IT’S A COMBUSTIBLE SITUATION
We are all getting less. Companies don’t charge more, they just reduce the amount they use to provide. It's called Shrinkflation. Chocolate bars from 100 to 90 grams, breakfast cereal boxes the same size, less contents. Toilet paper rolls have less sheets. Household cleaning solutions and laundry detergents packaging contain less liquid.
So too, as with the 49 Code of Federal Regulations, (CFR) Department of Transportation, (DOT) Pipeline and Hazardous Material Safety Administration, (PHMSA) Hazardous Materials Regulations (HMR) who is allowing shippers of hazardous materials and waste to reduce the size of the Class 3 Combustible Liquid placard for use on Intermediately Bulk Containers, (IBC’s) and Portable Tanks.
Combustible liquids are defined by the DOT as liquids that have a flash point at or above 100°F (37.8°C) and below 200°F (93.3°C). The flash point of a liquid is the lowest temperature at which it can vaporize to form an ignitable mixture in air near the surface of the liquid (per ChatGPT).
If the new smaller combustible liquid placard were a combustible liquid label there would be no need for the revision as PHMSA already authorizes the use of labels on IBCs in place of placards per 172.514(c).
There is a lot of misunderstanding around combustible liquid regulations as the international community does not regulate combustible liquids, unless they flash above 100°F up to 140°, but as Class 3 Flammable Liquids. When they flash over 140°F up to 200°F neither the United Nations, (UN), the International Maritime Organization (IMO) or the International Civil Aviation Organization,(ICAO) recognize domestic DOT combustible liquids as dangerous goods, because of their extremely high flashpoints, only DOT.
If a liquid flashes between 100°F and 140°F it could be flammable or combustible. But, if it flashes above 140°F up to 200°F in a bulk container, it is only combustible (per DOT).
Add to the confusion, DOT allows the reclassification of both bulk and non-bulk containers of flammable liquids flashing above 100°F, to combustible liquids under 173.120(b)(1) and 173.150(f)(2) based on the prior combustible definition. The PHMSA does not regulate non-bulk containers of combustible liquids. That’s why there’s no combustible label under 173.150(f)(2), only the combustible placard for bulk containers.
PHMSA has also revised 172.514(c)(1) and (4) to allow portable tanks containing combustible liquids to be placarded with a combustible placard that meets the label size specifications in 172.407(c).
Your UN/ID Identification number options are on the orange panel, inside the placard, or on a square on square point. Unless you meet the marking requirements in 172.301(a)(1), for non-bulk container markings, which would then include the proper shipping name, in addition to the UN/ID identification number.
Don’t use the new smaller label size combustible liquid placard on your trucks or trailers as they are not authorized. The IBC’s and portable tanks can use the label size combustible liquid placard with the proper shipping name and UN/ID Identification number on two opposite sides, however all four sides of the truck would be required to have the full size combustible liquid placard under 172.504(a) and the UN/ID Identification numbers under 172.302 (b).
To be sure some people will wrongly believe that there is a new combustible liquid label and that DOT has started to regulate combustible liquids in non-bulk containers. Download the final rule and check the federal register regularly to prepare for any proposed and final rules in the future. If you have a comment or input on my blogs, a question about hazardous materials, hazardous wastes or hazardous substances regulations please feel free to contact us and we won't charge you at all.
Thank you for your support.
Robert J. Keegan
Publisher and President
Hazardous Materials Publishing Company
Transportation Skills Programs Inc
610-587-3978
www.hazmat-tsp.com
