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Reclassifying combustible liquids

Regulation

173.150(f)

Regulation summary

Section 173.150(f) establishes the general requirements for flammable liquids reclassified as combustible liquids.

Question/Dilemma

In this scenario, a law enforcement agency inquires if documentation must be retained in the transport vehicle to serve as proof that a flammable liquid has been reclassed as a combustible liquid and is being shipped in accordance with the combustible liquid exception.

In this interpretation, PHMSA addresses the definition and applicability of reclassed combustible liquids.

Interpretation summary

In interpretation Ref. No. 08-0066, PHMSA advises that a flammable liquid with a flash point of 38℃ (100℉) or higher that does not meet the definition of any other hazard class may be reclassed as a combustible liquid.

  • A combustible liquid that is not a hazardous substance, hazardous waste, or a marine pollutant and is packaged in non-bulk packaging is not subject to any other requirements in the Hazardous Materials Regulations.
  • Therefore, a flammable liquid that has been reclassed to a combustible liquid does not require specials packagings, markings, or documentation.