American Airlines — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials 1200 New Jersey Avenue, SE Washington, DC 20590 Safety Administration Mr. Michel A. Wentz Manager, Dangerous Goods Compliance MAR 2 4 2015 Safety, Security, & Environmental American Airlines 4333 Amon Carter Blvd. Fort Worth, TX 76155 Reference No. 15-0016 Dear Mr. Wentz: This responds to your December 22, 2014 letter requesting clarification on transporting Class 7 materials under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- 180) aboard passenger aircraft. Section 175.700(a) prescribes that no person may carry any Class 7 materials aboard a passenger-carrying aircraft unless that material is intended for use in, or incident to research, medical diagnosis or treatment. Regardless of its intended use, no person may carry a Type B(M) package aboard a passenger-carrying aircraft, a vented Type B(M) package aboard any aircraft, or a liquid pyrophoric Class 7 material aboard any aircraft. You ask if a passenger aircraft operator may transport Type B(U) packages containing vials of liquid radioactive Molybdenum 99 (Mo99) and the return of empty Type B(U) containers as Type A packages, provided the requirements applicable to radioactive materials incident to research, medical diagnosis or treatment are satisfied. The answer to your question is yes. Radioactive materials in Type B(U) and Type A packages that do not exceed a transport index of 3.0 and intended for use in or incident to research, medical diagnosis, or treatment may be transported on board passenger-carrying aircraft in accordance with §§ 173.448(f) and 175.700(a). I trust this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, Jane A. Duane A. Pfund International Standards Coordinator Standards and Rulemaking Division#

Page 2Manager, Dangerous Goods Compliance Michel A. Wentz American Airlines Safety, Security & Environmental luiener $10 706) December 22, 2014 1'13. 10: Oper 0 limitatious U.S. DOT PHMSA Office of Hazardous Materials Standards 15-0016 Attn: PHH-10 East Building 1200 New Jersey Avenue, S.E. Washington, D.C. 20590-0001 RE: Type B(U) packages of radioactive materials transported by air Dear Sir, In 49 CFR 175.700 (a) it states: (a) Except as provided in 173.4a, 173.422 and 173.423 of this subchapter, no person may carry any Class 7 materials aboard a passenger-carrying aircraft unless that material is intended for use in, or incident to research (See 171.8 of this subchapter), medical diagnosis or treatment. Regardless of its intended use, no person may carry a Type B(M) package aboard a passenger-carrying aircraft, a vented Type B(M) package aboard any aircraft, or a liquid pyrophoric Class 7 material aboard any aircraft. In 49 CFR 173.403, Definitions under "Package" it states; (4) "Type B package" means a packaging designed to transport greater than an A1 or Az quantity of radioactive material that, together with its radioactive contents, is designed to retain the integrity of containment and shielding required by this part when subjected to the normal conditions of transport and hypothetical accident test conditions set forth in 10 CFR part 71. (i) "Type B(U) package" means a Type B packaging that, together with its radioactive contents, for international shipments requires unilateral approval only of the package design and of any stowage provisions that may be necessary for heat dissipation. Fort Worth, TX 76155 4333 Amon Carter Blvd. 817 931 6892 Office Mike.wentz@aa.com 817 931 6392 Fax#

Page 3American Airlines We are requesting clarity that authorized type B(U) packages with materials intended for use in, or incident to research, medical diagnosis or treatment are acceptable for air transport per 49 CFR 175.700. Provided all other requirements of 49 CFR for transportation of radioactive materials incident to research, medical diagnosis or treatment are met, is a passenger carrier such as American Airlines permitted to carry authorized Type B(U) packages as defined in 49 CFR 173.416 containing vials of liquid radioactive Molybdenum 99 (Mo99) and the return of empty Type B(U) containers as Type A packages? Sincerely, michla.Wat Michel A. Wentz Manager, Dangerous Goods Compliance Safety, Security & Environmental#