Interpretation Response #00-0121 ([Eveready Products Corporation] [Mr. Sam Vandivort])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Eveready Products Corporation
Individual Name: Mr. Sam Vandivort
Location State: OH Country: US
View the Interpretation Document
Response text:
May 24, 2000
Mr. Sam Vandivort Ref. No. 00-0121
Eveready Products Corporation
1101 Belt Line Street
Cleveland, OH 44109-2896
Dear Mr. Vandivort:
This is in response to your letter dated April 6, 2000 regarding the transportation of a combustible liquid in a non-bulk packaging under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if a material reclassed as a combustible liquid in accordance with §173.150(f)(1) is subject to the marking, labeling, placarding, and shipping paper requirements of the HMR when transported in non-bulk packagings.
Section 173.150(f)(1) provides that shippers may reclass a flammable liquid as a combustible liquid if the material's flashpoint is at or above 38°C (100°F) and does not meet the definition of any other hazard class. This exception is for domestic transportation and does not apply to transportation by vessel or aircraft, except where other means of transportation is impracticable.
In accordance with §173.150(f)(2), a combustible liquid transported in a non-bulk packaging is not subject to the HMR unless it is a hazardous substance, a hazardous waste, or a marine pollutant.
I hope this satisfies your request.
Sincerely,
John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards
173.150
Regulation Sections
| Section | Subject |
|---|---|
| 173.150 | Exceptions for Class 3 (flammable and combustible liquids) |