{"operation":"document","citation":"20-0052","title":"Southwest Airlines Co. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2020-08-07","effective_on":null,"summary":"20-0052 response to Southwest Airlines Co. concerning 175.33.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-20-0052.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-20-0052.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-20-0052","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/74206/200052.pdf","body":"<<<PAGE 1>>>\n\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nAugust 7, 2020\nTodd Hargrove\nHazardous Materials Lead\nSouthwest Airlines Co.\n2702 Love Field Drive\nDallas, TX 75235\nReference No. 20-0052\nDear Mr. Hargrove:\nThis letter is in response to your June 29, 2020, email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) when providing the pilot in command and\nflight dispatcher with shipping paper and other information regarding onboard hazardous\nmaterials in accordance with § 175.33.\nWe have paraphrased and answered your questions as follows:\nQ1. You ask whether the notification of onboard hazardous materials information must be a\ndirect message to the flight dispatcher.\nA1. The answer is no. In accordance with § 175.33(a), when a hazardous material subject to\nthe provisions of the HMR is carried in an aircraft, the operator of the aircraft must\nprovide the pilot-in-command and the flight dispatcher, or other ground support\npersonnel with responsibilities for operational control of the aircraft, with accurate and\nlegible written information (e.g., handwritten, printed, or electronic form) as early as\npracticable, but in no case later than when the aircraft moves under its own power before\ndeparture of the aircraft.\nQ2. You ask whether providing the flight dispatcher with hazardous materials information by\nmaking the information available in a flight system meets the requirements of\n§ 175.33(a).\n\n<<<PAGE 2>>>\n\nA2. The answer is yes. Making the information available and readily accessible in a flight\nsystem for use by the flight dispatcher meets the intent of the requirement if the\ninformation required by § 175.33(a) is included in the system and is provided in the\nmanner as discussed in answer A1.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nDirk Der Kinderen\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\nCiccarone\n20-0052\nTo:\nFrom:\nINFOCNTR (PHMSA)\nSubject:\nHazmat Interps\nDate:\nFW: 175.33 Interpretation\nAttachments:\nimage001.png\nTuesday, July 21, 2020 3:09:55 PM\nHello Alice and Ikeya,\nPlease see below for letter of interpretation request.\nThank you,\nKathryn (HMIC)\nFrom: Todd Hargrove [mailto:Todd.Hargrove@wnco.com]\nSent: Monday, June 29, 2020 12:17 PM\nTo: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov>\nSubject: 175.33 Interpretation\nopen attachments unless you recognize the sender and know the content is safe.\nCAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or\nGood morning,\nI'm requesting an official interpretation on the following requirements per 49 CFR part 175.33, as\nspecifically listed below.\n175.33(a)\nQuestion 1: When providing Dispatch with the onboard hazardous materials information, does this\nneed to be a direct message notification to the Dispatcher?\nQuestion 2: When providing Dispatch with the hazardous material information, is this requirement\nmet by only having the Dangerous Goods information available in our flight system and accessible to\nthe Dispatcher in the event the information is needed?\nRegards,\nHazardous Materials Lead\nTodd Hargrove USAF(Ret.)\nSafety & Security Department\nOffice (469)-603-4813\nFax (469)-603-4883\nCell (214)-475-3318\nSouthwest•\n******* CONFIDENTIALITY NOTICE *******\nThis email communication is intended solely for the information and use of Southwest Airlines\nEmployees and may contain information that is confidential and proprietary in nature. Accordingly,\n\n<<<PAGE 4>>>\n\nthe reproduction, re-transmission, or other dissemination or use of this email (or any information\ncontained in it) is strictly prohibited. If you are not an addressee and/or have received this email\ncommunication in error, please advise the sender either by reply email or by telephone and\nimmediately delete this email from any computer and destroy all physical copies.\n******* CONFIDENTIALITY NOTICE *******\nThis e-mail message and all attachments transmitted with it may contain legally privileged and\nconfidential information intended solely for the use of the addressee. If the reader of this\nmessage is not the intended recipient, you are hereby notified that any reading, dissemination,\ndistribution, copying, or other use of this message or its attachments is strictly prohibited. If\nyou have received this message in error, please notify the sender immediately and delete this\nmessage from your system. Thank you.","truncated":false,"body_characters":4577}