It is your understanding that although § 173.150 authorizes an exception in order to reclassify a flammable liquid with a flashpoint at or above 100☏ to a combustible, describing the material as flammable does not diminish the intent of the HMR and could provide a higher level of packaging protection and a higher level of emergency response in the event of an incident. In your letter, you state you intend to reclassify and rename a combustible liquid (NA1993, Combustible liquid, PG III) as a flammable liquid (UN1993, Flammable liquid, PG III) material. Specifically, you ask about classification of material to a more stringent classification and classification of a non-hazardous material as hazardous. This responds to your Marequest for clarification on combustible liquid material under the Hazardous Materials Regulations (HMR 49 CFR Parts 171-180). Interpretation Response Details Response Publish Date: 11-24-2014Ĭompany Name: Transportation Systems Solutions Below is the interpretation response detail and a list of regulations sections applicable to this response.
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