Air Transport International, L.L.C. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation esearch ant Administration pecial Program MAY 3 0 2001 Mr. Jack Hagenmayer Director Ref. No. 00-0285 Aircraft Ground Services Air Transport International, I.I.C. One Air Cargo Parkway East Swanton, Ohio 43558-9490 Dear Mr. Hagenmayer: This responds to your letter regarding the quantity limitation and package containment requirements for hazardous materials transported by cargo-only aircraft under the Hazardous Materials Regulations (HMR; 49 CER Parts 171-180). Your questions are paraphrased and answered as follows: Q1. Is it acceptable to stow 25 kg net weight of hazardous material and, in addition, 75 kg net weight of Division 2.2 non-flammable compressed loaded in an accessible cargo compartment on the main deck gas, in a freight container that is of a cargo-only aircraft? upon multiple freight containers containing hazardous What limit, if any, is placed materials? S 175.75 (a) (2) (ii) permits 25 kg of hazardous materials and, the cargo compartment is accessible, in addition, 75 kg net weight of Division 2.2 non-flammable gas, that are acceptable on a passenger-carrying aircraft, to be loaded in each freight container regardless of the number of containers in the compartment. compartment is inaccessible, the 25 kg/75 kg limit applies If the cargo to the entire compartment. As specified in § 175.85 (b), hazardous materials acceptable only on cargo aircraft must be stowed in such a manner that within an accessible compartment, they may be stowed in a Ireight container or other suitable containment without regard to the weight limitation. Certain hazard classes that may be carried in an inaccessible location without in $ 175.85 (c) (1). regard to the § 175.75 (a) (2) weight limitation are specified 175.75 000285#

Page 2- - definition of a freight container? Do pallet and net/strap combinations meet the and net combinations subject to the weight limitations in Are accessible pallet $ 175.75 (a) (2)? A2. combination with a No. A pallet, which is a bottom platform used in definition in S 171.8 of a freight container. net or straps, does not meet the used in combination with a net, would meet the definition in A pallet, § 171.8 of a unit load device. For transportation by cargo- only aircraft, passenger authorized hazardous materials loaded on an accessible unit load device within an accessible compartment are not subject to the weight limitations specified in § 175.75 (a) (2). I trust this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely, Hatter. miles Hattie I. Mitchell Office of Hazardous Materials Standards Chief, Regulatory Review and Reinvention#

Page 3Stevens One Alr Cargo Parkway East Air Transport internatonal, L.L.C. ATI $ 175.75 (a) (2) (ili) Santon, Ohio 435589490 171.8 Fax: /Admn (419) 867-0138 Tel: (419) 867-9911 AIR TRANSPORI INTERNATIONAL, L.I.C. Fax: /Operation (419) 867-0393 Aircraft October 10, 2000 Definition Fax 202-366-3012 00-0285 Edward Mazzullo Director for the Office of Hazardous Material Standards US Department of Transportation Research and Special Programs Adminisration (DHM10) 400 7* Street SW Washington, DC 20590-0001 Dear Mr. Mazzullo: I am writing to you for clarification of 49 CFR, Subpart B, 175.75(a)(2)(iii) and 171.8 "Freight Container". Is it acceptable to carry 25 kg net weight of hazardous materials and in addition thereto, 75 kg net Question 1: weight of Division 2.2 (non-flammable compressed gas) in each freight container loaded on the main deck of a cargo aircraft's main deck? The cargo aircraft's main deck is accessible to the flight crew through an access door in the 9g bulkhead. Based on the definition of a "freight container" in 171.8, I assume that the answer is yes. Does the definition of a "freight container" also include aircruft pallet/net combination and aircraft Question 2: pailet/cargo strap combinations providing their volume is 64 cubic feet or more? I assume that the answer is yes because aircraft pallets used in combination with nets or cargo straps are designed and constructed to permit being lifted with its contents and intended primarily for containment of packages (in unit form) during transportation. If my two assumptions above are incorrect would it be possible to discuss this matter with someone on the telephone so I can better understand the intent of these rogulations. My telephone number is 419-867-9911 × 2241 and my fax is 419-867-0138. I look foniard to your response. Fack guys Director, Aircraft Ground Services FAA Question on Requlations. doc SubsIdiary of BAX Global Inc.#