{"operation":"document","citation":"08-0146","title":"L-3 Vertex Aerospace LLC — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2008-06-25","effective_on":null,"summary":"08-0146 response to L-3 Vertex Aerospace LLC concerning 173.22, 173.222.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0146.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0146.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0146","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2008/080146.pdf","body":"<<>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Ave . S E\nWashington, DC 20590\nJUN 2 5 2008\nStephen W. Miller\nL-3 Vertex Aerospace LLC\n555 Industrial Drive South\nMadison, MS 391 10\nRef. No. 08-0146\nDear Mr. Miller:\nThis responds to your May 19,2008 letter requesting clarification of the proper shipping\nname for aircraft fuel nozzles under the Hazardous Materials Regulations (HMR; 49 CFR\nParts 171 -1 80). Specifically, you ask if nozzles that are removed and sent back to the\nmanufacturer for servicing should be shipped as \"Dangerous Goods in Apparatus\" or non-\nhazardous. Your letter indicates that all fuel residue is removed from the nozzles using\npressurized air.\nGenerally, items classified as \"Dangerous Goods in Apparatus\" (e.g., fuel pumps and\ninjectors, engines, parts, etc.) contain the residue of a hazardous material. If the aircraft fuel\nnozzles you describe have been completely drained, sufficiently cleaned of residue, and\npurged of vapors to remove any potential hazard then they are no longer considered\nhazardous materials. As such, they are not subject to the HMR and may be shipped as non-\nhazardous ( 5 173.22). You should note, however, as the shipper it is your responsibility to\nproperly class the nozzles for transportation; this office cannot make that determination for\nyou.\nI hope this information is helpful. Please contact us if you require additional assistance.\nSincerely,\n,&%L-\nSusan Gorsky,\nActing Chief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<>>\n\nDrakeford, Carolyn \nFrom:\nSent:\nTo :\nCc:\nSubject:\nINFOCNTR \nMonday, lMay 19,2008 2:01 PM\nDrakeford, Carolyn \nNickels, at thew \nFW: Information Center Cornrnents/Questions\nCarolyn,\nHere is the initial interp request. I never sent it my apologies. It wasn't very\napparent he wanted an actual written letter.\nThanks rob\n----- Original Message-----\nFrom: Stephen.Miller@L-3com.com [mailto:Stephen.Miller@l-3com.com]\nSent: Thursday, May 15, 2008 3:51 PM\nTo: INFOCNTR \nSubject: Information Center Comrnents/Questions\nBelow is the result of your feedback form. It was submitted by Stephen W. Miller\n(Stephen.Miller@L-3com.com) on Thursday, May 15, 2008 at 15:50:48.\nName: Stephen W. Miller\nCategory: Interpretations (Letters) issued by PHMSA\nOrganization: L-3 Vertex Aerospace LLC\nStreet: 555 Industrial Drive South\nCity: Madison\nState: Mississippi\nZip Code: 39110\nPhone: 601-607-6480\nFax: 601-607-6276\nComments: We have aircraft fuel nozzle kits that have to be shipped by air. They contain\nfuel nozzles (14 in total). The nozzle have fuel that flows into them and then is sprayed\ninto the combustion chamber of the engine. When the engine is shutdown air pressure is\nsent back through the nozzles removing all fuel residue. The nozzles are removed at a\nrequired time change and sent back to the manufacturer for servicing and then retuned to\nthe field to be placed into another engine. Would these fuel nozzle kit be considered\nclass 9 Dangerous Goods in Apparatus or as a non-hazardous item when shipped by air?\n\n<<>>\n\nPage 1 of 1\nDrakeford, Carolyn \n-..--- ------.w*vv< \".- .w---%m-- \". -\" %-%-- *\"\"-- --- \" -*-%% v v --*-- m --*-- +..\" - \"--.* . \" ~---\"\nFrom: INFOCNTR \nSent: Monday, May 19,2008 9:44 AM\nTo: Drakeford, Carolyn \nCc: 'Stephen.Nliller@l-3com.com'\nSubject: FW: Interpretation letter\nImportance: High\nAttachments: PHMSA INT.ppt\nCarolyn,\nThis is some additional information for a letter of interpretation I forwarded to you last week. See below.\nThanks,\nRob\nFrom: Stephen.Miller@l-3com.com [mailto: 1\nSent: Monday, May 19, 2008 9:32 Alvl\nTo: INFOCNTR \nSubject: Interpretation letter\nImportance: High\nI sent a request for an interpretation on the 15th of May and I am sending the following file to give a better\nexplanation of the question I am asking.\nIs it possible that this nozzle kit could be classified as a Dangerous Goods in Excepted Quantities if it is\nconsidered to be hazardous when shipping by air?\nStephen W. Miller\nT6A Training Administrator\nL-3 Vertex LLC\nSte~!!.e.n,.M~!!.er@L-3com .... c.0m.l.\n601-607-6480\n601-607-6276 (fax)\nThis document may contain unclassified technical data whose export, transfer and/or disclosure is\nrestricted by United States law. Dissemination to non-US persons, whether in the United states or abroad\nrequires an export license or other authorization.\nThe information contained herein, including any attached documents or files, is confidential, may be\nlegally privileged and is solely for the intended recipient(s). If you received this information in error,\nplease destroy it and notify the sender immediately by reply e-mail, letter fax or phone. Any unauthorized\nuse, dissemination, disclosure, coping or printing is strictly prohibited.\n\n<<>>\n\n1. Fuel flows thru here\nduring operation\nThis shows the actual size of the nozzle\nne shu\n~ i r is se\n!I nozzl\nig all fi\n2. Fuel sprayed into\ncombustion chamber\nthru this nozzle point\n\n<<>>\n\nPACKING OF THE NOZZLE KIT\n1. Each nozzle is placed inside of leak proof liner\n\n<<>>\n\nAll of the nozzles are then placed inside\nof the plastic box they were received in\n3. The plastic box is then wrapped with cushioning material\nfrom the manufacturer.\nplaced in fibreboard box they were received in from\n2.\nthe manufacturer.\nany 1953.\n\n<<>>\n\n4. The box is then closed and all seams are sealed\nhazmat shipping tape.","truncated":false,"body_characters":5500}