{"operation":"document","citation":"PHMSA Guidance, 24-0047","title":"24-0047","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2025-03-13","effective_on":"2025-03-13","summary":"24-0047 Document 24-0047.pdf (164.85 KB) 24-0047 (to COSTHA) Issued Date: Thursday, March 13, 2025","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-guidance-24-0047-4ddaad33.json","markdown":"https://regulus.evalyn.ai/document/phmsa-guidance-24-0047-4ddaad33.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-guidance-24-0047-4ddaad33","source_url":"https://www.phmsa.dot.gov/regulatory-compliance/phmsa-guidance/24-0047","body":"24-0047\n\nDocument\n\n 24-0047.pdf (164.85 KB)\n\n        24-0047 (to COSTHA)\n\n          Issued Date: Thursday, March 13, 2025\n\n<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nMarch 13, 2025\nDrew Watts\nRegulatory Compliance Specialist\nCouncil on Safe Transportation of Hazardous Articles\n101 Ridge Street, Suite I\nGlens Falls, NY 12801\nReference No. 24-0047\nDear Mr. Watts:\nThis letter is in response to your June 5, 2024 letter requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to the exceptions for “UN0012,\nCartridges for weapons, inert projectile or Cartridges, small arms, 1.4S,” “UN0014, Cartridges\nfor weapons, blank or Cartridges, small arms, blank or Cartridges for tools, blank, 1.4S,” and\n“UN0055, Cases, cartridge, empty with primer, 1.4S” in accordance with 49 CFR §§ 173.63(b)\nand 175.75(c). Specifically, you ask whether a package can be fully prepared for transport by air\nin accordance with the International Civil Aviation Organization Technical Instructions for the\nTransport of Dangerous Goods by Air (ICAO Technical Instructions) and also be affixed with\nthe 49 CFR §§ 172.315(a) or (b) limited quantity mark, and, if so, whether such a package would\nbe eligible for the 25kg inaccessible cargo compartment limit exception in 49 CFR § 175.75(c).\nWe have paraphrased and answered your questions as follows:\nQ1. Can a package containing less than 25kg of UN0012, UN0014, and UN0055—offered as\na fully regulated shipment for international air transportation (e.g., packaged, marked,\nlabeled, and documented) in accordance with the ICAO Technical Instructions—also be\naffixed with the limited quantity mark with or without the symbol “Y,” specifying air\ntransport, in accordance with 49 CFR § 173.63(b)(1)(i)?\nA1. Yes. A package containing less than 25kg of UN0012, UN0014, and UN0055—offered\nas a fully regulated shipment for international air transportation (e.g., packaged, marked,\nlabeled, and documented) in accordance with the ICAO Technical Instructions—can also\nbe affixed with the limited quantity mark with or without the symbol “Y,” specifying air\ntransport, in accordance with 49 CFR § 173.63(b)(1)(i). However, using the limited\n\n<<<PAGE 2>>>\n\nquantity mark with the “Y” may frustrate the shipment for air transportation for the\nfollowing reasons.\nAs PHMSA explained in the January 17, 2013 final rule that added the 49 CFR\n§ 173.63(b)(1)(i) marking requirement, the ICAO Dangerous Goods Panel Working\nGroup of the Whole (DGP-WG/12) has not authorized these 1.4S articles as limited\nquantities.1 The DGP-WG/12 has noted, however, that packages bearing the limited\nquantity marking of other modes can still be accepted for air transport provided all\nadditional requirements of the ICAO Technical Instructions are met. As PHMSA and the\nFederal Aviation Administration (FAA) also noted in the January 17, 2013 final rule—\nalbeit in the context of a proposal to remove the air limited quantity marking\nauthorization in 49 CFR § 173.63(b)(1)(i) that was not adopted—retaining the option to\ndisplay the air limited quantity marking by all modes may result in confusion and\npotentially frustrate shipments of packages with the air limited quantity marking for air\ntransportation.\nIn other words, while the HMR authorizes the use of either limited quantity marking,\nsince the ICAO Technical Instructions do not authorize these materials to be shipped as\nlimited quantities by air, it is advisable to only affix the limited quantity mark without the\n“Y” to the package when a shipment is prepared in accordance with the ICAO Technical\nInstructions for air transport. This will help to reduce potential frustration and confusion\nwith air operators and freight forwarders. Please also be advised that an air operator may\nhave additional restrictions based on its FAA-accepted operator procedures and\ninformation.\nQ2. Is such a package eligible for the 49 CFR § 175.75(c) exception to the 25kg inaccessible\ncargo compartment limit?\nA2. Yes. A package prepared in accordance with 49 CFR § 173.63(b) is eligible for the\nexception in 49 CFR § 175.75(c).\nWe hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n1 Hazardous Materials: Harmonization with International Standards (RRR) (HM-215L; 78 FR\n988)","truncated":false,"body_characters":4512}