Shipment of Non-bulk Quantities of Fuel
Pipeline and Hazardous Materials Safety Administration · Mar 26, 1998 · Reference No. 98-0519
Reggie’s quick take
Someone asked whether training requirements apply to non-bulk shipments of aviation turbine fuel (UN 1863) if the fuel is reclassified as a combustible liquid. The agency said that for transport by modes other than vessel or aircraft, the fuel may be reclassified as a combustible liquid under § 173.120(b). Under § 173.150(f)(2), a combustible liquid in non-bulk packages (450 L or less, or 400 kg net mass or less) is not subject to the Hazardous Materials Regulations. So the Part 172, Subpart H training requirements would not apply in that case. If the fuel moves by aircraft, it cannot be reclassified unless other transport is impracticable, so the regulations and training requirements still apply.
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 of March 4, 1998, concerning the shipment of non-bulk quantities of Fuel, aviation, turbine engine, UN 1863. In your letter you asked whether training requirements apply to the shipment of this material if it is reclassified as a combustible liquid.
For transport by a mode other than vessel or aircraft, the material may be reclassified as a combustible liquid in accordance with 49 CFR 173.120(b). In accordance with 49 CFR 173.150(f)(2), a combustible liquid is not subject to the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180), when shipped in non-bulk packages (i.e. a maximum capacity of 450 L or a maximum net mass of 400 kg). As the training requirements found in 49 CFR, Part 172, Subpart H apply only to persons handling materials which are subject to the HMR, they would not apply if the material is reclassified as a combustible liquid and transported in non-bulk quantities. However, if the material is transported by aircraft, it may not be reclassified as a combustible liquid unless transportation by other means is impracticable and would, therefore, be subject to the regulations, including the training requirements.
With regard to samples transported by your agency's employees, the transportation of a hazardous material by a Federal government employee for non-commercial purposes in a privately-owned or government-owned vehicle is not subject to the HMR.
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.