Alaska Airlines - SEADG — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Washington. DC 20590 1200 New Jersey Avenue SE Materials Safety Pipeline and Hazardous Administration SEP 2 1 2015 Mr. Mike Tobin, CHMM Manager, Dangerous Goods Alaska Airlines - SEADG P.O. Box 68900 Seattle, WA 98168 Reference No.: 15-0134 Dear Mr. Tobin: This responds to your June 26, 2015 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding quantity limitations and cargo location for carriage aboard passenger-carrying aircraft under § 175.75(c). Your questions are paraphrased and answered in the order you provided. Q1. Can 100 kg of Division 2.2 (non-flammable compressed gas) be loaded in an inaccessible manner if that is the only hazardous material subject to the quantity limits in § 175.75 (c)? Al. The answer is yes. In accordance with § 175.75(c), for each package containing a hazardous material acceptable for carriage aboard passenger-carrying aircraft, no more than 25 kg (55 pounds) net weight of hazardous material may be loaded in an inaccessible manner. In addition to the 25 kg limitation, an additional 75 kg (165 pounds) net weight of Division 2.2 (non-flammable compressed gas) may be loaded in the same compartment. As such, a package with a net weight of 100 kg of Division 2.2 may be loaded on a passenger- carrying aircraft in a single compartment in an inaccessible manner. Q2. Please confirm the following three scenarios of different inaccessible aircraft cargo compartments are all in compliance with the regulation-- Compartment A: 25 kg Class 3, PG I, and 75 kg Division 2.2 Compartment B: 50 kg Class 9 and 100 kg Division 2.2 Compartment C: 10 kg Class 3, PG I, and 90 kg Division 2.2 A2. Your understanding is correct. All three scenarios described above meet the quantity limitations prescribed in § 175.75(c) for packages containing hazardous material acceptable for carriage aboard passenger-carrying aircraft loaded in an inaccessible manner.#

Page 22 I trust this satisfies your inquiry. Please feel free to contact us if you need further assistance. Sincerely, Diane A. Pful Duane Pfund International Standards Coordinator Office of Standards and Rulemaking#

Page 3antonielli $ /75.75 Load/unload Alaska Airlines. 15-0134 June 26, 2015 PHMSA Office of Hazardous Materials Standards U.S. Department of Transportation Attn: PHH-10 East Building Washington, D.C. 20590-0001 1200 New Jersey Avenue, SE Interpretation Request 175.75(c) passenger-carrying aircraft, no more than 25 kg (55 pounds) net weight of hazardous material may be 49CFR 175.75(c) For each package containing a hazardous material acceptable for carriage aboard loaded in an inaccessible manner. In addition to the 25 kg limitation, an additional 75 kg (165 pounds) net requirements of this paragraph do not apply to Class 9, articles of Identification Numbers UN0012, UN0014, weight of Division 2.2 (non-flammable compressed gas) may be loaded in an inaccessible manner. The or UN0055 also meeting the requirements of §173.63(b), and Limited or Excepted Quantity material. Alaska Airlines requests an interpretation on this sentence in regards to the "addition" and "additional" wording: In addition to the 25 kg limitation, an additional 75 kg (165 pounds) net weight of Division 2.2 (non-flammable compressed gas) may be loaded in an inaccessible manner. inaccessible manner if that is the only hazardous material subject to the 25 kg Question: Can 100 kg Division 2.2 (non-flammable compressed gas) be loaded in an limitation? We would like confirmation the following 3 scenarios of different inaccessible aircraft compartments are all in compliance with the regulation. Compartment A Compartment B Compartment C* 25 kg Class 3, PG I 50 kg Class 9 75 kg Division 2.2 100 kg Division 2.2 10 kg Class 3, PG I 90 kg Division 2.2 *Compartment C scenario is 10 kg class 3 + 15 kg Division 2.2 = 25 kg, plus an additional 75 kg Division 2.2 Thank you in advance for your reply. If you have any questions, please don't hesitate to ask. Mike Tobin, CHMM Alaska Airlines - SEADG Manager Dangerous Goods P.O. Box 68900 Seattle, WA 98168 206-392-7854 mike.tobin@alaskaair.com Page 1 of 1#