Using a company that doesn’t have experience in this industry can lead to many SDS sheets and product labels with hazmat warnings when many of these products, because they are both a consumer commodity and packaged in small containers, are exempt from this hazard classification for flammability. By having flash point testing done, we can determine if your products qualify for shipping exemptions for combustible liquids.
The shipping exemptions for combustible materials and limited quantities are as follows:
DOT – 49 CFR 173.120(a)(3)
- Class 3 Flammable Liquids Exemption
- CLASSIFICATION EXCEPTION UNDER U.S. REQUIREMENTS: Under U.S. shipping regulations, this material would otherwise be classified as a combustible liquid. However, pursuant to U.S. regulations at 49 CFR 173.120(a)(3) this material is not considered combustible under the following exceptions: any liquid with a flash point greater than 37.8°C (100°F) which does not sustain combustion under ASTM Standard D4206 is not considered to be a combustible liquid and which is in non-bulk packaging (max capacity of 119 gal (450L) or less for liquids or 882 lbs. (400 kg) or less for solids transported by motor vehicle, rail car, sea vessel or aircraft.
ADR – European Agreement – concerning the International Carriage of Dangerous Goods by Road – Volume 1 – Jan. 1 2015 – 2.2.3.1
- Class 3 Flammable Liquids Exemption.
- Substances which have a flashpoint above 35°C, which do not sustain combustion according to the criteria of sub-section 32.2.5 of Part III of the Manual of Tests and Criteria, are not substance of Class 3; if, however these substances are handed over for carriage and carried whilst heated at temperatures equal to or higher than their flashpoint, they are substances of Class 3.
IMDG Code (Amdt. 43-08) – 2.3.1.3
- Class 3 Flammable Liquids Exemption
- The provisions of the Code need not apply to such liquids with a flashpoint of more than 35°C which do not sustain combustion. Liquids are considered to be unable to sustain combustion for the purposes of the Code if:
- They have passed the suitable combustibility test (see the Sustained Combustibility Test prescribed in part iii, 32.5.2 of the United Nations Manual of Tests and Criteria); or
- Their fire point according to ISO 2592:1973 is greater than 100°C; or
- They are water-miscible solutions with a water content of more than 90%, by mass.
IATA – Dangerous Goods Regulations- 57th Edition January 1, 2016 – 3.3.1.3
- Class 3 Flammable Liquids Exemption
- Liquids described in 3.3.1.2 with a flashpoint exceeding 35°C which do not sustain combustion need not be considered as flammable liquids for the purposes of these regulations, if:
- They have passed the suitable combustibility test (see the Sustained Combustibility Test prescribed in part III, 32.5.2 of the United Nations Manual of Tests and Criteria); or
- Their fire point according to ISO 2592:1973 is greater than 100°C; or
- They are water-miscible solutions with a water content of more than 90% by weight.
We have written thousands of SDS (Safety Data Sheets) for the Essential Oils and Fragrance Industries over the years. Call on MSDS Authoring Services to help you with SDS services.