{"operation":"document","citation":"13-0203","title":"United Airlines, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2014-05-01","effective_on":null,"summary":"13-0203 response to United Airlines, Inc. concerning 175.75.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0203.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0203.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0203","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2013/130203.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nMAY 0 1 2014\nMr. William B. Wojtas\nManager, Dangerous Goods\nUnited Airlines, Inc.\n233 South Wacker Drive\nChicago, IL 60606\nRef. No.: 13-0203\nDear Mr. Wojtas:\nThis is in response to your October 16, 2013 letter requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) regarding the standard for converting\nliters to kilograms. In your letter, you ask if the specific gravity of a liquid must be used\nwhen converting from volume (liters) to net mass (kilograms) in situations when the net mass\nis required by the HMR such as determining compliance with the loading requirements of\n§ 17 5. 7 5 and verifying the maximum gross weight authorized as a limited quantity. You state\nthis conversion is difficult for air cargo acceptance personnel because neither the HMR, nor\nthe International Civil Aviation Organization Technical Instructions for the Safe Transport of\nDangerous Goods by Air (ICAO TI) mandate provision of the specific gravity or density as\npart of the information to be provided by shippers. You ask if a 1 liter to 1 kilogram ( 1:1\nratio) volume to mass conversion is acceptable for all liquid hazardous material.\nIn a previous letter of interpretation, 10-0145, dated December 3, 2010, applicable to this\nscenario, guidance was provided by stating that when the net quantity shown on shipping\ndocuments is expressed as a volume (e.g. liters) the net mass expressed in kilograms may be\ncalculated from the net volume by multiplying the volume of the liquid expressed in liters by\nits specific gravity. However, in this case the HMR do not require the use of a specific\nmethod for converting units of measure. Therefore, as an alternative to the use of specific\ngravity data, a 1: 1 conversion ratio where 1 liter is equal to 1 kilogram may be used for the\npurposes of interpreting the HMR cargo quantity limitations expressed in kilograms.\nI hope this information is helpful. If you have further questions, please do not hesitate to\ncontact this office.\nInternational Standards Coordinator\nStandards and Rulemaking Division\n---~----~--~\n\n<<<PAGE 2>>>\n\nW1€V\\e~\n§ 115.33\n§ 11!J ·1_)\nA-ir\n13-0203\n16 October 2013\nUS Department of Transportation\nPHMSA\nOffice of Hazardous Materials Standards\nAttn: PHH-10\nEast Bldg.\n1200 New Jersey Ave. SE\nWashington DC 20590-001\nSubject: Liters to Kilogram Conversion Standard\nFAA regulators indicate that the specific gravity must be used in the conversion of liquid\nvolume to mass when determining compliance with 49 CFR 175.33 (PNF) and\n175.75/ICAO Tl US-13 (25kg limitations).\nCurrently, there exists an industry conversion standard of 1 liter to 1 kilogram based on\nthe specific gravity of water at 4 degrees Celsius at sea level. This was validated in an\nemail from lATA dated 09 July 2013 where the Secretary of the Dangerous Goods\nBoard indicated that using this 1:1 ratio is a viable option based on the information\nrequired by ICAO for shippers to provide.\nThere is a single reference to using this conversion factor in the ICAO Tl in Part 5\nChapter 4.1.5.1 (b) \" ... the net mass of liquids within the kits is to be calculated on a 1\nto 1 basis of their volume, i.e. 1 litre equal to 1 kilogram.\" for chemical kits. While\n49CFR173.161 does not specifically state that this standard conversion is used, it\nalludes to it in 173.161(c)(3)\n(3) No more than 10 L or 10 kg of hazardous material may be contained in one outer\npackage (excluding dry ice). For transportation by aircraft, no more than 1 Lor 1 kg of\nhazardous material may be contained in one kit\nSince 49CFR 175.75 limits the amount of DG which can be carried onto an aircraft to\n25Kgs, using this conversion factor of 1:1 would have minimal impact on safety. For\nExample: The specific gravity of Isopropyl Alcohol is .8 and the maximum net quantity\nallowed is 5L. This calculates to 4Kg in mass or a difference of 1 Kg if the 1:1 ratio is\nused. This is a very small difference. Conversely, mercury, having a specific gravity of\n13.6 is shipped in small quantities (average shipment size over 3 months was .25L)\nwould have a slight difference of 3.1 kg.\n233 South Wacker Drive Chicago, IL 60606 A STAR ALLIANCE MEMBER\n\n<<<PAGE 3>>>\n\nThere seems to be some tolerance in conversion difference, particularly with smaller\nquantities. ICAO Tl Part 1 Chapter 3 Table 1-1 indicates that for 500kg or less, a\nconversion factor of 1 kg= 2.0Lbs may be used instead of the 2.205Lb factor. This\nresults in a 2.6Kg difference when converting a 55Lb shipment using the 2.0 factor vice\nthe 2.205 factor. This indicates that an argument using the 1:1 ratio would create too\nmuch of a weight difference, is difficult to prove when the ICAO allows for a slight\ndifference in shipments under 500Kg.\nOne factor which causes the use of the 1:1 ratio in converting volume to mass is the fact\nthat neither ICAO regulations nor the US Regulations mandate provision of the specific\ngravity as part of the required information to be provided by the shippers. Because this\ninformation is not required, it is not available to our front line employees to accurately\ncalculate the volume to mass conversion.\nOne of the most commonly converted items is UN3082 Environmentally Hazardous\nSubstance, Liquid NOS, which requires that the volume be converted to mass for limited\nquantities to ensure that the 30KgG (173.156 and ICAO Tl Table 3-1) is not exceeded.\nFor the frontline employee accepting dangerous goods, finding the specific gravity for\nthis particular UN number via the use of a Chemical Dictionary as suggested by some\nFAA regulators is not an easy task and may impede commerce by frustrating cargo.\nUN3082 is just one example used to illustrate the need for a 1:1 conversion standard.\nThere may be others that require this method of conversion.\nIn light of the above, I conclude that all shippers are allowed to use a 1.1 conversion of\nvolume to mass for all liquid hazardous materials since the necessary information is not\nrequired to be provided by the shippers. Please let me know if PHSMA agrees with this\ninterpretation.\nRegards,\nJt/1/tfl~\nWilliam B.~\nManager, Dangerous Goods\nUnited Airlines Inc.\n233 South Wacker Drive Chicago, IL 60606 A STAR ALLIANCE MEMBER","truncated":false,"body_characters":6347}