UMALI, GERALD

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TOPICS: Industrial Hazards

What is Hazardous Material?

BY VALERIE ZIAVRAS
Which code or standard applies to hazardous materials? How much of a particular
hazardous material can be stored or used? What floor of the building can that
hazardous material be stored or used on? These are all questions some are faced with
daily. There is an assumption that people, such as facility managers, building owners,
engineers, and first responders, just inherently know when a material is a hazardous
material. And, that once they know it is a hazardous material, they know how to deal
with that material properly and safely. We have seen the potential impacts of materials
that are improperly stored or used such as in the 2013 fire and explosion at West
Fertilizer Company in Texas. How can we prevent incidents like this from happening?
The first step is knowing how to identify a hazardous material.
Part of the challenge when it comes to determining and classifying hazardous materials
is that there is not one consistent definition of “hazardous material” nor is there one
consistent approach to the classification of hazardous materials. Therefore, when
looking at Safety Data Sheets (SDS) or literature provided by the manufacturer, it is
imperative to know and understand which hazardous material classification system is
being used. NFPA 400, Hazardous Materials Code, has its own definition and
classification method that consists of 14 different categories. The U.S. DOT uses a 9-
category classification system. OSHA has its own definitions established in 29 CFR,
which has been revised to align with the Globally Harmonized System of Classification
and Labelling of Chemicals (GHS). While there has been an effort to coordinate
between the groups, differences do still exist. Information on SDS is often based on the
GHS system and not the system in NFPA 400.

Defining Hazardous Material

The approach I like to take is to assume materials are hazardous, until I have proven
that a particular material is not. As we will discuss there are a number of different
definitions and triggers that could lead to a material being considered hazardous.
Therefore, I would not want to rely on an initial assumption that a material is not
hazardous. When determining if a material is to be considered hazardous, the first step
is to identify for what purpose you are evaluating the material for. If you are transporting
the material in the United States then the DOT’s definition is what you would need to
use, whereas if you are storing or using the material, then you would need to use the
definition found in the applicable building code or fire code.
GHS does not define the term “hazardous material”, but the DOT defines a hazardous
material as “means a substance or material that the Secretary of Transportation has
determined is capable of posing an unreasonable risk to health, safety, and property
when transported in commerce, and has designated as hazardous under section 5103
of Federal hazardous materials transportation law (49 U.S.C. 5103). The term includes
hazardous substances, hazardous wastes, marine pollutants, elevated temperature
materials, materials designated as hazardous in the Hazardous Materials Table (see 49
CFR 172.101), and materials that meet the defining criteria for hazard classes and
divisions in part 173 of this subchapter.”
NFPA 1, Fire Code, NFPA 101, Life Safety Code, and NFPA 5000, Building
Construction and Safety Code, all use the definition from NFPA 400 for hazardous
material. NFPA 400 defines a hazardous material as:
A chemical or substance that is classified as a physical hazard material or a health
hazard material, whether the chemical or substance is in usable or waste condition.
The definitions of physical hazard material and health hazard material are integral in
understanding and properly applying this definition. A physical hazard material per
NFPA 400 is a substance that is classified as any one of the following:

 Explosive
 Flammable cryogen
 Flammable gas
 Flammable solid
 Ignitable (flammable or combustible) liquid
 Organic peroxide
 Oxidizer
 Oxidizing cryogen
 Pyrophoric
 Unstable (reactive)
 Water-reactive material
A health hazard material per NFPA 400 is a chemical or substance that is classified as
any one of the following:

 Toxic
 Highly toxic
 Corrosive material

Many of these terms are defined within NFPA 400 to further help in defining what a
hazardous material is.
It is also worth noting that other NFPA codes and standards may use a different
definition for “hazardous material”. That is why it is essential to understand for what
purpose (e.g., offsite transportation, storage, use, etc.) you need to determine whether
something is a hazardous material or not and then consult the appropriate document to
determine if it meets the definition. There is not one universally accepted definition. One
example of a document that defines hazardous material differently is NFPA 30,
Flammable and Combustible Liquids Code. NFPA 30 defines hazardous material or
hazardous chemical as a “material presenting dangers beyond the fire problems relating
to flash point and boiling point.” The annex material goes on to explain that the other
dangers could include things like toxicity, reactivity, instability, or corrosively. However,
that is not intended to be an exhaustive list. While this may seem to conflict with NFPA
400, when you consider the scope of NFPA 400 the definition from NFPA 30 actually
aligns with how NFPA 400 is applied. Although a flammable and combustible liquid that
has no other physical or health hazards would be considered a hazardous material per
NFPA 400, it is excluded from the scope of the document. I’ll talk more about this in a
future blog where we will look in detail at the scope and applicability of NFPA 400.

Classifying Hazardous Materials

As I mentioned earlier, different organizations have different ways of classifying
hazardous materials. The DOT uses a 9-system classification method while NFPA 400
uses a 14-system category method. Some of the DOT classifications are further broken
into divisions, while some of the NFPA 400 categories are broken into sub
classifications.
The 9 classes used by the DOT are:
Class 1: Explosives
Class 2: Gases
Class 3: Flammable Liquid and Combustible Liquid
Class 4: Flammable Solid, Spontaneously Combustible, and Dangerous When Wet
Class 5: Oxidizer and Organic Peroxide
Class 6: Poison (Toxic) and Poison Inhalation Hazard
Class 7: Radioactive
Class 8: Corrosive
Class 9: Miscellaneous

The 14 categories of hazardous materials used in NFPA 400 are:

 Corrosive solids, liquids, or gases
 Flammable solids
 Flammable gases
 Flammable cryogenic fluids
 Inert cryogenic fluids
 Inert gases
 Organic peroxide formulations
 Oxidizer solids or liquids
 Oxidizing gases
 Oxidizing cryogenic fluids
 Pyrophoric solids, liquids, or gases
 Toxic or highly toxic solids, liquids, or gases
 Unstable (reactive) solids, liquids, or gases
 Water-reactive solids or liquids
Compounding the challenge associated with determining and classifying hazardous
materials, is the fact that between the two systems many of the categories use similar
verbiage but may have different thresholds that trigger that particular classification. One
example is flammable liquid. DOT defines flammable liquid as “a liquid having a flash
point of not more than 60 °C (140 °F), or any material in a liquid phase with a flash point
at or above 37.8 °C (100 °F) that is intentionally heated and offered for transportation or
transported at or above its flash point in a bulk packaging”. NFPA 400 states that a
flammable liquid is an ignitable liquid that is classified as a Class I liquid. There are
three sub classifications of a Class I liquid. The table below summarizes the specific
thresholds for the sub classifications.
Sub classification
Flash point
Boiling point
Class IA Liquid
Below 73 OF (22.8O C)
Below 100 OF (37.8O C)
Class IB
Liquid Below 73 OF (22.8O C)
At or above 100 OF (37.8OC) Class IC Liquid At or above 73O F (22.8O C) but below
100O F (37.8OC)
These discrepancies mean that when determining the category of hazardous material
you have, you need to know what system was used to provide a classification, such as
the one found on a Safety Data Sheet, or you need the actual test data so the
classification can be determined based on the definitions.
In summary, although there is agreement that hazardous materials are physical or
health hazard materials, there is not one standard definition or approach to determining
if a material should be considered hazardous or not. NFPA 400 defines hazardous
material as any chemical or substance that is a physical hazard material or a health
hazard material. Hazardous materials are then categorized based on the physical or
health hazard they present. There are 14 different categories in NFPA 400 and a
material may fall into one or more of those categories. Be on the lookout for my future
blogs which will take a deeper dive into NFPA 400, covering topics like applicability of
NFPA 400, maximum allowable quantities (MAQs), and more.
Important Notice: Any opinion expressed in this column (blog, article) is the opinion of
the author and does not necessarily represent the official position of NFPA or its
Technical Committees. In addition, this piece is neither intended, nor should it be relied
upon, to provide professional consultation or services.