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Mailing
Flammable and Combustible Liquids That Do Not Sustain Combustion
June 2008
PS-331 (601.10)
This
Customer Support Ruling (CSR) describes the conditions under which certain
flammable and combustible liquids that do not sustain combustion are
mailable.
The Domestic Mail Manual (DMM) and
Publication 52, Hazardous, Restricted
and Perishable Mail, define flammable or combustible liquids based
solely on their flash point.
Department of Transportation (DOT) and International Air Transport
Association (IATA) regulations allow shipping of these materials when they
do not sustain combustion as described below.
DOT
regulations are found in Title 49 of the Code of Federal Regulations (CFR). 49 CFR §173.120(a) defines a flammable
liquid as “a liquid having a flash point of not more than 60°C
(140°F). DOT lists several
exceptions, among them “(3) Any liquid with a flash point greater
than 35°C (95°F) that does not sustain combustion according to ASTM D
4206…or the procedure in Appendix H of this part” and
“(5) Any liquid with a flash point greater than 35°F (95°C) which is
in a water-miscible solution with a water content of more than 90 percent
by mass.” 49 CFR
§173.120(b)(1) defines a combustible liquid as “any liquid that does
not meet the definition of any other hazard class specified in this
subchapter and has a flash point above 60°C (140°F) and below 93°C
(200°F).” §173.120(b)(3)
further states that a “combustible liquid that does not sustain
combustion is not subject to the requirements of this subchapter as a
combustible liquid.”
IATA Dangerous
Goods Regulations § 3.3.1.3 provides that liquids “with a flash
point exceeding 35°C (95°F) which do not sustain combustion need not be
considered as flammable liquids for the purposes of these Regulations,
if…they have passed a suitable test for combustibility…or they
are miscible solutions with a water content of more than 90% by
weight.”
Liquids
that do not sustain combustion may be mailed when the mailer presents a
Material Safety Data Sheet (MSDS) that indicates its composition as a
water-miscible solution of more than 90% water and the solution is unable
to sustain combustion as indicated by standardized test ASTM D 4206. These factors preclude the liquid’s
classification as a flammable liquid under both DOT and IATA rules and
define it as not subject to DOT requirements as a combustible liquid. After consideration of all the factors,
the liquid is properly classified as a non-regulated material by DOT
standards and is not subject to the restrictions for flammable or
combustible liquids. The material is
still subject to the general packaging requirements for liquids in DMM
601.1 through 601.8 and in Publication 52, Hazardous, Restricted, and Perishable Mail, 226, 462, and 463.
Sharon Daniel
Manager
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