CCSB Contact: Lisa K. O Donnell Telephone (703) Item Description Class

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1 Re: Flammable or Combustible Liquids Hazard Class 3 CCSB Contact: Lisa K. O Donnell Telephone (703) odonnell@nmfta.org Proponent: Commodity Classification Standards Board Present Classification Provisions ADHESIVES GROUP: subject to item Adhesives, NOI, Adhesive Cements, NOI, Adhesive Glues, NOI, or Adhesive Pastes, NOI, other than toxic, see Note, item 4622: Sub 1 Combustible, in bulk containers holding 119 gallons or more; flammable; nonflammable gas; or corrosive; see Note, item 4623, in U.S. DOT authorized containers, subject to Item 170 and having a density in pounds per cubic foot of: Sub 2 Less than Sub 3 20 or greater Sub 4 Other than combustible in bulk containers holding 119 gallons or more, and other than flammable, nonflammable gas or corrosive, in bags, boxes, crates, drums, pails, intermediate bulk containers (IBCs), U.S. DOT specification portable tanks, or Packages 1398, 2213, 2399, 2440, 2445, 2452, 2458, 2463, 2467, 2478, 2496, 2499, 2500, 2515, 2516, 2521, 2526, 2528 or 2530, subject to Item 170 and having a density in pounds per cubic foot of: Sub 5 Less than Sub 6 20 or greater NOTE Not Involved NOTE Applies on materials regulated by the U.S. Department of Transportation as a Hazard Class 2, Division 2.1, Flammable Gas, or 2.2, Nonflammable Gas, as defined in 49 CFR ; Hazard Class 3, Flammable Liquid, as defined in 49 CFR ; or Hazard Class 8, Corrosive, as defined in 49 CFR ; and required to bear a notice to that effect on bills of lading and packaging. ASPHALT GROUP: subject to item Asphalt (Asphaltum), natural, by-product or petroleum, liquid, other than paint, stain or varnish, in containers in boxes or drums, in metal cans in crates, in pails, in bulk in drums, or in Package Tar, coal or petroleum, in metal cans in boxes or crates, or in pails, or in bulk in drums, see Note, item NOTE Will also apply on solid coal or petroleum tar, the melting point of which is over 140 degrees Fahrenheit, as determined by the Ball and Ring test in water or by the 1 /2 inch Cube test in water, when shipped in fiber drums Tar, NOI, in metal cans in boxes or crates, or in bulk in drums National Motor Freight Traffic Association, Inc. Subject 3, Page 1 of 30

2 Present Classification Provisions Continued BUILDING MATERIALS, MISCELLANEOUS, GROUP: subject to item Cement, Concrete or Masonry Waterproofing Compound, liquid or paste: Sub 1 In carboys, or in glass in boxes Sub 2 In metal cans in boxes or crates; in pails; in bulk in drums; or in Package CHEMICALS GROUP: see Notes, items and NOTE Not Involved NOTE 1. Materials regulated by the U.S. Department of Transportation that are required to bear any of the Hazard Class 6 or Hazard Division 6.1 labels listed below are subject to the provisions of item 45615, regardless of the DOT-designated Hazard Class or Hazard Division. (a) 'INHALATION HAZARD' (b) 'POISON' (c) 'TOXIC' (d) 'PG III' 2. Not Involved Acetaldehyde. See item for class dependent upon released value: Sub 1 In bulk in drums Sub 2 In inner containers in boxes, or in steel cylinders Sub 3 In carboys Acetone, NOI. See item for class dependent upon released value: Sub 1 In carboys Sub 2 In inner containers in boxes Sub 3 In bulk in drums or steel cylinders Acetonitrile, in boxes or drums. See item for class dependent upon released value Acrylate, butyl, ethyl, ethylhexyl, hydroxyethyl, hydroxypropyl, isobutyl or methyl, or Methyl Methacrylate Monomer, with inhibitor added, in drums Alcohols, other than alcoholic liquors and other than toxic: Alcohols, NOI; including Anhydrous Alcohol, not denatured. See item for class dependent upon released value: Sub 1 In carboys Sub 2 In inner containers in boxes, or in pails Sub 3 In bulk in drums or steel cylinders Alcohol, methallyl, in bulk in drums or steel cylinders Subject 3, Page 2 of National Motor Freight Traffic Association, Inc.

3 Present Classification Provisions Continued CHEMICALS GROUP: subject to item Alcohols, other than alcoholic liquors and other than toxic: subject to item Alcohol, amyl; Alcohol, butyl, including Butanol; Alcohol, decyl, hexadecyl, hexyl, tridecyl, or undecyl, other than perfumery grade; Alcohol, denatured, see Note, item 42704, liquid; Alcohol, denaturing, NOI, see Note, item 42692; Alcohol, isobutyl; Alcohol, isopropanol or propyl; Alcohol, octyl or isooctyl, other than perfumery grade; Alcohol, propargyl; Alcohol, tetrahydrofurfuryl; Alcohol, antifreeze, see Note, item 42694; Distillates, synthetic alcohol, see Note, item 42696; Fluid, spirit duplication machine, see Note, item 42703; Oil, fusel; Solvent, denatured alcohol, see Note, item 42698; Solvent, isopropyl alcohol, see Note, item 42699; Solvent, methanol, NOI, see Note, item 42702; See item for class dependent upon released value: Sub 1 In bulk in drums or steel cylinders Sub 2 In inner containers in boxes Sub 3 In carboys NOTE Provisions for denaturing alcohol, NOI, apply on denaturants for ethyl alcohol consisting of natural blends of synthetic alcohol distillates which have not been processed beyond separation and removal of the methanol content NOTE Applies only on alcohol or alcohols with or without inhibitor, prepared and represented as antifreeze alcohol NOTE Applies only on those distillates, obtained in the synthetic production of methyl alcohol, which consist of mixtures of various alcohols other than those specifically classed in the Classification NOTE Applies only on denatured alcohol solvent containing not less than 90 percent of denatured alcohol NOTE Applies only on isopropyl alcohol solvent containing not less than 90 percent of isopropyl alcohol NOTE Applies only on methanol solvent, NOI, containing not less than 90 percent of methanol NOTE Applies only on fluid containing not less than 80 percent of methanol NOTE Applies on denatured alcohol other than Specially Denatured Alcohol National Motor Freight Traffic Association, Inc. Subject 3, Page 3 of 30

4 Present Classification Provisions Continued CHEMICALS GROUP: subject to item Alcohols, other than alcoholic liquors and other than toxic: subject to item Denatured or Methanol (Methyl Alcohol), solidified, in glass or metal containers in boxes Methyl Isobutyl Carbinol: Sub 1 In inner containers in boxes Sub 2 In bulk in drums Amyl Acetate. See item for class dependent upon released value: Sub 1 In carboys Sub 2 In inner containers in boxes Sub 3 In bulk in drums or steel cylinders Aqueous Monomethylamine, Aqueous Dimethylamine, or Aqueous Trimethylamine, in drums Benzol (Benzene). See item for class dependent upon released value: Sub 1 In boxes or drums, or in steel cylinders Sub 2 In glass in boxes or drums Sub 3 In glass carboys Butyl Acetate. See item for class dependent upon released value: Sub 1 In inner containers in boxes Sub 2 In bulk in drums or Package Butyraldehyde. See item for class dependent upon released value: Sub 1 In glass carboys Sub 2 In inner containers in boxes Sub 3 In bulk in drums or steel cylinders Chemicals, NOI, see Note, item See item for class dependent upon released value: Sub 1 In glass carboys or Package Sub 2 In bags, boxes, drums or Packages 1439, 2258, 2419, 2456 or NOTE Not Involved Chloropentanes (Dichloropentanes, Trichloropentanes or Tetrachloropentanes). See item for class dependent upon released value: Sub 1 In boxes or drums Sub 2 In glass carboys Cyclohexane, in boxes or drums Dichloroethyl Ether. See item for class dependent upon released value: Sub 1 In containers in boxes or drums Sub 2 In bulk in drums Dichloroethylene, in drums or in inner containers in boxes Subject 3, Page 4 of National Motor Freight Traffic Association, Inc.

5 Present Classification Provisions Continued CHEMICALS GROUP: subject to item Diisobutyl Ketone: Sub 1 In inner containers in boxes Sub 2 In bulk in drums or steel cylinders Dyes or Colors, coal tar, other than indigo and other than toxic or corrosive materials, dry, liquid or paste, in boxes or drums, or dry, in Packages 1059, 1065 or See item for class dependent upon released value Ether, butyric. See item for class dependent upon released value: Sub 1 In inner containers in boxes Sub 2 In glass carboys Ether: Diethylene glycol dimethyl; Tetraethylene glycol dimethyl; Triethylene glycol dimethyl; In drums Ether, ethyl (Sulfuric Ether), anesthesia ether, in boxes or drums. See item for class dependent upon released value Ether, ethyl (Sulfuric Ether), other than anesthesia ether. See item for class dependent upon released value: Sub 1 In bulk in drums or steel cylinders Sub 2 In inner containers in boxes Sub 3 In glass carboys Ether, isopropyl, in boxes or drums Ethylbenzene (Ethylbenzol), Ethylbenzine, Polyethylbenzene, Polyethylbenzine or Diethylbenzene, in boxes or drums Ethylidene Aniline, in inner containers in boxes. See item for class dependent upon released value Formaldehyde, paste. See item for class dependent upon released value: Sub 1 In boxes or drums Sub 2 In metal holders in boxes or drums Formate, ethyl or methyl: Sub 1 In boxes, drums or steel cylinders Sub 2 In glass carboys Isobutyl Acetate. See item for class dependent upon released value: Sub 1 In bulk in drums Sub 2 In containers in boxes or drums Isobutyl Aldehyde, in bulk in drums. See item for class dependent upon released value Isobutyric Acid, in boxes or drums. See item for class dependent upon released value National Motor Freight Traffic Association, Inc. Subject 3, Page 5 of 30

6 Present Classification Provisions Continued CHEMICALS GROUP: subject to item Isopropyl Acetate. See item for class dependent upon released value: Sub 1 In bulk in drums Sub 2 In inner containers in boxes Methyl Acetate. See item for class dependent upon released value: Sub 1 In bulk in drums or steel cylinders Sub 2 In glass carboys Sub 3 In inner containers in boxes Methyl Butyl Ketone, Methyl Ethyl Ketone, Methyl Isobutyl Ketone or Methyl Propyl Ketone. See item for class dependent upon released value: Sub 1 In bulk in drums or steel cylinders Sub 2 In containers in boxes or drums Sub 3 In glass carboys Methylal, in drums Paraldehyde. See item for class dependent upon released value: Sub 1 In inner containers in boxes Sub 2 In bulk in drums Sub 3 In glass carboys Proprietary Antifreeze or Engine Coolant Preparations, see Note, item 45972; Heat Transfer Agents or Media, NOI, see Note, item 45976; or Proprietary De-icing Preparations, see Note, item 45974: Sub 1 In inner containers in boxes or drums, or in Packages 2053, 2436 or Sub 2 In bulk in drums NOTE Applies only on proprietary antifreeze or engine coolant preparations made from denatured ethyl alcohol, methanol, ethylene glycol, propylene glycol, dipropylene glycol, diethylene glycol, glycol ether or hexylene glycol, with or without inhibitor NOTE Applies only on preparations containing alcohols or glycols, with or without water or inhibitors, in pressurized dispensing containers NOTE Applies only on proprietary heat transfer agents or media consisting of glycol ether, ethylene glycol, propylene glycol, diphenyl and diphenyl oxide mixtures, o-dichlorobenzene, modified terphenyl or alkylated benzene, with or without inhibitor Propyl Acetate. See item for class dependent upon released value: Sub 1 In bulk in drums Sub 2 In inner containers in boxes or drums Propyl Aldehyde, in bulk in drums Propylene Oxide, in drums Pyridine, in inner containers in boxes or in bulk in drums. See item for class dependent upon released value Subject 3, Page 6 of National Motor Freight Traffic Association, Inc.

7 Present Classification Provisions Continued CHEMICALS GROUP: subject to item Resins, coal tar or petroleum, or Resin Compounds, see Note, item 46032, in multiple-wall paper bags, cloth bags, boxes, drums or Packages 591, 2452, 2473, 2501 or NOTE Not Involved. Tar Products: subject to item Chlorobenzene (Chlorobenzol) or Monochlorobenzol (Monochlorobenzene). See item for class dependent upon released value: Sub 1 In boxes, drums or steel cylinders Sub 2 In glass carboys Terepine Ether, in drums Toluol (Toluene), NOI. See item for class dependent upon released value: Sub 1 In bulk in drums or steel cylinders Sub 2 In inner containers in boxes or drums Sub 3 In glass carboys Vinyl Acetate. See item for class dependent upon released value: Sub 1 In bulk in drums Sub 2 In inner containers in boxes or drums Vinyl Toluene, inhibited, liquid, in drums Xylol, NOI, or Xylene. See item for class dependent upon released value: Sub 1 In bulk in drums or steel cylinders Sub 2 In inner containers in boxes or drums Sub 3 In glass carboys Chlorinated Phenol Petroleum Solution (Liquid Wood Preservatives), not exceeding 5 percent of chlorinated phenol by weight: Sub 1 In inner containers in boxes Sub 2 In bulk in drums Compounds or Solutions, windshield washer cleaning or antifreeze, concentrated or premixed: Sub 1 In inner containers in boxes Sub 2 In bulk in drums DRUGS, MEDICINES OR TOILET PREPARATIONS: subject to item Nitroglycerin, Spirits of, in glass or metal containers in wooden boxes only. See item for class dependent upon released value Perfume or Perfumery, in boxes, drums or Packages 2189 or See item for class dependent upon released value Toilet Preparations, NOI, see Notes, items 59422, and 59425, in boxes, drums or Packages 2180, 2189, 2407, 2411, 2440, 2499, 2500 or See item for class dependent upon released value National Motor Freight Traffic Association, Inc. Subject 3, Page 7 of 30

8 Present Classification Provisions Continued NOTE Not Involved NOTE Not Involved NOTE Not Involved. FOODSTUFFS GROUP: subject to item Extracts, NOI; Flavoring Compounds, NOI; Imitation Flavors, NOI; or Bottlers' Flavoring Compounds, NOI, see Note, item 72917; liquid, paste or dry, see Notes, items 72912, and 72916; in boxes or drums or dry, in bulk in paper-lined cloth bags or four-ply multiple-wall paper bags, or in Packages 1000, 2358 or 2440, see Note, item NOTE Not Involved NOTE Not Involved NOTE Not Involved NOTE Not Involved NOTE Not Involved. INK AND RELATED MATERIALS GROUP: subject to item Ink and Related Materials, viz.: Bases, color, ink; Compounds, ink reducing, thickening or thinning; Driers, ink; Extenders, ink; Ink, brush or stencil marking; Ink, printing, NOI; Plasticizers, ink; Solvents, ink; Varnishes, ink; Sub 1 In metal or plastic tubes, in boxes other than Package Sub 2 In metal or plastic tubes, in Package Sub 3 In inner containers other than metal or plastic tubes in boxes, crates, drums or pails, in bulk in drums, or in Packages 574, 2388, 2440, 2463, 2467, 2499, 2516 or LIQUORS, BEVERAGE: subject to item Liquors, alcoholic, NOI, in boxes, drums or Packages 1343, 1352, 2297, 2332 or Motor Fuels, NOI, liquid (liquid blends of alcohol and petroleum or tar products; alcohol, castor oil and nitromethane; or of tar products with or without petroleum products), see Note, item , in inner containers in boxes, or in drums NOTE Applies only on motor fuels with an alcohol or tar content of 50 percent or more. Motor fuels with a petroleum content of 50 percent or more are classified per item OILS, OTHER THAN PETROLEUM: subject to item Camphor. See item for class dependent upon released value: Sub 1 In inner containers in boxes Sub 2 In boxes or drums Subject 3, Page 8 of National Motor Freight Traffic Association, Inc.

9 Present Classification Provisions Continued OILS, OTHER THAN PETROLEUM: subject to item Coal Tar or Gas Drips, crude, NOI, including Crude Coal Tar Naphtha and Crude Light Oil of Coal Tar, in drums Creosote (Dead Oil of Coal Tar or Wood Tar) including Distillate or Solution (Creosote Oil and Tar): Sub 1 In pails or in inner containers in boxes Sub 2 In bulk in drums Paint Oils, NOI: Sub 1 In metal cans in crates Sub 2 In boxes or drums, or pails, with or without bails but equipped with handles Pine: Sub 1 In glass in boxes Sub 2 In inner containers, other than glass, in boxes, or in bulk in drums Pine Tar: Sub 1 In glass in boxes Sub 2 In inner containers, other than glass, in boxes Sub 3 In bulk in drums Rosin, in boxes or drums PAINTS GROUP: subject to item Caulking or Glazier's Compounds, NOI, other than foam, cellular or expanded plastic or rubber, see Note, item ; in boxes, crates, pails or steel drums NOTE Also applies on paint in tubes in the same shipping container when the weight of the paint does not exceed 10 percent of the weight upon which freight charges are assessed. THIS SPACE INTENTIONALLY LEFT BLANK 2019 National Motor Freight Traffic Association, Inc. Subject 3, Page 9 of 30

10 Present Classification Provisions Continued PAINTS GROUP: subject to item Paint and Related Materials, viz.: Additives, paint preserving; Color, mortar; Compounds, paint, lacquer, varnish, gum, resin, plastic or adhesive increasing, reducing, removing, thickening or thinning; Driers, paint or varnish; Fillers, wood; Lacquer; Liquids, bronzing; Paints, Stains or Varnishes, NOI; Pigments, NOI; Plasticizers, paint, lacquer, varnish, gum, resin or plastic; Shellacs; Solvent, paint, lacquer, varnish, gum, resin, plastic, rubber or adhesive; Sub 1 Combustible, in bulk containers holding 119 gallons or more; flammable; or corrosive; see Note, item , in U.S. DOT authorized containers, subject to Item 170 and having a density in pounds per cubic foot of: Sub 2 Less than Sub 3 20 or greater Sub 4 Other than combustible in bulk containers holding 119 gallons or more, and other than flammable or corrosive, in bags, boxes, crates, drums, pails, intermediate bulk containers (IBCs), U.S. DOT specification portable tanks, or Packages 33, 601, 934, 1398, 2138, 2257, 2301, 2335, 2374, 2403, 2404, 2440, 2445, 2463, 2467, 2473, 2499, 2516 or 2521, subject to Item 170 and having a density in pounds per cubic foot of: Sub 5 Less than Sub 6 20 or greater NOTE Applies on paint and related materials meeting the U.S. DOT regulations' definition of combustible, flammable or corrosive materials Turpentine, NOI, including Pinene or Wood Turpentine, in boxes or drums Subject 3, Page 10 of National Motor Freight Traffic Association, Inc.

11 Present Classification Provisions Continued PETROLEUM PRODUCTS GROUP: subject to item NOTE Not Involved Petroleum Oils, Greases and Related Products, viz.: Adhesive or Coating, air filtering element dust arresting; Alcohols, inedible fatty, NOI; Aviation Turbine Engine Fuel or Jet Fuel; Case Oil; Coal Oil; Crude Oil, petroleum; Diesel Fuel; Fatty Acid, petroleum; Fuel Oil; Gasoline, Motor Spirit or Petrol, including Casinghead Gasoline; Grease; Isopentane; Kerosene; Naphthenic Acid; Oil, NOI, see Notes, items and ; Paraffin, chlorinated; Paraffin Wax; Pentane; Petrolatum, Petroleum Jelly or Petroleum Petrolatum Preparations, see Note, item ; Petroleum Distillates or Petroleum Products, NOI; Petroleum Naphtha; Petroleum Oil; Petroleum Wax; Transformer Oil; Sub 1 Combustible, in bulk containers holding 119 gallons or more, or flammable, see Note, item , in U.S. DOT authorized Sub 2 containers Other than combustible in bulk containers holding 119 gallons or more, and other than flammable, in bags, boxes, crates, drums or Packages 210, 589, 591, 602, 926, 1000, 1235, 1500, 2096, 2342, 2440, 2445, 2452, 2454, 2473, 2500, 2516, 2526, 2528 or NOTE Applies on petroleum products meeting the U.S. DOT regulations' definition of combustible materials, when shipped in bulk containers holding 119 gallons or more, or flammable materials NOTE Not Involved Petroleum Toluene (Petroleum Toluol), in bulk in drums National Motor Freight Traffic Association, Inc. Subject 3, Page 11 of 30

12 Present Classification Provisions Concluded PLASTIC MATERIALS, OTHER THAN EXPANDED, GROUP: subject to item Liquid, NOI, other than as described in items and 46032, in boxes, crates, drums or Packages 2440, 2445, 2516 or ROOFING OR SIDING MATERIALS GROUP: subject to item Coating, roofing, having asphalt, pitch, rosin or tar base, other than paint, stain or varnish, in drums or pails or in inner containers in boxes Tributyltin Compound Petroleum Solution, liquid (Liquid Wood Preservative), not exceeding 5 percent of tributyltin compound by weight: Sub 1 In pails, or in inner containers in boxes Sub 2 In bulk in drums WASTE MATERIALS GROUP: subject to item Waste Hydroxy Aldehydes or Sugars, containing not less than 40 percent water (residuum from manufacture of pentaerythritol), in bulk in drums Package 574 Paste ink in electrically welded single-seam straight-sided 5-gallon 29-gauge (minimum inch thickness) nonreusable steel containers. Containers must bear initials 'NRC' to signify that they are not again to be used as shipping containers after contents have been removed following initial shipment. Proposed Classification Provisions ADHESIVES GROUP: subject to item Adhesives, NOI, Adhesive Cements, NOI, Adhesive Glues, NOI, or Adhesive Pastes, NOI, not required by the U.S. Department of Transportation to bear a Hazard Class or Hazard Division label, see Notes, items 4622 and A-NEW, in bags, boxes, drums, pails, intermediate bulk containers (IBCs), portable tanks or Packages 1398, 2213, 2399, 2440, 2445, 2452, 2458, 2463, 2467, 2478, 2496, 2499, 2500, 2515, 2516, 2521, 2526, 2528 or 2530, subject to Item 170 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 20 or greater NOTE No Change NOTE Cancel; no further application. A-NEW NOTE Does not apply on materials regulated by the U.S. Department of Subject 3, Page 12 of National Motor Freight Traffic Association, Inc.

13 Proposed Classification Provisions Continued ASPHALT GROUP: subject to item Asphalt (Asphaltum), natural, by-product or petroleum, liquid, other than paint, stain or varnish and not required by the U.S. Department of Transportation to bear a Hazard Class or Hazard Division label, see Note, item B-NEW, in containers in boxes, or in drums, pails or Package Tar, coal or petroleum, not required by the U.S. Department of Transportation to bear a Hazard Class or Hazard Division label, see Note, item B-NEW, in metal cans in boxes, or in drums or pails, see Note, item NOTE No Change Tar, NOI, not required by the U.S. Department of Transportation to bear a Hazard Class or Hazard Division label, see Note, item B-NEW, in metal cans in boxes, or in drums B-NEW NOTE Does not apply on materials regulated by the U.S. Department of BUILDING MATERIALS, MISCELLANEOUS, GROUP: subject to item Cement, Concrete or Masonry Waterproofing Compound, liquid or paste, not required by the U.S. Department of Transportation to bear a Hazard Class or Hazard Division label, see Note, item C-NEW: Sub 1 No Change. Sub 2 In metal cans in boxes, or in drums, pails or Package C-NEW NOTE Does not apply on materials regulated by the U.S. Department of CHEMICALS GROUP: see Notes, items and NOTE No Change NOTE No Change Acetaldehyde, etc... Cancel; see Acetone, NOI, etc... Cancel; see Acetonitrile, etc... Cancel; see Acrylate, butyl, ethyl, ethylhexyl, hydroxyethyl, hydroxypropyl, isobutyl or methyl, or Methyl Methacrylate Monomer, with inhibitor added, etc... Cancel; see 2019 National Motor Freight Traffic Association, Inc. Subject 3, Page 13 of 30

14 Proposed Classification Provisions Continued CHEMICALS GROUP: subject to item Alcohols, NOI, other than alcoholic liquors and not required by the U.S. Department of Transportation to bear a Hazard Class or Hazard Division label, see Note, item D-NEW: Sub 1 In carboys Sub 2 In inner containers in boxes, or in pails Sub 3 In drums D-NEW NOTE Does not apply on materials regulated by the U.S. Department of Alcohols, NOI; including Anhydrous Alcohol, not denatured, etc... Cancel; see items and G-NEW Alcohol, methallyl, etc... Cancel; see Alcohol, amyl, etc... Cancel; see items and G-NEW NOTE Cancel; no further application NOTE Cancel; no further application NOTE Cancel; no further application NOTE Cancel; no further application NOTE Cancel; no further application NOTE Cancel; no further application NOTE Cancel; no further application NOTE Cancel; no further application Denatured or Methanol (Methyl Alcohol), solidified, etc... Cancel; see item and G-NEW Methyl Isobutyl Carbinol, etc... Cancel; see Amyl Acetate, etc... Cancel; see Aqueous Monomethylamine, Aqueous Dimethylamine, or Aqueous Trimethylamine, etc... Cancel; see Benzol (Benzene), etc... Cancel; see Butyl Acetate, etc... Cancel; see Subject 3, Page 14 of National Motor Freight Traffic Association, Inc.

15 Proposed Classification Provisions Continued CHEMICALS GROUP: subject to item Butyraldehyde, etc... Cancel; see Chemicals, NOI, see Note, item See item for class dependent upon released value: Sub 1 In glass carboys or Package Sub 2 In bags, boxes, drums or Packages 1439, 2258, 2419, 2456 or NOTE No Change Chloropentanes (Dichloropentanes, Trichloropentanes or Tetrachloropentanes), etc... Cancel; see Cyclohexane, etc... Cancel; see Dichloroethyl Ether, etc... Cancel; see Dichloroethylene, etc... Cancel; see Diisobutyl Ketone, etc... Cancel; see Dyes or Colors, coal tar, other than indigo and not required by the U.S. Department of Transportation to bear a Hazard Class or Hazard Division label, see Note, item E-NEW, dry, liquid or paste, in boxes or drums; or dry, in Packages 1059, 1065 or See item for class dependent upon released value E-NEW NOTE Does not apply on materials regulated by the U.S. Department of Ether, butyric, etc... Cancel; see Ether: Diethylene glycol dimethyl; Tetraethylene glycol dimethyl; Triethylene glycol dimethyl, etc... Cancel; see Ether, ethyl (Sulfuric Ether), anesthesia ether, etc... Cancel; see Ether, ethyl (Sulfuric Ether), other than anesthesia ether, etc... Cancel; see Ether, isopropyl, etc... Cancel; see Ethylbenzene (Ethylbenzol), Ethylbenzine, Polyethylbenzene, Polyethylbenzine or Diethylbenzene, etc... Cancel; see 2019 National Motor Freight Traffic Association, Inc. Subject 3, Page 15 of 30

16 Proposed Classification Provisions Continued CHEMICALS GROUP: subject to item F-NEW Ethylidene Aniline, in inner containers in boxes. See item for class dependent upon released value Ethylidene Aniline, etc... Cancel; see item F-NEW G-NEW Flammable Liquids, NOI; or Combustible Liquids in bulk containers with a maximum capacity greater than 119 gallons, NOI; other than toxic, see Notes, items and H-NEW, in U.S. DOT-authorized packaging: Sub 1 In Packing Group I Sub 2 In Packing Group II Sub 3 In Packing Group III H-NEW NOTE Applies on materials regulated by the U.S. Department of Transportation as a Hazard Class 3: Flammable Liquid; or Combustible Liquid in bulk containers; as defined in 49 CFR and required to bear a notice to that effect on bills of lading and packaging Formaldehyde, paste, etc... Cancel; see and provisions otherwise applicable Formate, ethyl or methyl, etc... Cancel; see Isobutyl Acetate, etc... Cancel; see Isobutyl Aldehyde, etc... Cancel; see Isobutyric Acid, etc... Cancel; see Isopropyl Acetate, etc... Cancel; see Methyl Acetate, etc... Cancel; see Methyl Butyl Ketone, Methyl Ethyl Ketone, Methyl Isobutyl Ketone or Methyl Propyl Ketone, etc... Cancel; see Methylal, etc... Cancel; see Paraldehyde, etc... Cancel; see Proprietary Antifreeze or Engine Coolant Preparations, see Note, item 45972; Heat Transfer Agents or Media, NOI, see Note, item 45976; or Proprietary De-icing Preparations, etc... Cancel; see Subject 3, Page 16 of National Motor Freight Traffic Association, Inc.

17 Proposed Classification Provisions Continued CHEMICALS GROUP: subject to item NOTE Cancel; no further application NOTE Cancel; no further application NOTE Cancel; no further application Propyl Acetate, etc... Cancel; see Propyl Aldehyde, etc... Cancel; see Propylene Oxide, etc... Cancel; see Pyridine, etc... Cancel; see Resins, coal tar or petroleum, or Resin Compounds, see Note, item 46032, not required by the U.S. Department of Transportation to bear a Hazard Class or Hazard Division label, see Note, item I-NEW, in multiple-wall paper bags, cloth bags, boxes, drums or Packages 591, 2452, 2473, 2501 or I-NEW NOTE Does not apply on materials regulated by the U.S. Department of NOTE No Change. Tar Products: subject to item Chlorobenzene (Chlorobenzol) or Monochlorobenzol (Monochlorobenzene), etc... Cancel; see Terepine Ether, etc... Cancel; see Toluol (Toluene), NOI, etc... Cancel; see Vinyl Acetate, etc... Cancel; see Vinyl Toluene, inhibited, liquid, etc... Cancel; see Xylol, NOI, or Xylene, etc... Cancel; see Chlorinated Phenol Petroleum Solution (Liquid Wood Preservatives), not required by the U.S. Department of Transportation to bear a Hazard Class or Hazard Division label, see Note, item J-NEW: Sub 1 In inner containers in boxes Sub 2 In bulk in drums National Motor Freight Traffic Association, Inc. Subject 3, Page 17 of 30

18 Proposed Classification Provisions Continued J-NEW NOTE Does not apply on materials regulated by the U.S. Department of Compounds or Solutions, windshield washer cleaning or antifreeze, concentrated or premixed, not required by the U.S. Department of Transportation to bear a Hazard Class or Hazard Division label, see Note, item K-NEW: Sub 1 In inner containers in boxes Sub 2 In bulk in drums K-NEW NOTE Does not apply on materials regulated by the U.S. Department of DRUGS, MEDICINES OR TOILET PREPARATIONS: subject to item Nitroglycerin, Spirits of, etc... Cancel; see Perfume or Perfumery, not required by the U.S. Department of Transportation to bear a Hazard Class or Hazard Division label, see Note, item L-NEW, in boxes, drums or Packages 2189 or See item for class dependent upon released value Toilet Preparations, NOI, not required by the U.S. Department of Transportation to bear a Hazard Class or Hazard Division label, see Notes, items 59422, 59424, and L-NEW, in boxes, drums or Packages 2180, 2189, 2407, 2411, 2440, 2499, 2500 or See item for class dependent upon released value NOTE No Change NOTE No Change NOTE No Change. L-NEW NOTE Does not apply on materials regulated by the U.S. Department of FOODSTUFFS GROUP: subject to item Extracts, NOI; Flavoring Compounds, NOI; Imitation Flavors, NOI; or Bottlers' Flavoring Compounds, NOI, see Note, item 72917; liquid, paste or dry, not required by the U.S. Department of Transportation to bear a Hazard Class or Hazard Division label, see Notes, items 72912, 72914, and M-NEW; in boxes or drums; or dry, in bulk in paper-lined cloth bags or four-ply multiple-wall paper bags, or in Packages 1000, 2358 or 2440, see Note, item Subject 3, Page 18 of National Motor Freight Traffic Association, Inc.

19 Proposed Classification Provisions Continued M-NEW NOTE Does not apply on materials regulated by the U.S. Department of NOTE No Change NOTE No Change NOTE No Change NOTE No Change NOTE No Change. INK AND RELATED MATERIALS GROUP: subject to item Ink and Related Materials, not required by the U.S. Department of Transportation to bear a Hazard Class or Hazard Division label, see Note, item N-NEW, viz.: Bases, color, ink; Compounds, ink reducing, thickening or thinning; Driers, ink; Extenders, ink; Ink, brush or stencil marking; Ink, printing, NOI; Plasticizers, ink; Solvents, ink; Varnishes, ink; Sub 1 In metal or plastic tubes, in boxes other than Package Sub 2 In metal or plastic tubes, in Package Sub 3 In inner containers other than metal or plastic tubes in boxes, or in drums, pails or Packages 2388, 2440, 2463, 2467, 2499, 2516 or N-NEW NOTE Does not apply on materials regulated by the U.S. Department of LIQUORS, BEVERAGE: subject to item Liquors, alcoholic, NOI, not required by the U.S. Department of Transportation to bear a Hazard Class or Hazard Division label, see Note, item O-NEW, in boxes, drums or Packages 1343, 1352, 2297, 2332 or O-NEW NOTE Does not apply on materials regulated by the U.S. Department of 2019 National Motor Freight Traffic Association, Inc. Subject 3, Page 19 of 30

20 Proposed Classification Provisions Continued Motor Fuels, NOI, liquid (liquid blends of alcohol and petroleum or tar products; alcohol, castor oil and nitromethane; or of tar products with or without petroleum products), not required by the U.S. Department of Transportation to bear a Hazard Class or Hazard Division label, see Notes, items and P-NEW, in inner containers in boxes, or in drums NOTE No Change. P-NEW NOTE Does not apply on materials regulated by the U.S. Department of OILS, OTHER THAN PETROLEUM: subject to item Camphor, etc... Cancel; see Coal Tar or Gas Drips, crude, NOI, including Crude Coal Tar Naphtha and Crude Light Oil of Coal Tar, etc... Cancel; see Creosote (Dead Oil of Coal Tar or Wood Tar) including Distillate or Solution (Creosote Oil and Tar), etc... Cancel; see Paint Oils, NOI, etc... Cancel; see items G-NEW and Pine, etc... Cancel; see Pine Tar, etc... Cancel; see Rosin, etc... Cancel; see PAINTS GROUP: subject to item Caulking or Glazier's Compounds, NOI, other than foam, cellular or expanded plastic or rubber and not required by the U.S. Department of Transportation to bear a Hazard Class or Hazard Division label, see Notes, items and Q-NEW, in boxes, crates, pails or steel drums... No Change NOTE No Change. Subject 3, Page 20 of National Motor Freight Traffic Association, Inc.

21 Proposed Classification Provisions Continued PAINTS GROUP: subject to item Paint and Related Materials, not required by the U.S. Department of Transportation to bear a Hazard Class or Hazard Division label, see Note, item Q-NEW, viz.: Additives, paint preserving; Color, mortar; Compounds, paint, lacquer, varnish, gum, resin, plastic or adhesive increasing, reducing, removing, thickening or thinning; Driers, paint or varnish; Fillers, wood; Lacquer; Liquids, bronzing; Paint Oils; Paints, Stains or Varnishes, NOI; Pigments, NOI; Plasticizers, paint, lacquer, varnish, gum, resin or plastic; Shellacs; Solvent, paint, lacquer, varnish, gum, resin, plastic, rubber or adhesive; in bags, boxes, drums, pails, intermediate bulk containers (IBCs), portable tanks or Packages 33, 601, 934, 1398, 2138, 2257, 2301, 2335, 2374, 2403, 2404, 2440, 2445, 2463, 2467, 2473, 2499, 2516 or 2521, subject to Item 170 and having a density in pounds per cubic foot of: Sub 1 Less than Sub 2 20 or greater NOTE Cancel; no further application. Q-NEW NOTE Does not apply on materials regulated by the U.S. Department of Turpentine, NOI, including Pinene or Wood Turpentine, etc... Cancel; see 2019 National Motor Freight Traffic Association, Inc. Subject 3, Page 21 of 30

22 Proposed Classification Provisions Continued PETROLEUM PRODUCTS GROUP: subject to item NOTE No Change Petroleum Oils, Greases and Related Products, not required by the U.S. Department of Transportation to bear a Hazard Class or Hazard Division label, see Note, item R-NEW, viz.: Adhesive or Coating, air filtering element dust arresting; Alcohols, inedible fatty, NOI; Fatty Acid, petroleum; Naphthenic Acid; Oil, NOI, see Notes, items and ; Paraffin Wax; Petrolatum, Petroleum Jelly or Petroleum Petrolatum Preparations, see Note, item ; Petroleum Distillates or Petroleum Products, NOI; Petroleum Wax; Transformer Oil; In bags, boxes, drums or Packages 210, 589, 591, 602, 926, 1000, 1235, 1500, 2096, 2342, 2440, 2445, 2452, 2454, 2473, 2500, 2516, 2526, 2528 or NOTE Cancel; no further application. R-NEW NOTE Does not apply on materials regulated by the U.S. Department of NOTE No Change Petroleum Toluene (Petroleum Toluol), etc... Cancel; see PLASTIC MATERIALS, OTHER THAN EXPANDED, GROUP: subject to item Liquid, NOI, other than as described in items and and not required by the U.S. Department of Transportation to bear a Hazard Class or Hazard Division label, see Note, item S-NEW, in boxes, drums or Packages 2440, 2445, 2516 or S-NEW NOTE Does not apply on materials regulated by the U.S. Department of Subject 3, Page 22 of National Motor Freight Traffic Association, Inc.

23 Proposed Classification Provisions Concluded ROOFING OR SIDING MATERIALS GROUP: subject to item Coating, roofing, having asphalt, pitch, rosin or tar base, other than paint, stain or varnish and not required by the U.S. Department of Transportation to bear a Hazard Class or Hazard Division label, see Note, item T-NEW, in inner containers in boxes, or in drums or pails T-NEW NOTE Does not apply on materials regulated by the U.S. Department of Tributyltin Compound Petroleum Solution, liquid (Liquid Wood Preservative), not exceeding 5 percent of tributyltin compound by weight and not required by the U.S. Department of Transportation to bear a Hazard Class or Hazard Division label, see Note, item U-NEW: Sub 1 In inner containers in boxes, or in pails Sub 2 In drums U-NEW NOTE Does not apply on materials regulated by the U.S. Department of WASTE MATERIALS GROUP: subject to item Waste Hydroxy Aldehydes or Sugars, containing not less than 40 percent water (residuum from manufacture of pentaerythritol) and not required by the U.S. Department of Transportation to bear a Hazard Class or Hazard Division label, see Note, item V-NEW, in drums V-NEW NOTE Does not apply on materials regulated by the U.S. Department of Cancel; no further application. Analysis Package 574 Research Project 1348 This proposal is based on information developed through Research Project 1348, which was initiated in February 2018 on materials regulated by the U.S. Department of Transportation (DOT) as Flammable Liquids in Hazard Class National Motor Freight Traffic Association, Inc. Subject 3, Page 23 of 30

24 Definitions, Regulations and Provisions 49 CFR defines Hazard Class 3 materials as flammable or combustible liquid. A flammable liquid is defined in 49 CFR (a) as a liquid having a flash point of not more than 140 F, or any material in a liquid phase with a flash point at or above 100 F that is intentionally heated and offered for transportation or transported at or above its flash point in a bulk packaging. Exceptions to the definition for a flammable liquid are shown in 49 CFR (a)(1)-(5). A combustible liquid is defined in 49 CFR (b)(1) as any liquid that does not meet the definition of any other hazard class specified in [the hazardous materials regulations 49 CFR parts ] and has a flash point above 140 F and below 200 F. 49 CFR (b)(2) states that a flammable liquid with a flash point at or above 100 F that does not meet the definition of any other hazard class may be reclassed as a combustible liquid. The required Hazard Class 3 label is shown on the right. Per 49 CFR (a)(1), the Packing Group for Hazard Class 3 materials is determined by the material s flashpoint or boiling point, as shown below. The DOT requires the offeror (in most cases that would be the shipper) to determine the hazard class of a hazardous material before the material is offered for transportation (see 49 CFR 171.1(b)(1)). When a material meets the definition of more than one hazard class or division as defined in 49 CFR part 173, the material must be classed according to the highest applicable hazard class. Hazard Classes 3 and 8 and Divisions 4.1, 4.2, 4.3, 5.1 and 6.1 are ranked in the precedence of hazard table shown in 49 CFR 173.2a(b). The table shows the primary Hazard Class of materials that meet the definitions of both Hazard Class 3 and Hazard Class 8, or Divisions 4.1, 4.2, 4.3, 5.1 and 6.1. As shown in the excerpt from the table, below, materials that may be defined as Hazard Class 3, Packing Groups I and II as well as Hazard Class 8 or Division 6.1, are generally classed as Hazard Class 3. Subject 3, Page 24 of National Motor Freight Traffic Association, Inc.

25 According to the Bureau of Transportation Statistics 2012 Commodity Flow Survey of Hazardous Materials 1, Hazard Class 3 materials comprise 85.4% of the total tonnage of all hazardous materials moving throughout the United States, by all modes. Materials in Hazard Class 3 include industrial chemicals as well as commonplace consumer products, such as adhesives, paint and paint-related products, ink, household cleaners, perfumes, cosmetics and flavoring compounds, to name a few. The CCSB has identified multiple NMFC item numbers as applying on commodities regulated as Hazard Class 3 materials. The majority of those shown in the present provisions herein apply on a specific Hazard Class 3 material. A number of the NMFC items are generic catch all items that provide for groupings of materials, some of which are regulated as a Hazard Class 3, and some that are not regulated. These items include: 43940, Chemicals, NOI; 59420, Toilet Preparations, NOI; , Ink and Related Materials; , Paint and Related Materials; and , Petroleum Oils, Greases and Related Products. Seven of the NMFC items provide listings for specific types of products formulated from a range of chemicals, some of which may be regulated as Hazard Class 3 materials, and some that are not regulated. These entries include items: 33880, Cement, Concrete or Masonry Waterproofing Compound, liquid or paste; 50475, Compounds or Solutions, windshield washer cleaning or antifreeze; and 59070, Perfume or Perfumery. The subgrouping for Alcohols, other than alcoholic liquors and other than toxic, under the Chemicals Group, contains five NMFC items. Three of those items, 42680, and 42720, provide for Hazard Class 3 materials. The other two, item 42670, Alcohols, NOI, including Anhydrous Alcohol, not denatured, and item 42690, which lists 15 specific alcohols and alcohol-based products, and two general, NOI listings, provide for regulated and unregulated materials. In addition to the listings for Hazard Class 3 materials and unregulated materials, item contains a listing for spirit duplication machine fluid. Similar to the mimeograph machine, spirit duplicating machines were printing machines invented in the 1920s to make cheap, fast copies of an original document 2. The duplicating fluid contained 1 Bureau of Transportation Statistics 2012 Commodity Flow Survey of Hazardous Materials: (accessed July 2018) 2 See (accessed July 19, 2018) 2019 National Motor Freight Traffic Association, Inc. Subject 3, Page 25 of 30

26 isopropanol and methanol. The printers and, consequently, the fluid, fell into disuse with the advent of cheap, high-quality desktop printers in the 1980s 3. When Hazard Class 3 materials and the obsolete listing for spirit duplication machine fluid are removed from the provisions of item and 42690, maintaining the two separate provisions for similar types of alcohols and alcohol-related materials becomes unnecessary. Transportation Characteristics Density The information of record on materials in Hazard Class 3 includes 15,490 density observations submitted by carriers, observed firsthand on CCSB dock surveys and obtained from the CCSB s Density Study 4. The densities range from 0.17 to pcf, with an overall average density of pcf. Items and provide for alcohols or alcohol-related materials. When Hazard Class 3 materials are not included in the density data of record, and the remaining materials are combined and grouped according to the current distinctions based on packaging, the density ranges and averages shown below emerge. Packaging Density Range (pcf) Density Average (pcf) In carboys In inner containers in boxes, or in pails In drums Handling Due to the hazardous nature of these materials, extra care and attention is necessary. Training carrier employees in handling hazardous materials and then supervising them to ensure compliance with DOT regulations takes additional time, more paperwork and extra personnel than that required when transporting nonhazardous freight. Personnel who must be trained in the intricacies of handling hazardous materials include: dispatchers, drivers (pickup, line-haul and delivery), driver supervisors, billing clerks, billing supervisors, terminal managers, freight handlers, dock foremen, maintenance personnel, safety and claims personnel, and even sales personnel. 3 See (accessed July 19, 2018) 4 The Density Study is part of an ongoing effort by the CCSB to collect information on actual shipments; it is not tied to any particular research project, nor does it target any particular product category. Carriers that choose to participate in the study periodically submit shipment data captured through their respective freight auditing programs. The data is identified by NMFC item, and only verifiable data points, which include the weight and the dimensions and/or cube of the shipping unit involved, are used. Subject 3, Page 26 of National Motor Freight Traffic Association, Inc.

27 The carrier s driver must check the accuracy of the information provided on the bill of lading and confirm that the shipper s compliance certification statement is included. Further, the driver must accurately count the number of pieces tendered, verify the inclusion of an emergency contact telephone number and verify the application of the proper hazard labels 5. It is also imperative that the driver be aware of the type of freight already in the vehicle to ensure the carrier complies with coloading prohibitions and segregation requirements. The driver must also be aware of the threshold quantities of hazardous materials that will trigger the need to display the appropriate warning placards on the vehicle. If placards are required, the driver must ensure that they are properly displayed on the vehicle (visible from the front, rear and both sides). The driver must also place the shipping documents for all hazardous materials on top of all documents for nonhazardous freight, or distinctively tab each hazardous materials shipping paper, and the hazardous materials documents must be kept within the driver s reach at all times. Considering the thousands of hazardous materials handled daily by for-hire carriers and the inescapable fact that leaks, spills, fires and accidents occur, emergency response information must be included in a shipping paper or with a shipping paper, in a manner that cross-references the description of the hazardous material on the shipping paper with the emergency response information contained in a separate document (see 49 CFR part 172, subpart G). In addition to these regulatory requirements, virtually every carrier has its own rules that detail the actions to be taken by drivers in the event of problems involving hazardous materials. Carrier billing personnel must be trained to recognize hazardous materials shipments and to accurately transfer all information on these materials from the bill of lading to the freight bill (a copy of which is used to move the freight through the carrier s system to its destination). Additionally, many carriers require that freight bills pertaining to hazardous materials be flagged as a means to ensure that freight handlers and drivers are aware of the dangers presented by the material. Terminal managers, dock foremen and freight handlers must all be trained to be familiar with the care and attention required in the handling of hazardous materials, including the coloading prohibitions and segregation of freight bearing different DOT-required hazard designation labels. Further, complying with the involved handling regulations requires at least one dedicated space on carrier docks for hazardous materials. Most general freight does not require a separate space on the carriers docks. The photos on the following page were obtained through CCSB dock surveys conducted in They demonstrate the range of Hazard Class 3 materials being transported in the less-than-truckload environment and the various packaging used to contain the materials CFR , , , , , , National Motor Freight Traffic Association, Inc. Subject 3, Page 27 of 30

28 Stowability DOT regulations in 49 CFR establish coloading prohibitions and segregation requirements that apply on flammable liquids, as per the table below 6. These restrictions can limit where in the vehicle and with what freight the carrier can stow the shipments and can result in less than full utilization of vehicle capacity and/or necessitate the dispatch of more than one vehicle. Class or division Segregation Table for Hazardous Materials gas zone A 2.3 gas Zone B liquids PG I zone A Flammable liquids X X O X X O O X X=Coloading Prohibition O=Segregation Requirement Liability Flammable and combustible liquids are hazardous in nature, may damage other freight and carrier equipment, and may pose a risk of injury to carrier personnel. When hazardous materials are involved in a transportation incident, often a report may be required. Reporting requirements are the responsibility of the carrier. For certain incidents, the carrier must notify the National Response Center (NRC) as soon as practical but not later than 12 hours after the incident occurs. For any such incident, the carrier must also follow up with a written Hazardous Materials Incident Report, DOT Form F within 30 days. A written Hazardous Materials Incident Report, DOT Form F must also be submitted within 30 days of discovering any unintentional release of hazardous materials or unintentional discharge of hazardous waste, as well as under certain other conditions (see 49 CFR ). According to the DOT s Office of Hazardous Materials Safety s Incident Reports Database, from January 1, 2015 through January 28, 2018 there were 20,745 incidents involving Hazard Class 3 materials transported by highway, other than by cargo tank. The cost of damages for 2,415 of those incidents totaled $36,285,884, averaging approximately $15,025 per incident. 6 Flammable liquids are not subject to coloading prohibitions or segregation requirements with Hazard Classes or Divisions that are not shown. Subject 3, Page 28 of National Motor Freight Traffic Association, Inc.