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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #08-0066 ([Montana Motor Carrier Services Enforcement Division] [Lt. Jeff McLaughlin])

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

Interpretation Response Details

Response Publish Date:

Company Name: Montana Motor Carrier Services Enforcement Division

Individual Name: Lt. Jeff McLaughlin

Location State: MT Country: US

View the Interpretation Document

Response text:

March 17, 2008


Lt. Jeff McLaughlin

Montana Motor Carrier Services Enforcement Division

2550 Prospect Ave

Helena, MT 59620

Ref. No.: 08-0066

Dear Lt. McLaughlin:

This is in response to your letter dated March 7, 2008, concerning requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of combustible liquids in non-bulk packages. Specifically, you ask if there must be documentation 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.

As you are aware, a flammable liquid with a flash point of 38°C (100°F) or higher that does not meet the definition of any other hazard class may be reclassed as a combustible liquid, as provided by §§ 173.120(b)(2) and 173.150(f)(1). In addition, under § 173.150(f)(2), a combustible liquid, that is not a hazardous substance, hazardous waste, or a marine pollutant and is packaged in a non-bulk packaging, i.e., a packaging having a liquid capacity of 450 L (119 gallons) or less, is not subject to any other requirements in the HMR. Therefore, a combustible liquid, even if it has been reclassed from a flammable liquid to a combustible liquid, does not require special packagings, markings, or documentation.

I hope this information is helpful. Please contact us if you require additional assistance.


John A. Gale

Chief, Standards Development

Office of Hazardous Materials Standards

173.120(b)(2) 173.150(f)(1)

Regulation Sections

Section Subject
173.120 Class 3-Definitions
173.150 Exceptions for Class 3 (flammable and combustible liquids)