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Interpretation Response #14-0027 ([URS Corporation] [Mr. Andrew Romach])

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

Interpretation Response Details

Response Publish Date:

Company Name: URS Corporation

Individual Name: Mr. Andrew Romach

Location State: NC Country: US

View the Interpretation Document

Response text:

September 22, 2014

Mr. Andrew N. Romach
Regulatory Compliance Manager
URS Corporation
1600 Perimeter Park Drive
Morrisville, NC  27560

Ref. No.: 14-0027

Dear Mr. Romach:

This responds to your February 7, 2014 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers.  In your letter, you note that for transportation by water § 172.203(i)(2) requires the minimum flash point, if 60 °C (140 °F) or below (in °C closed cup (c.c.)) to be entered on the shipping paper in association with the basic description.  You ask whether this requirement applies to “UN3363, Dangerous Goods in Apparatus, 9” where the apparatus contains a flammable liquid with a minimum flashpoint of 60 °C (140 °F) or below?
The answer is yes.  The definition of flash point as provided in § 173.120(c)(1) is the minimum temperature at which a liquid gives off vapor within a test vessel in sufficient concentration to form an ignitable mixture with the air near the surface of the liquid.  Therefore, the HMR § 172.203(i)(2) requirement that for transportation by water, the minimum flash point must be entered on the shipping paper, applies only to liquids.  If the material in the apparatus is appropriately classed as Class 3 flammable liquid, the shipping paper flash point requirement does apply regardless of the fact that “UN3363” is assigned for the overall shipping description.
I trust this satisfies your inquiry.  Please contact us if we can be of further assistance.


T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

172.203(i)(2), 173.120(c)(1)

Regulation Sections

Section Subject
172.203 Additional description requirements
173.120 Class 3-Definitions