Interpretation Response #25-0024
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Buckeye Partners, L.P.
Individual Name: Mark Bonenberger
Location State: PA Country: US
View the Interpretation Document
Response text:
June 5, 2025
Mark Bonenberger
Program Manager
Buckeye Partners, L.P.
6161 Hamilton, Blvd.
Allentown, PA 18106
Reference No. 25-0024
Dear Mr. Bonenberger:
This letter is in response to your February 27, 2025 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to reclassifying a flammable liquid to a combustible liquid. Specifically, you state that your company transports aviation fuel (i.e., jet fuel) throughout the United States and Canada by cargo tank motor vehicle. You understand that according to the requirements in §§ 173.150(f)(1) and 172.332(c)(4), the HMR permits the reclassification of a flammable liquid to a combustible liquid and the use of a combustible placard, respectively.
We have paraphrased and answered your questions as follows:
Q1. Can jet fuel with a flash point at or above 38 °C (100 °F), not meeting the definition of any hazard class, and transported in a cargo tank motor vehicle, be described as "UN1863, Fuel, aviation, turbine engine, Combustible liquid, PG III?"
A1. Yes. Please note that, in accordance with § 173.150(f)(3) of the HMR, a combustible liquid in a bulk packaging is not subject to the requirements of the HMR, except for those requirements listed in § 173.150(f)(3)(i) through (f)(3)(xi).
Q2. Can the United Nations identification number be displayed on a COMBUSTIBLE placard conforming to either § 172.332(c)(1) and (c)(2) or § 172.332(c)(4) of the HMR?
A2. Yes. Both types of placards are permitted for display of the identification number on a cargo tank motor vehicle. However, please note that a COMBUSTIBLE placard with a white background as described in § 172.332(c)(4) of the HMR for display of the identification number must be used during rail transportation but may be used during highway transportation.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
§ 172.332(c)(1), § 172.332(c)(2), § 172.332(c)(4), § 173.150(f)(1), § 173.150(f)(3), § 173.150(f)(3)(i), § 173.150(f)(3)(xi)