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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 #99-0305 ([U.S. Department of Transportation] [Mr. John D. Steinhoff])

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

Interpretation Response Details

Response Publish Date:

Company Name: U.S. Department of Transportation

Individual Name: Mr. John D. Steinhoff

Location State: MD Country: US

View the Interpretation Document

Response text:

December 9, 1999


Mr. John D. Steinhoff                 Ref. No. 99-0305
U.S. Department of Transportation
Office of Motor Carrier Safety
City Crescent Building, Suite 4000
10 S. Howard Street
Baltimore, MD 21201

Dear Mr. Steinhoff:

This is in response to your letter dated November 2, 1999, regarding the proper shipping description for gas oil under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you asked which of the following are proper shipping descriptions for gas oil:

(1)   Gas oil, 3, UN1202, III
(2)   Gas oil, Combustible liquid, UN1202, III
(3)   Gas oil, 3, Combustible liquid, UN1202, III
(4)   Combustible liquid, n.o.s., (Gas oil), UN1202, III

Description (1) is correct.  The proper shipping description for gas oil specified in the Hazardous Materials Table (HMR; § 172.101) is Gas oil, 3, UN1202, PG III." Description (2) is appropriate if the gas oil is reclassed as a combustible liquid in accordance with § 173.150(f). When a material is reclassed in accordance with § 173.150(f), each reference to Class 3 is modified to read “Combustible liquid”( (§ 172-101(d)(4)).

Description (3) is incorrect.  Two hazard classes have been identified; Hazard class 3 (Flammable liquid) and Combustible liquid.  While § 172.202(a)(2) allows shippers to enter a subsidiary class name, subsidiary class or division number following the numerical hazard class, combustible liquid can not be a subsidiary of a flammable liquid.  Description (4) is also incorrect.  Section 172.101(d)(4) allows the hazard class to be modified from '3" to 'Combustible liquid," but does not authorize modification of the proper shipping name.  In addition, UN1202 is not the correct identification number for the proper shipping name "Combustible liquid, n.o.s."

I hope this satisfies your request.



John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table