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Interpretation Response #06-0264 ([Intertek Caleb Brett] [Mr. William J. Cherepon])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Intertek Caleb Brett

Individual Name: Mr. William J. Cherepon

Location State: NJ Country: US

View the Interpretation Document

Response text:

Jan 11, 2007


Mr. William J. Cherepon               Reference No. 06-0264

Safety, Health and

Environmental Manager

Intertek Caleb Brett

1000 Port Carteret Road Building - C

Carteret, NJ 07008

Dear Mr. Cherepon:

This is in response to your November 9, 2006 letter regarding training as specified under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your scenario involves the shipment of flammable liquids that have been re-classed as combustible liquids in accordance with § 173.150(f)(1). Specifically, you ask if the training requirements apply to an employee who fills a package containing a combustible liquid that is not subject to the HMR.

The answer is no. For transport by a mode other than vessel or aircraft, a flammable liquid may be re-classed as a combustible liquid in accordance with § 173.150(f)(1) of the HMR.  In accordance with § 173.150(f)(2), a combustible liquid is not subject to the HMR when shipped in non-bulk packages (i.e. a maximum capacity of 450 L or a maximum net mass of 400 kg). Thus, the training requirements found in Part 172, Subpart H do not apply if the material is re-classed as a combustible liquid and transported in non-bulk quantities.

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.



Hattie Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials, Standards

172.704, 173.150 (f)

Regulation Sections

Section Subject
172.704 Training requirements
173.150 Exceptions for Class 3 (flammable and combustible liquids)