# Syncro Medical Innovations, Inc. — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 09-0084
- **title:** Syncro Medical Innovations, Inc. — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2011-03-21
- **effective on:** Not available
- **summary:** 09-0084 response to Syncro Medical Innovations, Inc. concerning 173.21.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-09-0084.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-09-0084.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-09-0084
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2009/090084.pdf
**body:**

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U.S. Department of Transportation 1200 New Jersey Ave, SE
Washington, D.C. 20590
Pipeline and Hazardous Materials
Safety Administration
M ;\") 2 1 ') 011
IHH ]. LUI
Mr. Lalit Sabramanian
Product Engineer
Syncro Medical Innovations, Inc.
20 W Federal Street, Suite M5B
Youngstown, OH 44503
Reference No. 09-0084
Dear Mr. Sabramanian:
This is in response to your letter concerning the provision in § 173.21(d) under the Hazardous
Materials Regulations (HMR; 49 CFR Parts 171-180) that forbids from transportation by aircraft
a package that has a magnetic field measurement of more than 0.00525 gauss at a distance of 4.5
meters (15 feet) from any surface of the package. We have paraphrased your questions and
answered them in the order you provided. We apologize for the delay in responding and any
inconvenience this may have caused.
The HMR also authorize use of the International Civil Aviation Organization (ICAO) Technical
Instructions for the Safe Transport of Dangerous Goods by Air (Technical Instructions) when all
or part of the transportation of a hazardous material is by aircraft, so we have included
information relative to these requirements. Under the provisions of §§ 171.22-171.24, the HMR
give shippers and carriers the option of preparing shipments of hazardous materials offered or
intended for transportation by aircraft in conformance with the ICAO Technical Instructions.
01. The earth's magnetic field is 0.5 gauss. Why then does § 173.21(d) forbid from
transportation by aircraft a package with a magnetic field measurement greater than
0.00525 gauss at a distance of 4.5 meters from any surface of the package when this
measurement is 100 times greater than that of the earth? Is this a typographical error or
are the units expressed in teslas?
AI. The magnetic field measurement in § 173.21(d) is expressed in gauss and is based on
tests conducted by the Federal Aviation Administration (FAA) to determine when a
magnetic material would adversely affect the operation of an aircraft. In a 1987 advisory,
entitled "Preparation and Loading of Magnetic Materials for Air Transportation"
(enclosed), the FAA concluded a material with a measurable magnetic field of more than
0.00525 gauss at a distance of 4.5 meters from any surface of the package can cause an
aircraft's magnetic compass or compass master unit to have "compass deviations as high
as 125 degrees, cause navigation errors, and jeopardize the safety of the transporting

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aircraft." The FAA is especially concerned magnetic fields of this strength will affect
older or smaller aircraft because they may have magnetic master units located inside or
near their cargo compartments. Under the HMR, packages with magnetic field of
0.00525 gauss or less at a distance of 4.5 meters are considered non-magnetic and are not
subject to regulation.
Effective January 1,2011, the ICAO revised its requirements for transporting magnetic
materials by aircraft in its 2011-2012 edition of the Technical Instructions. These
changes substantially revised the requirements for shipping magnetized material in
former Packing Instruction (PI) 902, moved this revised language to new PI 953, and
deleted PI 902. Specifically, the new requirements permit magnetized materials to be
transported by aircraft with magnetic field strengths that can cause a compass deflection
of 2 degrees or more at a distance of 2.1 meters but not more than 2 degrees at a distance
of 4.6 meters (equivalent to 0.418 amperes per meter (Aim) or 0.00525 Gauss measured
at a distance of 4.6 meters). Also, PI 953 excepts magnetized materials from all other
requirements under the ICAO Technical Instructions provided they comply with the
following:
1) the shipper must make prior arrangements with the operator (i.e., carrier) identifying
the magnetized material. The dangerous goods transport document requirements of
Part 5;4 are not applicable provided alternative written or electronic documentation
includes the words "magnetized material" in association with the description of the
goods;
2) the package must bear the magnetized material handling label (as shown in Figure 524
(enclosed) of Part 5; Chapter 3 of the 2011-2012 ICAO Technical Instructions);
3) the operator must stow the packaged magnetized material in accordance with 7;2.10;
and
4)' the incident reporting requirements of 7;4.4 must be met.
Finally, PI 953 requires magnetized material with a field strength sufficient to cause a
compass deflection of more than 2 degrees at a distance of 4.6 meters to be transported
only with the prior approval of the appropriate authority of the State (i.e., country) of
origin and the State of the operator.
02. If the magnetic field measurement in § 173.21(d) is not an error, is this a field value
relative to the earth's magnetic field of 0.5 gauss?
A2. Yes. Also see Answer A3.
03. Do you recommend any specific test to be able to measure magnetic field strength that is
this low?
A3. The HMR do not prescribe any test methods to measure a magnetic field strength.
Please note, however, that the ICAO Technical Instructions provide several methods for
measuring magnetic field strength in § 9.2.1(d).
2

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Q4. Is any special labeling or documentation required for us to transport this package?
A4. Under the HMR, a magnetized material is either not of sufficient magnetic strength to be
regulated or is forbidden in transportation (see § 173.21(d)); therefore, no labels or
shipping papers are required. However, the ICAO Technical Instructions require
magnetized material that is not excepted from regulation to be described on a shipping
paper as "UN 2807, Magnetized material, 9 (miscellaneous);" and marked and packaged
as prescribed in PI 953. The package must also be labeled with a MAGNETIZED
MATERIAL label that complies with the image in Figure 5-24 discussed earlier in
Answer AI. Also, packages correctly labeled with the MAGNETIZED MATERIAL
label under the ICAO Technical Instructions do not need to bear the Class 9
(MISCELLANEOUS) label (see § 3.2.11).
I hope this satisfies your request.
Sincerely,
r-:7f7'/tt/~~~
~ ~ e:r-:-:-~T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
Enclosures
3

<<<PAGE 4>>>

Advisory
u.s. Department
of Transportation Circular
Federal AvtatIon
AdmInistration
Subject:
PREP~R~TION ~ND LO~OING OF Date: 3-19-87 AeNo: 121-28
M1\GNETIC M~'r.FRV\LC; FOR ~IR Initialtd by: l\C~-lOO Change:
'l'Rl\N~PORTl\TrON
1. PURPOSE. This circular provides information relevant to the
preparation and loading of magnetic materials for shipment in
civil aircraft. ~ir transportation of improperly located or
improperly shielded magnetic materials presents specific hazards
in ~ircraft having compass master units located within the
fuselage. Magnetic materials which are loaded in the vicinity of
a magnetic compass or compass master unit could produce compass
deviations as high as 125 degrees, cause navigation errors, and
jeopardize the safety of the transporting aircraft. Physical
separation can contribute significantly to reduce magnetic
interference.
..
2. CA~CELLl\TIO~. l\dvisory Circular 121-23 dated 2-10-77 is
cancelled.
3. REFERENCE. Title 49 of the Code of ~ederal Regulations (49
CFR) Part l73.2l(f) strictly forbids the carriage by aircraft of
any material which, when packaged, has a measurable magnetic
field of more than 0.00525 gauss when measured from any surface
of the package at a distance of 15 feet. 49 CPR l75.85(g) states
no person may load magnetized material (which might cause an
erroneoQs magnetic compass reading) on an aircraft, in the
vicinity of a magnetic compass, or compass master unit, that is a
part of the instrument equipment of the aircraft, in a manner
that affects its operation. If this requirement cannot be met, a
special aircraft swing and compass calibration may be required.
4. UIC;CUC;SION. ~ material is considered to be magnetized when
it has a magnetic field strength greater than 0.00525 gauss at a
distance of 15 feet from any point on the surface of the package,
or which is of such mass that it could affect aircraft
instrumentation, particularly magnetic compasses. Such material
must be shielded to reduce the readings to a level that is no
greater than 0.00525 gauss before being offered for
transportation by aircraft.
Certain materials with a magnetic field of less than
0.00525 gauss were previously classified as hazardous materials.
~uto fenders, automotive parts, metal stock and other large metal
objects which are not intentionally magnetic, but have acquired
magnetic properties during their manufacture or because of their
-

<<<PAGE 5>>>

3119187
orientation with other cargo, fall into this category. Although
slightly magnetized, such materials pose little or no
transportation hazard. Modern aircraft use electronic compasses
with magnetic compasses as backups. The sensors for magnetic
backup compasses are s.ufficiently distant from the cargo bays,
that a measurable deflection effect on the compass will not be
caused by the potential marginal magnetic properties of metal
objects such as those mentioned above.
5. HAZARDS. The hazard associated with the carriage of
magnetized materials on older types of aircraft, where the
magnetic master units are not located outside and away from the
cargo compartments, is that a compass deviation as great as
125 degrees could be experienced and cause unacceptable
navigation errors which can jeopardize the safety of the
transporting aircraft.
6. PRECAUTIONS AND RECOMMEND~TIONS.
a. When offering magnetized materials for air transportation,
the shipper must ensure that each package has a magnetic field
strength no greater than 0.00525 gauss when measured at IS feet
from all surfaces of the package.
b. The shipper should also take the following measures when.
offering magnetized materials for air transportation: ..,
1. Whenever possible, magnets or magnetized devices should
be packaged so that the polarities of each unit opposes the
other.
2. Keeper bars should be installed on permanent magnets to
prevent the magnetic field from affecting the magnetic compass.
7. LOADING REQUIREMENTS. When accepting magnetized material,
aircraft operators should ensure that the shipper verifies that
the maximum field strength is no greater than 0.00525 gauss when
measured at IS feet f.rom all surfaces of the package. If the
aircraft being used does not have the magnetic compass master
unit in a remote location and amply distant from the cargo hold,
it is recommended that a special aircraft swing and compass
calibration be made after loading and prior to operation.
~ircraft operators should also check their compass calibration
when transporting large amounts of metal assemblies such as auto
fenders, frames, or other material which may not be magnetic in
themselves but may have magnetic properties due to their
manufacturing process or their orientation when placed aboard the
aircraft. Cargo of this nature should be placed aboard the
aircraft as far as possible from magnetic compass master units.
~1!:~
DIRECTOR OF C~~AVIATION SECURITY

<<<PAGE 6>>>

4
5-3-16 Part 5 Ch
(Magnetic)
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MAGNETIZED !
ERIAL :
I<EE~~~.~Y~~~ ~R~,A:~ ~~~,~~_ ~~T~.~T~~ ~~I~~ I
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Colour: blue on white
Dimensions: 110 mm)( 90 mm
Figure 5-24. Magnetized material
Colour: black'on orange
Dimensions: 120 mm )( 110 mm
Note.- Figure 5-24 as contained in the 2007-2008 edition of these Technicalll1structions may continue to I
be used until 31 December 2012. '
------------------------------------------------------------------------"
Figure 5-25. Cargo aircraft only
----------------~-------------------------------------------------------------
2011$2012 EDITION

<<<PAGE 7>>>

DOYf.:;~;PA, /OHI\1S
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09 ~PR 1 5 PN 3: I 5
Lalit Subramanian (SyncnJ "\1edi(.'al Inn:",.',(.';) ;'-,'.
20 W Federal St.. Suite MBa,
Youngstown, OH 44503
Phone: (234) 855-l620
£c/m~/}OCJI1
~ 173 ·21 (d)
Fa r biolc1en ita-zamtJII.S
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L.S. Dcp<.u-tmcnl of Transportation
Pipeline and Hazardous Safety Administration
()n'j,-e of ~hl:~Hrd()LiS Material
1JUG :\cw ,Jersey Ave SE
:;:;'sl Bu;ldicg. 2nd Floor
DC .?O590
Subject: Request for verification of specification in 49CFR §173.21(d) [Ref. # for Letter of Interpretation - 020316]
Dear Sir/Madam:
We are a medical device company and our product is a magnetically-guided enteral feeding tube. We are
required to ship magnetic material. Could you please get back to me on the matter described below?
49CFR §173.21(d) states that, in order for magnetized material to be considered hazardous, the magnetic field
measured at a distance of 15ft from the package must be at least 0.00525 gauss. We believe this specification
to be in error, since the Earth's magnetic field is 0.5 gauss, which is 100x greater than this specification. We
believe this is possibly a typographical error or the units are teslas and not gauss as stated?
If not, is this field value relative to the Earth's magnetic field of 0.5 gauss? Do you recommend any specific test
to be able to measure field strength of this low magnitude? Finally, is there any special labeling or other
documentation required in order for us to transport this package?
Thank you very much for your assistance in this matter.
Sincerely,
~
---
Lalit Subramanian
Product Engineer
Syncro Medical Innovations, Inc.
April 7, 2009
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