Compliance Just Got Easier: Stay ahead of regulatory changes with instant notifications on updates that matter.
['Hazmat']
['Combustible liquids - Hazmat', 'Exceptions - Hazmat']
12/01/2023
Copyright 2026 J. J. Keller & Associate, Inc. For re-use options please contact copyright@jjkeller.com or call 800-558-5011.
InstituteInterpretations SpotlightExceptions - HazmatTransportationHazmat SafetyHazmat EdgeHazmatCombustible liquids - HazmatEnglishAnalysisFocus AreaUSA
Combustible Liquid Exception for Non-bulk Packaging
Regulation
Regulation summary
Section 173.150(f)(2) establishes the exception to the Hazardous Materials Regulations for combustible liquids in a non-bulk packaging.
Question/Dilemma
In this scenario, a tank manufacturer inquires if multiple non-bulk tanks, containing diesel fuel, that are connected using piping would meet the combustible liquid exception for non-bulk packages. Each tank outlet would have its own ball valve capable of isolating each tank.
In this interpretation, PHMSA addresses the definition and applicability of non-bulk packages of combustible liquids.
Interpretation summary
In interpretation Ref. No. 21-0001, PHMSA advises that if the ball valves separating the individual tanks are in a closed position while in transportation, they would meet the requirements for the combustible liquid exception in a non-bulk packaging. However, if there are no stop valves on each individual outlet preventing the flow of lading between tanks, and free flow between tanks is allowed during transportation, then the tanks would be considered a single bulk package and the requirements of 173.150(f)(3) would apply, including marking and placarding.
hazmat
Hazmat
HAZMAT EDGE
Combustible Liquid Exception for Non-bulk Packaging
Regulation
Regulation summary
Section 173.150(f)(2) establishes the exception to the Hazardous Materials Regulations for combustible liquids in a non-bulk packaging.
Question/Dilemma
In this scenario, a tank manufacturer inquires if multiple non-bulk tanks, containing diesel fuel, that are connected using piping would meet the combustible liquid exception for non-bulk packages. Each tank outlet would have its own ball valve capable of isolating each tank.
In this interpretation, PHMSA addresses the definition and applicability of non-bulk packages of combustible liquids.
Interpretation summary
In interpretation Ref. No. 21-0001, PHMSA advises that if the ball valves separating the individual tanks are in a closed position while in transportation, they would meet the requirements for the combustible liquid exception in a non-bulk packaging. However, if there are no stop valves on each individual outlet preventing the flow of lading between tanks, and free flow between tanks is allowed during transportation, then the tanks would be considered a single bulk package and the requirements of 173.150(f)(3) would apply, including marking and placarding.
Answer
UPGRADE TO CONTINUE READING
J. J. Keller is the trusted source for DOT / Transportation, OSHA / Workplace Safety, Human Resources, Construction Safety and Hazmat / Hazardous Materials regulation compliance products and services. J. J. Keller helps you increase safety awareness, reduce risk, follow best practices, improve safety training, and stay current with changing regulations.
Copyright 2026 J. J. Keller & Associate, Inc. For re-use options please contact copyright@jjkeller.com or call 800-558-5011.