Southwest Airlines Co. — Hazardous Materials Safety Interpretation

Page 11200 New Jersey Avenue, SE Washington, DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration August 7, 2020 Todd Hargrove Hazardous Materials Lead Southwest Airlines Co. 2702 Love Field Drive Dallas, TX 75235 Reference No. 20-0052 Dear Mr. Hargrove: This letter is in response to your June 29, 2020, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) when providing the pilot in command and flight dispatcher with shipping paper and other information regarding onboard hazardous materials in accordance with § 175.33. We have paraphrased and answered your questions as follows: Q1. You ask whether the notification of onboard hazardous materials information must be a direct message to the flight dispatcher. A1. The answer is no. In accordance with § 175.33(a), when a hazardous material subject to the provisions of the HMR is carried in an aircraft, the operator of the aircraft must provide the pilot-in-command and the flight dispatcher, or other ground support personnel with responsibilities for operational control of the aircraft, with accurate and legible written information (e.g., handwritten, printed, or electronic form) as early as practicable, but in no case later than when the aircraft moves under its own power before departure of the aircraft. Q2. You ask whether providing the flight dispatcher with hazardous materials information by making the information available in a flight system meets the requirements of § 175.33(a).#

Page 2A2. The answer is yes. Making the information available and readily accessible in a flight system for use by the flight dispatcher meets the intent of the requirement if the information required by § 175.33(a) is included in the system and is provided in the manner as discussed in answer A1. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Dirk Der Kinderen Chief, Standards Development Branch Standards and Rulemaking Division#

Page 3Ciccarone 20-0052 To: From: INFOCNTR (PHMSA) Subject: Hazmat Interps Date: FW: 175.33 Interpretation Attachments: image001.png Tuesday, July 21, 2020 3:09:55 PM Hello Alice and Ikeya, Please see below for letter of interpretation request. Thank you, Kathryn (HMIC) From: Todd Hargrove [mailto:Todd.Hargrove@wnco.com] Sent: Monday, June 29, 2020 12:17 PM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Subject: 175.33 Interpretation open attachments unless you recognize the sender and know the content is safe. CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or Good morning, I'm requesting an official interpretation on the following requirements per 49 CFR part 175.33, as specifically listed below. 175.33(a) Question 1: When providing Dispatch with the onboard hazardous materials information, does this need to be a direct message notification to the Dispatcher? Question 2: When providing Dispatch with the hazardous material information, is this requirement met by only having the Dangerous Goods information available in our flight system and accessible to the Dispatcher in the event the information is needed? Regards, Hazardous Materials Lead Todd Hargrove USAF(Ret.) Safety & Security Department Office (469)-603-4813 Fax (469)-603-4883 Cell (214)-475-3318 Southwest• ******* CONFIDENTIALITY NOTICE ******* This email communication is intended solely for the information and use of Southwest Airlines Employees and may contain information that is confidential and proprietary in nature. Accordingly,#

Page 4the reproduction, re-transmission, or other dissemination or use of this email (or any information contained in it) is strictly prohibited. If you are not an addressee and/or have received this email communication in error, please advise the sender either by reply email or by telephone and immediately delete this email from any computer and destroy all physical copies. ******* CONFIDENTIALITY NOTICE ******* This e-mail message and all attachments transmitted with it may contain legally privileged and confidential information intended solely for the use of the addressee. If the reader of this message is not the intended recipient, you are hereby notified that any reading, dissemination, distribution, copying, or other use of this message or its attachments is strictly prohibited. If you have received this message in error, please notify the sender immediately and delete this message from your system. Thank you.#