transport the tank with residuals in it and do we need paper work and placards.

My attempt to buy some time that same day:

Please give me some time to research and provide an answer.

My reply eleven days later (06.13.17):

UN1993 in Intermediate Bulk Container

UN1993, Diesel fuel in an intermediate bulk container

Thank you for your patience.  I will try to answer your question.  Please see below.

  • I assume that red diesel meets the USDOT definition of a Class 3 Combustible Liquid.
  • If so, it is subject to the combustible liquid exception.
  • However, a bulk packaging (e.g. frac tank) is not subject to the full combustible liquid exception.
  • Unless rinsed, cleaned, & purged of all vapors, USDOT regulates a packaging with residue the same as if it was full.
  • Some non-bulk packagings are subject to the empty packaging exception.
  • A bulk packaging (e.g. frac tank) is not subject to the exception and if it contains any residue of a hazardous material must be transported in commerce as a fully-regulated HazMat.
  • A fully regulated bulk packaging transported in commerce requires placards, shipping paper, trained personnel, &etc.
I hope this helps.  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

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/
Q&A: Are my Deck Engines and Diesel Fuel Subject to the Hazardous Materials Regulations?

Q&A: Are my Deck Engines and Diesel Fuel Subject to the Hazardous Materials Regulations?

From the contact form on my website on December 9, 2016:

We have a trailer with two Deck Engines w/ a 400 Gal. Diesel Tank that supply’s Fuel to both engines.

Question 1. Do we have to Placard the on all for sides of the tank.

2. Does the driver need a Haz-mat Endorsement. Thanks.

(the email included a picture of a flat bed trailer hauling the deck engine and two intermediate bulk containers of diesel fuel.)

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

International and Domestic

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

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My reply December 11th:

Please see below:

  • Diesel fuel is classified as a Class 3 Combustible Liquid.
  • The diesel tanks on the trailer classify as a bulk packaging. The packaging is known as an IBC or Intermediate Bulk Container.
  • A bulk packaging of a combustible liquid is not subject to the exception at 49 CFR 173.150(f).
  • The requirements to use DOT specification packaging is not applicable to a bulk packaging of a Class 3 Combustible Liquid.
  • The placarding requirements of 49 CFR 172, subpart F do apply to this HazMat.
  • Per 49 CFR 172.514(c)(4) an IBC is required to display the applicable placards on two opposing sides. The 4-digit identification number must appear on or near the placard. Alternatively, the IBC may display HazMat labels and the proper shipping name and identification number on only one side.  Read:  HazMat Labels, Placards, and Marks on an IBC.
  • Per 49 CFR 172.504(a) each transport vehicle required to display placards (as in this situation) must display them on all four sides of the vehicle.
  • 49 CFR 172.516(a) requires the placards to be visible from the direction they face.
  • The placards on the IBCs may suffice to replace the required placards on the side of the truck that the placarded IBCs face. In short, if placards are displayed on the IBCs so that they are visible from all four sides of the vehicle, you can meet both requirements with the same 4 placards. A more conservative approach is the display placards or HazMat labels on the IBCs as required and also display placards on all four sides of the vehicle.

I hope this helps.

Please don’t hesitate to contact me with any other questions.

I guess that did it because I didn’t hear back from him.

Please feel free to contact me if you have any questions about the transportation of a combustible liquid.  See below for links to other articles for more information.

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

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/
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.

Q&A: Is a Shipping Paper Required for the Transport of Diesel Fuel in a 1,000 Gallon Cargo Tank?

HERE IS A QUESTION I RECEIVED THROUGH THE CONTACT ME PAGE OF MY WEBSITE.

Names and references to locations and companies have been changed to preserve anonymity.  Other minor editing changes have been made as well.

Subject: Help
Message: Hi Daniel,
My name is <<John Smith>> and I work for a construction company in a <<U.S. State>>. I drive a fuel/lube truck with a 1000 gallon diesel tank. I also haul engine, transmission, coolant, slop oil, and grease that are 100 gallons or less. I fuel off road construction equipment to our sites. My company does not or should I say certain individuals in the company do not know about HazMat DOT regulations.
What kind of shipping paper do I need? Would I need a permanent for diesel only or do I need to have the other chemicals listed as well?
I am personally getting the items I need from a well known company in this field. I purchased the orange book, placards 1993, and another HazMat book. I believe the company needs to have the HazMat Registration Permit also right. Please help. It seems I am alone with people who don’t know or don’t care. Call me, ###-###-####, so we can discuss this and perhaps if the price is right I would take one of your courses.
Respectfully for the cause,

AND HERE IS MY RESPONSE:

Thanks for contacting me. I’ll do my best to answer your questions.

First of all, diesel in the quantity and bulk packaging you describe is a hazardous material subject to the regulations of the USDOT when transported in commerce. Therefore, the following is required (at a minimum):

  • A shipping paper that describes the hazardous material (diesel) and any others you transport. A permanent diesel shipping paper would work as long as it is handled properly.
  • Placards on all four sides of the vehicle.
  • Markings on all fours sides of the vehicle: 1993, “Diesel”, or “Combustible”.
  • Emergency response information immediately available to the driver. The 2012 ERG is good for this. You must also have a 24 hour emergency response phone number.
  • The vehicle is a Commercial Motor Vehicle, subject to regulations for its operation on the highway. Depending on its weight, the driver may require a Commercial Driver’s License and be subject to hours-of-operation limits, &etc.
  • A placarded quantity of HazMat requires registration with the USDOT and payment of the fee.
  • Anyone involved in the transportation of the HazMat (not just the driver) must receive initial and triennial (every 3 years) HazMat Employee Training. Drivers require an additional component to HazMat Employee Training to include operation of the vehicle.

The other materials you mention may not be hazardous materials (or they might!). It is up to the Shipper to determine if a material is hazardous or not and therefore subject to the regulations.

You are right to be concerned about compliance issues at your company. I’d be happy to answer any other questions you may have.

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

International and Domestic

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

The White Bottom Placard for Combustible Liquids

In general, there are two ways in which a material may be classified as a Combustible Liquid (Hazard Class 3) pursuant to the regulations of the PHMSA/USDOT; they are:

  • It does not meet the definition of any other hazard class and its flash point is above 60 °C (140 °F) and below 93 °C (200 °F).

Or…

  • It meets the definition of a Flammable Liquid with a flash point of ≥100˚F and ≤140˚F and the shipper elects to classify it as a Combustible Liquid.

Read more about both of these options here:  The Classification of a Flammable Liquid and a Combustible Liquid

The transportation in commerce of a Combustible Liquid presents an interesting option when determining the placards to display on a motor vehicle or rail car. (more…)

Flash Point for Classification of US DOT Flammable and Combustible Liquids

Flash Point is a term used by the US EPA when characterizing an Ignitable Hazardous Waste and the US DOT when classifying a Flammable or Combustible Liquid.  Though similar, there are differences in how these two Federal agencies define and describe this term.  If you work with solvent, inks, paints, resins, fuels, or many other organic hydrocarbons it is necessary for you to be familiar with how both the US DOT and the US EPA identify this term and its role in identifying a hazardous material or a hazardous waste.  The purpose of this article is to describe the use of the Flash Point for classifying a Flammable or Combustible Liquid per the regulations of the US DOT.  You may also be interested in the US EPA’s use of Flash Point for the Determination of a Characteristic Ignitable Liquid Hazardous Waste.

The US DOT defines Flash Point at 49 CFR 173.120(c)(1):  “Flash Point means the minimum temperature at which a liquid gives off vapor within a test vessel in sufficient concentration to form an ignitable mixture with air near the surface of the liquid.”  It goes on to describe the methods to determine Flash Point based on the characteristics of the sample:

1.  For a homogeneous, single-phase, liquid having a viscosity <45 S.U.S. at 38°C (100°F) that does not form a surface film while under test, one of the following test procedures shall be used:

    • Standard Method of Test for Flash Point by Tag Closed Cup Tester, (ASTM D 56) (IBR; see §171.7 of this subchapter).
    • Standard Test Methods for Flash Point of Liquids by Small Scale Closed-Cup Apparatus, (ASTM D 3278) (IBR; see §171.7 of this subchapter).
    • Standard Test Methods for Flash Point by Small Scale Closed Tester, (ASTM D 3828) (IBR; see §171.7 of this subchapter).

2.  For a liquid other than one meeting all the criteria of #1 above, one of the following test procedures must be used:

    • Standard Test Methods for Flash Point by Pensky-Martens Closed Cup Tester, (ASTM D 93) (IBR; see §171.7 of this subchapter).  For cutback asphalt, use Method B of ASTM D 93 or alternative tests authorized in this standard.
    • Standard Test Methods for Flash Point of Liquids by Small Scale Closed-Cup Appartus (ASTM D 3279) (IBR; see §171.7 of this subchapter).
    • Determination of Flash/No Flash – Closed Cup Equilibrium Method (ISO 1516) (IBR; see §171.7 of this subchapter).
    • Determination of Flash Point – Closed Cup Equilibrium Method (ISO 1523) (IBR; see §171.7 of this subchapter).
    • Determination of Flash Point – Pensky-Martens Closed Cup Method (ISO 2719) (IBR; see §171.7 of this subchapter).
    • Determination of Flash Point – Rapid Equilibrium Closed Cup Method (ISO 3679) (IBR; see §171.7 of this subchapter).
    • Determination of Flash/No Flash – Rapid Equilibrium Closed Cup Method (ISO 3680) (IBR; see §171.7 of this subchapter).
    • Determination of Flash Point – Abel Closed-Cup Method (ISO 13736) (IBR; see §171.7 of this subchapter).

3.  If the liquid is a mixture of compounds with different volatility and Flash Points (eg. mixed solvents and paint), its Flash Point must be determined by one of the methods in #’s 1 & 2 above on the material in the form in which it is to be shipped.  Note that the form it is to be shipped in may differ from the form in which is was received as product or its form at its point of generation as a hazardous waste.  If by this test the Flash Point is greater than -7°C (20°F), then a second test shall be made by the procedure described in §173.120(c)(2) which is too complicated for me to describe here.

4.  And one final thing:  for Flash Point determinations by Setaflash closed tester, the glass syringe specified need not be used as the method of measurement of the test sample if a minimum quantity of 2 mL (0.1 oz) is assured in the test cup.

These are just the regulations of the US DOT pertaining to the determination of one class of hazardous material:  Flammable and Combustible Liquids.  There are many more, and you must be familiar with all of them if you ship or receive hazardous materials in any quantity, including hazardous waste.  My one day of training addresses the regulations of both the US DOT and the US EPA, it will help you to properly classify your hazardous materials and identify your hazardous waste.  Contact me to schedule the right kind of training for you.