PHMSA letter of interpretation

Classification of Kerosene Mixtures

Pipeline and Hazardous Materials Safety Administration · Jul 31, 1997 · Reference No. 97-0189

PHMSA says to use caution with this letter.

Interprets: 49 CFR § 173.150

Reggie’s quick take

Someone asked how to ship a kerosene mixture with a 120 to 135°F flash point that contains other hazardous materials. The agency says it can be reclassed as a combustible liquid, since flash points of 100°F or higher qualify if the material meets no other hazard class (§§ 173.120(b)(2), 173.150(f)). Being a hazardous substance, hazardous waste, or marine pollutant does not bar this. The shipping name is "Combustible liquid, n.o.s. (kerosene), UN 1993, PG III."

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 is in response to your letter dated May 15, 1997, requesting clarification on the proper shipping description for a kerosene mixture containing other hazardous materials with a flashpoint of 120 - 135°F that has been reclassified to a combustible liquid under §§ 173.120(b)(2) and 173.150(f) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

Shippers are permitted to reclassify a flammable liquid as "combustible" if its flash point is at or above 100°F, if that material meets no other hazard class in accordance with §§ 173.120(b)(2) and 173.150(f). The fact that a hazardous material may be a hazardous substance, hazardous waste, or marine pollutant does not disqualify it from reclassification.. The proper shipping description for your kerosene mixture would be a generic or n.o.s. description corresponding to the hazard class of the material. For example, if the mixture has a flashpoint below 100°F, the appropriate generic proper shipping name would be "Flammable liquid, n.o.s:"; if the flashpoint is at or above 100°F but below 200°F, the mixture described in your letter would be described using the proper shipping name "Combustible liquid, n.o.s.", The hazard class need not be included for the entry "Combustible liquid, n.o.s."., as prescribed in § 172.202(a)(2).

Therefore, the proper shipping description for your reclassed material is: "Combustible liquid, n.o.s. (kerosene), UN 1993, PG III".

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.