{"operation":"document","citation":"02-0137","title":"Singapore Airlines Ltd — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2002-06-28","effective_on":null,"summary":"02-0137 response to Singapore Airlines Ltd concerning 173.222.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0137.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0137.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0137","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020137.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nJS. Department\n400 Seventh Street, S.W.\nWashington, D.C. 20590\nResearch and\nSpecial Programs\nAdministration\nJUN 2 8 2002\nMr. Muthusamy Chandran\nRef. No. 02-0137\nSenior Officer\nSingapore Airlines Ltd.\nAirline House 05A\nSingapore\nDear Mr. Chandran:\nThis is in response to your April 16, 2002 letter regarding the classification of a material under the\nHazardous Materials Regulations (HMR;49 CFR parts 171-180). Specifically, you ask if Mobil\nJet Oil or Skdrol contained in hydraulic parts is considered a hazardous material for air\ntransportation.\nAlthough you did not provide material safety data sheets (MSDS) for these products, you state\nthat the MSDS for these materials do not indicate they are hazardous for air transportation and\nthat they can be air freighted as normal cargo. Subsequently, the materials in your hydraulic parts\nwould have to exhibit some characteristic that would make them hazardous for transportation,\nincluding by air. If the materials in your hydraulic parts do not meet the definition of a hazardous\nmatenal, such as a flammable liquid, and the internal fluid is identical in nature to the material\nlisted in the MSDS, then it would appear that the hydraulic parts you described are not subject to\nthe HMR.\nIt is up to the offerer to determine if their material is hazardous or not. Additionally, your\nmaterial may be subject to applicable requirements of the International Civil Aviation\nOrganization's Technical Instructions.\nI hope this satisfies your request.\nSincerely,\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n173.222\n020137\n\n<<<PAGE 2>>>\n\nSINGAPORE AIRLINES LIMITED\nMr. Ed Mazzullo\nJohnsen\nResearch and Special\nDepartment of Transport\nPrograms Administration\n3173.222\n$173.27\nIMDG\n16* April 2002\n02 - 0137\nDear Mr Ed,\nI have a question, which has been nagging me for sometime. I hope you can help me with it.\nMobile Jet Oil, used in aircraft engines and Skdrol. LDA, used in hydraulic parts are not classified as dangerous\nnormal cargo.\ngoods as per their respective manufacturers Material Safety. Data Sheet. These fluids can be air freighted as\nparts, considered dangerous.\nWhen the unserviceable parts are removed from the aircraft, is the Mobil Jet Oil or Skdrol contained in these\n!\nCan these parts be still air freighted as normal cargo or should they be declared as dangerous goods.\nIf it is to be declared as dangerous goods, under which Proper Shipping Name should these fluids be classified.\nreplying to me.\nI do hope to receive your reply as soon as possible. I would like to thank you in advance for taking your time in\nOnce again thank you very much.\nYours Truly,\nCherchann\nSenior Officer\nM Chandran\nEngineering Supplies Dept\nSingapore Airlines Ltd\nAirline House 05A\nSingapore\nFax: (65) 6545 7548\nTel: (65) 6541 4950\nEmail: chandran_ muthusamy@singaporeair.com.sq","truncated":false,"body_characters":2893}