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Interpretation Response #98-0519 ([The Defense Contract Management Command] [Ms. Jill E. Pettibone])

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

Interpretation Response Details

Response Publish Date:

Company Name: The Defense Contract Management Command

Individual Name: Ms. Jill E. Pettibone

Location State: VA Country: US

View the Interpretation Document

Response text:

MAR 26, 1998


Ms. Jill E. Pettibone
Executive Director
Contract Management Policy
Defense Logistics Agency
The Defense Contract ManagementCommand
8725 John J. Kingman Road, Suite 2533
Ft Belvoir, VA 22060-6221

Dear Ms. Pettibone:

This is in response to your letter of March 4, 1998, concerning the shipment of non-bulk quantities of Fuel, aviation, turbine engine, UN 1863. In your letter you asked whether training requirements apply to the shipment of this material if it is reclassified as a combustible liquid.

For transport by a mode other than vessel or aircraft, the material may be reclassified as a combustible liquid in accordance with 49 CFR 173.120(b). In accordance with 49 CFR 173.150(£)(2), a combustible liquid is not subject to the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180), when shipped in non-bulk packages (i.e, a maximum capacity of 450 L or a maximum net mass of 400 kg). As the training requirements found in 49 CFR, Part 172, Subpart H apply only to persons handling materials which are subject to the HMR, they would not apply if the material is reclassified as a combustible liquid and transported in non-bulk quantities. However, if the material is transported by aircraft, it may not be reclassified as a combustible liquid unless transportation by other means is impracticable and would, therefore, be. subject to the regulations, including the training requirements.

With regard to samples transported by your agency's employees, the transportation of a hazardous material by a Federal government employee for non-commercial purposes in a privately-owned or government-owned vehicle is not subject to the HMR.

I trust this satisfies your inquiry. If we can be of further assistance, please do not hesitate to contact us.



Edward T. Muzzullo
Director, Office of Hazardous
Materials Standards

Regulation Sections

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