Combustible liquid (solvent waste) in non-bulk packaging
Pipeline and Hazardous Materials Safety Administration · Dec 11, 2008 · Reference No. 08-0263
Interprets: 49 CFR § 173.150(f)(2)
Reggie’s quick take
A company that ships solvent waste asked whether the §173.150 exceptions cover its shipments. The agency said that a combustible liquid in non-bulk packaging is not covered by the HMR under §173.150(f)(2), unless it is a hazardous substance, a hazardous waste, or a marine pollutant. So the HMR do not apply to the company's shipment of non-hazardous solvent waste in non-bulk packaging. The agency also said that shipments under 1000 pounds of hazardous waste in non-bulk packaging, with no other hazard class, are excepted from placarding, registration, and security plan rules, but must still meet the training rules in Subpart H of Part 172.
Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.
This responds to your October 17, 2008 letter requesting clarification on the §173.150 exceptions in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether the exceptions apply to your client's shipping operations.
According to your letter, your client ships a combustible liquid (solvent waste) that does not meet the definition of a hazardous waste in non- bulk packaging. You request confirmation that this shipment of combustible liquid as well as shipments of less than 1000 pounds of hazardous waste in non-bulk packaging, are excepted from placarding, training, registration, and security requirements.
Under §173.150(f)(2), the HMR do not apply to a material classed as a combustible liquid in a non-bulk packaging unless the combustible liquid is a hazardous substance, a hazardous waste, or a marine pollutant. Therefore, the HMR do not apply to your shipment of non-hazardous waste combustible liquid in non-bulk packaging.
Shipments of less than 1000 pounds of hazardous waste in non-bulk packaging that do not meet the definition of any other hazard class are excepted from placarding, registration, and security plan requirements. However, the training requirements in Subpart H of Part 172 do apply to such shipments.
A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.