Northern Air Cargo, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 1200 New Jersey Avenue SE Washington. DC 20590 Materials Safety Pipeline and Hazardous Administration MAR 0 7 2016 Mark Smith Hazardous Materials Instructor Northern Air Cargo, Inc. 3900 Old International Airport Rd Anchorage, AK 99502 Ref. No. 15-0145 Dear Mr. Smith: This responds to your July 10, 2015 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the International Civil Aviation Organization's Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO TI) applicable to indicating use of an overpack on shipping papers. Specifically, you provide an example of a shipping paper entry and ask whether it conforms to both the HMR and the ICAO TI. Your questions are paraphrased and answered as follows: Q1. When shipping under the HMR, are offerors required to add the word "overpack" to the shipping paper? A1. No. However, § 172.201(a)(4) states that any additional information concerning the material that is not inconsistent with the basic description may be included on the shipping paper, provided it is placed after the basic description required by 8 172.202(a). Q2. When shipping under the ICAO TI, are offerors required to add the word "overpack" to the shipping paper? A2. Yes. As provided in the ICAO TI Part 5, Chapter 4.1.5.8.1, the dangerous goods transport document must also contain an indication that an overpack has been used, when appropriate. Q3. When including an indication of the use of an overpack on a shipping paper in accordance with the ICAO TI, would the following shipping description satisfy both the HMR and ICAO TI requirement to list the number and type of packagings being offered (note: there are 20 fiberboard boxes total)? "UN1263, Paint, 3, II, 10 fiberboard boxes X 2L, OVERPACK USED x 2 (#1 #2)" 1#

Page 2A3. No. Both the ICAO TI and the HMR require the number and type of packages covered by the shipping description to be indicated on the shipping paper. It is the opinion of this Office that the description you provided does not clearly indicate the total number and type of packages covered under the description. I trust this satisfies you inquiry. Please contact us if we can be of further assistance. Sincerely, Due Prane A Tful Duane Pfund International Standards Coordinator Standards and Rulemaking Division 2#

Page 3Ciccarore: 1,73.85 Goodall, Shante CTR (PHMSA) Nuthorised factaging From: INFOCNTR (PHMSA) 15-0145 Sent: Friday, July 10, 2015 5:50 PM To: Hazmat Interps Subject: FW: Overpack Description on Shipping Papers Attachments: Overpack Description on Shipping Papers.pdf Hi Shante and Alice, please assign to PHH-13 Int'l specialist. Thanks, HMIC From: Mark Smith [mailto:MSmith@nac.aerol Sent: Friday, July 10, 2015 5:12 PM To: INFOCNTR (PHMSA) Subject: RE: Overpack Description on Shipping Papers Hello, Please find attached a corrected copy that will hopefully get it squared away. Regards, Mark Smith | Hazardous Materials-Industrial Instructor NAC NORTHERN AR CARGO. Northern Air Cargo, Inc. Phone: 907-249-5186 | Fax: 907-249-5195 | Cell: 907-250-1905 Address: 3900 Old International Airport Road, Anchorage, AK 99502 Email: msmith@nac.aero. | Web: www.nac.aero#

Page 4July 10, 2015 NORTHERN AIR CARGO U.S. Department of Transportation PHMSA Office of Hazardous Materials Standards Attn: PHH-10 East Building 1200 New Jersey Avenue, SE Washington, D.C.20590-0001 Re: Quantities and overpack descriptions on shipping papers. Under 49CFR, placing the term "OVERPACK" on a shipping paper is not required, but package must be marked as per 173.25(a)(2)-(4). The ICAO Technical Instructions, 5;4.1.5.8.1(e) do require the word "OVERPACK" be placed onto the shipping paper. However, the manner in which to describe the overpack on the shipping paper is not discussed clearly in either 49CFR or ICAO, only that a total quantity of packages and net quantity per package for the shipment must be listed for air. ICAO EXAMPLE: UN1263, Paint, 3, II, 20 fiberboard boxes X 2L, OVERPACK USED In the second example below, is a description for total quantity of 20 boxes on a shipping paper. UN1263, Paint, 3, II, 10 fiberboard boxes X 2L, OVERPACK USED X2 (#1 #2) In this example, the two overpacks are being used to describe the total 20 boxes of the shipment. Is this a permissible method to describe the quantity for the shipment? Sincerely, Mark Smith Hazardous Materials Instructor 907-249-5186 Northern Air Cargo 907-243-3331 NORTHERN AIR CARGO INC 3900 Old International Airport Rd Anchorage AK 99502 800-727-2141 FAX 907-249-5190 WWW.NORTHERNAIRCARGO.COM#