# Singapore Airlines Ltd — Hazardous Materials Safety Interpretation

**Citation:** 02-0137  
**Type / status:** guidance / guidance  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2002-06-28

02-0137 response to Singapore Airlines Ltd concerning 173.222.

## Document text

<<<PAGE 1>>>

of Transportation
JS. Department
400 Seventh Street, S.W.
Washington, D.C. 20590
Research and
Special Programs
Administration
JUN 2 8 2002
Mr. Muthusamy Chandran
Ref. No. 02-0137
Senior Officer
Singapore Airlines Ltd.
Airline House 05A
Singapore
Dear Mr. Chandran:
This is in response to your April 16, 2002 letter regarding the classification of a material under the
Hazardous Materials Regulations (HMR;49 CFR parts 171-180). Specifically, you ask if Mobil
Jet Oil or Skdrol contained in hydraulic parts is considered a hazardous material for air
transportation.
Although you did not provide material safety data sheets (MSDS) for these products, you state
that the MSDS for these materials do not indicate they are hazardous for air transportation and
that they can be air freighted as normal cargo. Subsequently, the materials in your hydraulic parts
would have to exhibit some characteristic that would make them hazardous for transportation,
including by air. If the materials in your hydraulic parts do not meet the definition of a hazardous
matenal, such as a flammable liquid, and the internal fluid is identical in nature to the material
listed in the MSDS, then it would appear that the hydraulic parts you described are not subject to
the HMR.
It is up to the offerer to determine if their material is hazardous or not. Additionally, your
material may be subject to applicable requirements of the International Civil Aviation
Organization's Technical Instructions.
I hope this satisfies your request.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
173.222
020137

<<<PAGE 2>>>

SINGAPORE AIRLINES LIMITED
Mr. Ed Mazzullo
Johnsen
Research and Special
Department of Transport
Programs Administration
3173.222
$173.27
IMDG
16* April 2002
02 - 0137
Dear Mr Ed,
I have a question, which has been nagging me for sometime. I hope you can help me with it.
Mobile Jet Oil, used in aircraft engines and Skdrol. LDA, used in hydraulic parts are not classified as dangerous
normal cargo.
goods as per their respective manufacturers Material Safety. Data Sheet. These fluids can be air freighted as
parts, considered dangerous.
When the unserviceable parts are removed from the aircraft, is the Mobil Jet Oil or Skdrol contained in these
!
Can these parts be still air freighted as normal cargo or should they be declared as dangerous goods.
If it is to be declared as dangerous goods, under which Proper Shipping Name should these fluids be classified.
replying to me.
I do hope to receive your reply as soon as possible. I would like to thank you in advance for taking your time in
Once again thank you very much.
Yours Truly,
Cherchann
Senior Officer
M Chandran
Engineering Supplies Dept
Singapore Airlines Ltd
Airline House 05A
Singapore
Fax: (65) 6545 7548
Tel: (65) 6541 4950
Email: chandran_ muthusamy@singaporeair.com.sq

## Provenance

- Official: Yes
- Source: <https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020137.pdf>
- Source ID: `phmsa`
- SHA-256: `aa2f98a397163bef0b4adbc52858f0c34e1dc9ebd8e8ded266d62fe9e39479ad`
- Retrieved: 2026-08-20T00:59:31.977Z
- Exported: 2026-08-23T07:48:14.352Z
- Document slug: `phmsa-interpretation-02-0137`

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