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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 #15-0187R ([Florida Highway Patrol] [Lieutenant Bryan Gay])

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

Interpretation Response Details

Response Publish Date:

Company Name: Florida Highway Patrol

Individual Name: Lieutenant Bryan Gay

Location State: FL Country: US

View the Interpretation Document

Response text:

December 21, 2016

Lieutenant Bryan Gay
Florida Highway Patrol
6030 County Road 2321
Panama City, FL  32404

Reference No. 15-0187R

Dear Lieutenant Gay:

This letter is a response to your September 14, 2015, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the shipping description of diesel fuel reclassified as a “combustible liquid.”  This letter is an additional clarification revision to interpretation letter 15-0187 published on February 8, 2016.  In your original incoming letter, you note that § 172.202(a)(3)(ii) states the hazard class need not be included for the entry “Combustible liquid, n.o.s.”  You further list two proper shipping descriptions for diesel fuel reclassified as a combustible liquid:

1) NA1993, Diesel Fuel, Combustible liquid, PG III

2) NA1993, Combustible Liquid n.o.s. (diesel fuel), Combustible liquid, PG III

You ask if the shipping description “NA1993, Combustible liquid n.o.s.” must be used when taking the exception in § 172.202(a)(3)(ii) and which of the previously-listed shipping descriptions is correct.

For additional clarification, in accordance with § 172.202(a)(3)(ii) of the HMR, the hazard class need not be included for the entry “Combustible liquid, n.o.s.”  While this exception is specific only to the “Combustible liquid n.o.s.” shipping description, § 172.101(d)(4) specifies that a Class 3 material can be modified to read “combustible liquid” when that material is reclassified in accordance with § 173.150(e) or (f).  

Further, using the listing provided, shipping description number 1 would be appropriate for diesel fuel reclassified as a combustible liquid.  It should be noted that “UN1202, Diesel Fuel, Combustible liquid, PG III” may also be used as an alternative description.

I hope this information is helpful.  Please contact us if we can be of further assistance.


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

172.202(a)(3)(ii), 172.101(d)(4), 173.150(e) or (f)

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
172.202 Description of hazardous material on shipping papers
173.150 Exceptions for Class 3 (flammable and combustible liquids)