Dangerous Good of America — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave, S.E. Washington, D.C. 20590 AP~ l 6 1013 Fred A Romero Dangerous Good of America 1651 NW 681 h St., Cargo Building 706 Suite 211 Miami, FL 33152-0487 Reference No. 13-0033 Dear Mr. Romero: This is in response to your January 11, 2013 letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) requesting clarification of the Hazardous Materials Regulations (HMR; 49 CPR Parts 171-180), applicable to the use of the letter "G" on shipping papers. In your letter, you note that§ 172.202(a)(6)(vi) states that for items where "No Limit" is shown in Column (9A) (Quantity limitations for passenger aircraft/rail) or (9B) (Quantity limitations for cargo aircraft only) of the Hazardous Materials Table (HMT), the quantity shown must be the net mass or volume of the material. For articles (e.g., UN2800 and UN3166), the quantity must be the gross mass, followed by the letter "G." You also note that in the International Civil Aviation Organization Technical Instructions (ICAO TI), as well as the International Air Transport Association Dangerous Goods Regulations (IAT A DGR), the letter "G" is no longer required on the shipping paper or the shippers declaration. You ask if you must include the gross mass followed by the letter "G" as required by the HMR, or may you exclude the letter "G" on the shipping paper as indicated in the ICAO TI and lATA regulations. The provisions of§§ 171.23 and 171.24 of the HMR authorize the use of the ICAO TI for packaging, marking, labeling, classifying, and describing hazardous materials which are transported by air and by motor vehicle either before or after being transported by air. Therefore, if your shipment is being transported in accordance with the ICAO TI as authorized by the HMR, the letter "G" would not be required on the shipping paper. I hope this satisfies your request. Sincerely, T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2DANGEROUS GOODS OF AMERICA® PO BOX 520487 + MIAMI, FL 33152-0487 USA Phone (305) 871-3313 + Fax (305) 871-1388 E-mail: info@.dga4u.com Web: www.dga4u.com January 11, 2013 U.S. Department of Transportation Associate Administrator for Hazardous Materials Safety Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave., SE East Building, Second Floor Washington, DC 20590 USA Dear Rulemakers; According to § 172.202 (6)(iii)(vi) For items where "No Limit" is shown in Column (9A) or (98) of the § 172.101 table, the quantity shown must be the net mass or volume of the material. For articles (e.g., UN2800 and UN3166) the quantity must be the gross mass, followed by the letter "G"; In the International Civil Aviation Organization (ICAO) Technical Instructions as well as in the International Air Transportation Association (lATA), the letter "G" is no longer required on the shipping paper or shipper's declaration. My question to you is if I must include the gross mass followed by the letter "G' or may I not include the letter "G" as indicated in the ICAO and lATA regulations without consequences? - ~,\ Thank you for )1our prompt reply to this matter. Sincerelyt·· .c ::·· 't 1 t . .. V1tU;,k. L--Free(ARomer~ :%~~~uctor Office & Warehouse Facility • 1651 NW 68TH Ave • Cargo Bldg. 706 • Suite 211 Miami International Airport • Miami, FL 33126#