For FLambable, label 454 kg (1,001 pounds) or more. Gasoline can be used instead of the flammable plaque shown in a cargo tank or portable transport tank. The limit for placing these hazardous materials on signs is 454 kg (1,001 pounds). Regulations related to the transportation of combustible liquids may pose a tangible safety problem, such as the handling or misidentification of these shipments during transportation, or the transportation of undeclared shipments.
The recommendations of the United Nations, the technical instructions of the International Civil Aviation Organization for the safe transport of dangerous goods by air (ICAO technical instructions) or the International Maritime Dangerous Goods Code (IMDG) do not contain any provision allowing flammable liquids to be reclassified as combustible liquids. Most commentators also don't support the requirement that all combustible liquids be described as “combustible liquid”. Adopt a new brand for combustible liquids, designed to pass through international customs facilities without causing frustration and, at the same time, communicating emergency information. This would directly respond to the concerns of IVODGA and DGAC, but it may not maintain an adequate level of safety in relation to the domestic transport of these materials. The NFPA is concerned that the adoption of such a change in national requirements for offering and transporting combustible liquids will negatively affect the emergency response to incidents involving such materials.
However, these same materials are regulated as flammable liquids when transported by ship, in accordance with the International Maritime Dangerous Goods Code (IMDG), and by air, in accordance with the technical instructions of the International Civil Aviation Organization (ICAO technical instructions). Since this is an economic and safety issue, the PHMSA disagrees with those who advocate the total elimination of the class of combustible liquids, believing that a significant amount of nationally regulated materials pose transportation risks that cannot be ignored. To alleviate this problem, the DGAC requests that PHMSA exclude HFCL from all HMR requirements when transported in packages with specifications of less than 3000 liters (793 gallons) of capacity or when transported in an ISO (UN) portable tank in international trade. The NTTC firmly states that HMR must continue to allow Class 3 materials with a flash point between 38°C (100°F) and 60°C (140°F) to be reclassified and transported as combustible liquids. In addition, he states that this has been the practice for many years and is not aware of any negative impact on safety.
Commentators believe that a new brand to communicate the presence of combustible liquids would only increase confusion and increase the cost of retraining employees and staff. If the PHMSA were to eliminate the regulatory option for reclassified fuels, all commercial explosives companies operating MBT would be forced to seek a new SP or a modification of their existing SPs to request a specific exception to the classification of “flammable” for the transport of FO with flash points between 38°C (100°F) and 60°C (140°F). The IAFC said that, while deregulation of these materials would reduce problems in international trade and facilitate the movement of those products, it would eliminate important warnings for first responders about the presence of a combustible liquid.
