Singapore Airlines Ltd — Hazardous Materials Safety Interpretation

Page 1of 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 2SINGAPORE 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#