Northern Air Cargo — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration MAR 17 2008 1200 New Jersey Avenue, SE Washington, D.C. 20590 Mr. Mark Smith Hazardous Materials Instructor Northern Air Cargo Anchorage, AK 99502 Ref. No. 07-0236 Dear Mr. Smith: This responds to your December 18,2007 email requesting clarification of the shipping paper requirements for consumer commodity (ORM-D) materials under the hazardous materials regulations (HMR; 49 CFR Parts 17 1 - 180) and the Internationals Civil Aviation Organization (ICAO) Technical Instructions (TI). You note that under the ICAO TI, for a material described as an "ID8000, consumer commodity, 9," the gross mass may be indicated on the shipping paper using the average gross mass per package (for example, if there are 10 packages and the total gross mass of them is 100 kg, the dangerous goods transport document may show this as "average gross mass per package 1Okg"). You ask if the HMR permit the use of average gross mass per package to indicate total quantity on shipping papers for domestic transportation of consumer commodity, ORM-D materials by air. The answer is no. For transportation by aircraft, the gross mass per package is required to be indicated on the shipping paper for consumer commodity (ORM-D) materials (5 172.202(a)(6)). The use of average gross mass per package is not authorized by the HMR. Note that 5 17 1.22 authorizes the use of the ICAO TI for transportation of hazardous materials by aircraft. Therefore, average gross mass per package may be used to describe the quantity of a material on a shipping paper when the material is described as "ID8000, consumer commodity, 9" in accordance with the ICAO TI. Please keep in mind that many hazardous materials that qualify as ORM-D consumer commodities under the HMR may not qualify as Class 9 consumer commodities under the ICAO TI. I hope this information is helpful. Please contact us if you require additional assistance. Chief, Standards Development Office of Hazardous Materials Standards#

Page 218 Dec 07 NORTHERN AIR CARGO Office of Hazardous Materials Standards Pipeline and Hazardous Materials Safety Administration, Attn: PHH-10 U.S. Department of Transportation, East Building 1200 New Jersey Avenue, SE. Washington, DC 20590-000 1 Re: Using average gross mass for piece and weight description of 'consumer commodity ORMD' on shipping papers for air transport. Under the ICAO Technical Instructions, packing instruction 91 0(1)(2), a shipper is allowed to offer an average gross mass of packages for an ID8000, consumer commodity, 9. (For example, if there are 10 packages and the total gross mass of them is 100kg, the dangerous goods transport document may show this as "average gross mass per package 1 Okg".) This option is not given under 49CFR, but its use is not restricted for domestic air transport under 49CFR 17 1.22, 17 1.23 & 17 1.24. Is this description allowed to be used domestically for air shipments? If so, is it restricted to the definition of an ID8000, consumer commodity, 9 as defined in ICAO packing instruction 910, or can the definition and reclassification of a consumer commodity ORMD offered under 49CFR be used? Sincerely, Mark Smith Hazardous Materials Instructor Northern Air Cargo 907-249-5 186 NORTHERN AIR CARGO INC 3900 Old International Airport Rd Anchorage AK 99502 907-243-3331 800-727-21 41 FAX 907-249-51 90 WWW.NORTHERNAlRCARGO.COM#