Alaska Air Group, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave.. S.E Washington, DC 20590 Mr. Mike Tobin Manager Dangerous Goods Alaska Air Group, Inc. P.O. Box 68900 - SEADG Seattle, WA 98 168 Ref. No. 08-01 59 Dear Mr. Tobin: This is in response to your June 3,2008 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 - 1 80) applicable to cargo-only aircraft. Specifically, you ask whether it is permissible to transport on cargo-only aircraft an unlimited number of packages authorized for transport on passenger aircraft if the packages are in a freight container and accessible. You also ask how the limits on packages in inaccessible cargo locations apply. As specified in 8 175. 75, there is no limit to the number of packages that are authorized onboard a cargo-only aircraft if packages are in a freight container and are accessible. Only the packages that are inaccessible in a cargo compartment are subject to the limit of 25 kg per compartment plus an additional 75 kg of Division 2.2 materials. I hope this information is helpful. Sincerely, A9h2- 84) Susan Gorsky, Regulations Officer Office of Hazardous Materials Standards#

Page 2June 3, 2008 Edward T. Mazzullo Director, Hazardous Materials Standards Pipeline and Hazardous Materials Safety Administration U.S. Department of Transportation East Building, PHH- 10 1200 New Jersey Avenue, SE Washington, D.C. 20590-000 1 5115-75- 5 y car 0 hrrlrart b 6 -0 157 Dear Mr. Mazzullo, Alaska Airlines kindly requests formal interpretation of 49CFR175.75 a s it pertains to our 737-400 all-cargo aircraft. Here are the questions, with illustrated explanations attached. 1) Quantity in a freight container Question: I s it permissible to have onboard a Cargo Aircraft, an unlimited amount of packages authorized for transport onboard a passenger aircraft, in an accessible cargo compartment, if packages are in a freight container, and accessible? 2) Definition of cargo compartment Question: Does the "per containern limit apply up until the first package, is inaccessible, at which point all packages aft must comply with the per compartment limit, or does the fact any package is inaccessible render the entire main deck compartment subject to the "inaccessible-per compartmentn limit? Thank you very much for your assistance. Mike Tobin, CHMM Manager Dangerous Goods Alaska Air Group, Inc. P.O. Box 68900 - SEADG Seattle, WA 98 168 (206) 392-9848 . fa^ (206) 392-9832#

Page 31) Quantity in a freight container Question: Is it permissible to have onboard a Cargo Aircraft, an unlimited amount of packages authorized for transport onboard a passenger aircraft, in an accessible cargo compartment, if packages are in a freight container, and accessible? Why the question? It appears that no limit of packages bearing the orange Cargo Aircraft Only label are allowed in a freight container - provided they are accessible, where as; It appears less dangerous cargo (i.e. items that can travel on a passenger-carrying aircraft) are limited to 25 kg per freight container - since no differentiating is done between whether or not the packages are accessible in the container. "No limit" is already provided for accessible packages in accessible compartments. 49CFR 175.75 Quantity and Loading Tables Cargo O W AlrcraR container container contarner container What is doesn't seem logical.#

Page 42) Definition of cargo compartment Question: Does the "per container" limit apply up until the first package is inaccessible, at which point all packages aft must comply with the per compartment limit, or does the fact any package is inaccessible render the entire main deck compartment subject to the "inaccessible-per compartment* limit? Cargo Only brcrah Packages Aumonred for Transpon Onbo~rd a Passenger &ruafi Exumpl~, cr 10 position fi-eighter. i~ Iocrdrd with 3 position., on open flu! pullets fgrcrn), andposition 4-10 ure hurcl sided. inuccr.r.sihIr~fi-right c.ontainer:r (red). Are these statements correct based on this example? There is no limit in the green section (bulk, ULD positions 1, 2 and 3) as long as: 'The main deck is accessible. 'The packages are accessible, for example military boards (or other flats or pallets) are used; and 'The crew can access the packages 25 kgl75kg rule applies to the rest of the main deck (red section (ULD positions 4,5,6,7,8,9 and 10) once ULDs are inaccessible to the crew while inflight.#