Is a Combustible Liquid Reclassed as an ORM-D Subject to the Hazardous Materials Regulations?
Q. I am shipping a combustible liquid that has been renamed as a consumer commodity. There is a provision in the hazardous materials regulations stating combustible liquids shipped in non-bulk packaging are not subject to the hazardous materials regulations. Does my material still meet this exclusion even though it has been renamed a consumer commodity and reclassed as an ORM-D? A. Yes, a combustible liquid that is renamed consumer commodity and reclassed as an ORM-D is still eligible for exclusion from hazardous materials regulations. The provision of 49 CFR 173.150(c) states that certain combustible liquids “may be renamed ‘Consumer commodity’ and reclassed as ORM-D”. However, renaming the material as a consumer commodity is unnecessary and may make transporting the material more difficult. You can always choose not to reclass any particular shipment and instead to take advantage of the complete exclusion. The provision in 49 CFR 173.150(f)(2) states “the requirements in this subchap
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