By Frits Wybenga, Senior Technical Writer

An unintended consequence of the implementation of criteria for Environmentally Hazardous Substances (EHS) in the new edition of the IMDG Code is that for certain combustible liquids, it will eliminate problems associated with readying them for sea transport.

Combustible liquids with a flashpoint above 60oC are regulated when in bulk packagings under US regulations but are not regulated under the IMDG Code or transport regulations of other countries.  This poses a problem for US shippers consigning these combustible liquids to international destinations, as well as for importers of these products.  Under §171.22(c) a material not regulated by the IMDG Code must be transported in accordance with the Hazardous Materials Regulations (HMR).  Consequently, unless a combustible liquid with a flashpoint above 60oC in a bulk packaging (i.e., an IBC or portable tank) is regulated by the IMDG Code, it must be transported in accordance with the HMR.

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