DGI Training Center — Hazardous Materials Safety Interpretation

Page 1of Transportation J.S. Department Washington, D.C. 400 Seventh Street, S.W. 20590 Research and Special Programs Administration JUN 2 7 199G Ms. Candy L. Cook DGI Training Center P.O. Box 1283 Amelia Island, FL 32035 Dear Ms. Cook: This is in response to your letter concerning the amount of hazardous materials that may be carried on either a passenger or cargo aircraft. I apologize for the delay in responding and regret any inconvenience it may have caused. Your questions have been paraphrased and answered as follows: Q. Explain the quantity limitations in 49 CFR 175.75(a)(2). A. The quantities in this section are expressed in net weight. The section states that not more than 55 pounds of hazardous materials, and in addition thereto 165 inaccessible location or in a freight container on a passenger-carrying aircraft. pounds net weight of Class 2.2 (non-flammable gas) may be carried in any For cargo-only aircraft, not more than these quantities of hazardous materials may be loaded in a manner which makes them inaccessible unless the hazardous materials are in a freight container. Q. Is there a quantity limitation if the hazardous materials are loaded inaccessible on a pallet vs. a freight container? A. An aircraft pallet does not meet the definition. of freight container, § 171.8. Packages of hazardous materials loaded on an accessible pallet in an accessible cargo compartment on a cargo aircraft only, are not subject to the 55-pound (165 pounds for non-flammable compressed gases) net weight limitation. Q. Is it correct that items allowed on a passenger aircraft, but are being transported on an all cargo aircraft must follow the 25/75 rule in an inaccessible cargo hold, while some items packed for cargo aircraft only will not follow the limitation? A. Even if a package that is prepared for carriage on a passenger aircraft is being transported on a cargo-only aircraft, the quantity limits per package imposed by Column 9A of the Hazardous Materials Table, § 172.101 apply.#

Page 2Q. Are Foreign Flag carriers subject to the 25/75 rule? A. Yes. Part 175 - Carriage by Aircraft applies to the acceptance for transportation, loading and transportation of hazardous materials in any aircraft in the United States, § 175.5(a). This would include all foreign aircraft entering or departing U.S. airspace. If we can be of further assistance, please feel free to contact us. Sincerely, Achen Hillings Delmer F. Billings Chief, Regulations Development Office of Hazardous Materials Standards#

Page 3175.75 File DGI DGI Training Center-East 412,300 PO Box 1283 Amelia Island, FL 32035 IATA DANGEROUS GOODS INT'L 904-321-0874 • Fax 904-321-1801 13 July 1995, Mr. Delmer F. Billings Chief, Regulations Development Office of Hażardous Materials Standards R.S.P.A. 400 7th St: SW Washington D.C. 20590 Dear Mr. Billings, At your convénience, I would like to request a written interpretation on the following, please. I have spoken to many agents at the FAA and have received various answers. My question deals with the amount of Hazmat which may be carried on either a passenger or cargo aircraft: " 175.75 - Quantity limitations aboard aircraft". It seems pretty clear for passenger aircraft; 25 kg net weight of Hazardous Materials and in addition 75kg of non-flammable gas in each inaccessible cargo compartmen and in "this is of! addition 25/75 in each freight container if it is accessible. Item 175.75(2) (iii) not Anit" seems to be solely for cargo aircraft; If they are loaded on a cargo aircraft in an accessible position, but built up on the pallet so as to be inaccessible it. will be limited to 25/75. It goes on to state " unless in a freight container". So, how much is allowed in that freight container? Does it mean that on a cargo aircraft, if the items are packed according to a passenger packing instruction, there is no limitation if they are, containerized, but'there is a limitation if they are loaded inaccessible on a pallet? For packages that are packed for cargo aircraft only, we refer to 175.85 (b);These packages must be loaded so they may be seen, handled and where size and weight permit, separated from other cargo during flight. It goes on to list items which may be inaccessible during flight and are not subject to the 25/75 weight restriction. Is it correct to assume that items that are allowed on a passenger aircraft, but are/ being transported on an all cargo aircraft must follow the 25/75 rule in an inaccessible limitation? cargo hold, while some items that are packed for cargo aircraft only will not follow the For instance a shipper wishes to transport 60L of a Flammable liquid in Packing Group Ill. If they pack it for a passenger aircraft and move it on an all cargo carrier it would have to be loaded açcessibly to avoid the 25kg limitation. If the shipper, packed according to a cargo aircraft packing instruction number, it could then be loaded Seattle • Chicago • Miami • Denver • Phoenix • Minneapolis • Los Angeles • Boston • New Orleans • Honolulu • San Juan • Atlanta • Houston Indianapolis • Newark | San Francisco • Baltimore • Milwaukeo • New York • Dotroit * Philadeiphia • Dallas • Clovoland • St Louis#

Page 4inaccessible with no weight restrictions. And what about 175.75. (2) (iii), if he put it in a container? No weight restriction?? Are Foreign Flag carriers entering or departing the US. subject to the 25/75 Rule? I have included the pages from my workbook which deal with loading aircraft. Perhaps you can confirm or tell me where I'm going wrong. I'm probably going way too deep here and further confusing myself. I am an instructor and when thesé questions come up in class I need to know what I'm talking about. Mr. Billings, I thank you in advance for your time and attention to this matter. Most sinçerely, Caredy. Cook Candy L. Cook DGI Training _Center P.O.Box 1283 • Amelia Island, FL 32035 Fax, 904-321-1801#

Page 511/30/95 10:22 5202 366 8700 OHMS/RSPA/USDOT 49002 , 175:75 File DGI pGI Training Center East 412,300 PO Box 1283! Amelia Island, FL 32035* IATA DANGEROUS GOODS INT 904-321-0874 = Fax 904-321-1801 13. Jul 1995 .; Mr. Delmer F. Billings Chief, Regulations Development' .R.S.P.A. Office of Hażardous Materials Standards 400 7th St: SW Washington D.G... 20590 Dear Mr. Billings, Aț your convènience, I would like to request a written interpretation on the following, please. I have spoken to many agents at the FAA and have received various answers. My question deals with the amöunt of Hazmat which may be carried on either a passenger or cargo aircraft: " 175.75 - Quanțity limitations aboard aircraft". It seems pretty clear for passenger aircraft; 25 kg.net weight of Hazardous Materiäls and in addition 75kg of noni flammable gas in each inaccessible cargo compartmentand in this 1 ce addition 25|75 in each freight container if it is accessible, Item 175:75(2) (li) seems to be solely for cargo aircraft, if they are loaded on. a cargo aircraft in an accessible position, but built up on the pallet so as to be inaccessible it will be limited to 25/75. It goes on to state ". unless in a freight container". So, how much is allowed. . in that freight container? Boés it mean that on a cargo aircraft, if the items are packed açcording to a passenger packing instruction, there is no limitation. if they are containerined, batthere is a limitation if they are loaded inaccessible on a pallet? For packages that are packed for cargo aircraft only; we refer to 1p:85 (b) These 1. packages must be loaded so they may be seen, handled and where size and weight permiț, separated from other cargo during flight. It goes on to lișt items which may be inaccessible during flight and are not subject to the 25/75 weight restriction. Is it correct to assume that items that are allowed on a passeriger aircraft, but are being transported on an all cargo aircraft must follow the 25/75 rule in an inaccessible cargo hold, while some items that are packed for cargo aircraft only will not follow the For instance a shipper wishes to transport 60L of a Flammable liquid in Packing Group !!!, If they pack it for a passenger äircraft and move it on an all cargo carrier it would have to be loaded accessibly to avoid the 25kg limitation. If the shipper, packed according to a čargo aircraft packing instruction number, it could then be loaded Soattie • Chicagò • Miami • Denver, a Phóenix • Minneapolis • Los Angolasi Boston • Now Orleans • Honolulu • San Juan •: Attanta = Houston Indianapolis M Newark • San Francisco • Baltimore • Milwaukeo • New Yoik • Detroit • Philadolphie: • Dallas « Cleveland « St Loúis .#

Page 611/30/95 10:23 2202, 366 87.00 OHMS/RSPA/USDOT 4003 inaccessible witti no weight restrictions, Ahot what about 175;76 (ii), if hesput itin a container? No weight restriction? Are Foreign Flag cafters enteing or departing the US subject to the 25175 Rule? I have included the pages from my workbook which deal with loading aircraft: Perhaps • you can confirm or tell me: where I'm going wrong. I'm probably going way too deep here and further confusing myself. l am an instructor and when thesé questions comè up in' class I need to know what I'm talking. about. Mr. Bilings it thank you in advance for your time and attention to this matter. Most sincerely, Candy Cook! Candy L. Cook: ! P.O.Box 1283 DG! Training Center. • Amelia Island, FL.: 32035 Fax 904-321-1801. - 1... 3:#

Page 7RULES FOR AIRCRAFT CARRIAGE 251:0107 HAZ-206 under this section shall send a report to a package. Each operator making a report be carried aboard passenger-carrying air- materials, sce $175.702(b)(2) (iv)) or, for the Research and Special Programs Ad- any single package, exceeds 10.0. tion, Washington, D.C. 20590-0001, with ministration, Department of Transporta- [55 FR 52685, Dec. 21, 1990, effective Oct. 1, 1991] 147 FR 54817, Dec. 6, 1982, effective a separate copy to the FAA facility indi- cated in paragraph (a) of this section. (i) In an inaccessible cargo compart- Jan. 1, 1983; 55 FR 52685, Dec. 21, 1990, effective Oct. 1, 1991] 145 FR 74640, Nov. 10, 1980; 54 FR in feet conner within n 1990; 55 FR 39981, Oct. 1, 1990] 25813, June 19, 1989, effective Jan. I, accessible cargo compartment, or of packages of Class 9 (miscellaneous (b) No limitation applics to the number (ili) In any accessible cargo compart- (d) [Reserved] ment in a cargo aircraft only in a manner als aboard an aircraft. hazardous) materials, or ORM-D materi- [52 FR 8592, March 19, 1987] freight container; that makes it inaccessible unless in a (3) Packages containing Class 7 (radio- [55 FR 52685, Dec. 21, 1990, effective Subpart B-Loading, Unloading and transport index number (determined by their combined Oct. 1, 1991] Handling §175.78 Stowage compatibility of cargo. §175.75 Quantity limitations aboard air- bers shown on the labels of the individual adding together the transport index num- (a) For stowage on an aircraft, in a car- packages and/or overpacks)— go facility, or at any other area at an airport designated for the stowage of haz- §175.85(c)(3), no person may carry on an Oct. 1, 1991] 55FR5268 Dec. 21, 1990, effective hazardous materials which might react ardous materials, packages containing mitted by this subchapter; (1) A hazardous material except as per- cecds 50.0 or, for any single package, ex- (i) In passenger carrying aircraft, ex- placed next to each other or in a position dangerously with one another may not be weight of hazardous material (and in ad- (2) More than 25 kg (55 pounds) net ceeds 3.0, or that would allow a dangerous interaction dition thereto, weight of Division 75 kg (165 pounds) net Jan. 1, 1983] 448, De. 6, 1982, effective the segregation prescribed in the follow- in the event of leakage. As a minimum, compressed gas) materials) permitted to 200.00 (for fissile Class 7 (radioactive) (il) In cargo aircraft only, exceeds ing Table must be maintained. (58 FR SOSOS, Sept. 27, 1993] D Explosives and Blasting Agents or ICAO Class 1. G Compressed gases or ICAO Class 2....... Flammable liquids or ICAO Class ...................... Noto 4 Note 4 Flammable liquids and sollds (labeled SPONTANEOUSLY COM- Note 4 Flammable solids (labeled DANGEROUS WHEN WET) or ICAO BUSTIBLE) OR ICAO Division 4.2................... Note 4 Note 4 Note 4 Oxidizers or ICAO Division 5.1 and Organic peroxides or ICAO Division....................L.LLLLLLLLL. Note Corrosive materials or ICAO Class 8.... Division 5.2.............. Note 4 x Note 1. The letters across the top of the Table have the same meaning as the letters along the left side of the Table. x x Note 2. An "X" at the intersection of a row and a column in the Table means that packages containing the Indicaled classes of hazardous materials may not be stowed next to or in S may be stowed with explosives of all compatibility groups with the exception of A and L. Note 4. Explosives, other than safaty explosives (ICAO Division 1.4, Compatibilty Group S) must not be stowed together with this class. 141 FR 24582, June 7, 1982, effective effective Jan. 1, 1983] Aug. 6, 1982; 47 FR 54817, Dec. 6, 1982 materials marked "THIS SIDE UP" or (a) A packaging containing hazardous §175.81 Securing of packages containing "THIS END UP." or with arrows to indi- hazardous materials. beled BLASTING AGENT on an air- (b) No person may stow a package la- cate the proper orientation of the pack- [47 FR 54817, Dec. 6, 1982, effective fire-works or railway torpedoes. allow contact with, a package of special craft next to, or in a position that will age, must be stored and loaded aboard an Jan. 1, 1983] aircrait in accordance with such mark- latcrials must be secured in an aircra (a) Packages containing hazardou FR 31180, May 31, 1979] [43 FR 57897, December 11, 1978; 44 ment in flight which would result in dam- in a manner that will prevent any move- ardous materials not marked as indicated (b) A package containing liquid haz- packages. age to or change in the orientation of the §175.79 Orientation of cargo. in paragraph (a) of this section, must be Jan. 1, 1983] 147 FR 54817, Dec. 6, 1982, effective than side closure in addition to stop clo- stored and loaded with closurcs up (other sures). requirements of §$175.701 and 175.702 [Sec. 175.81(b)] DGI - Flight Crew '95 page 83#

Page 8251:0108 HAZARDOUS MATERIALS TRANSPORTATION will be maintained at all times during natcrials acceptable for cargo-only or (2) When packages of hazardous instrument equipment of the aircrait, in : passenger-carrying aircraft are carried or requirement cannot be met, a special air- manner that affects its operation. If thi Oct. 1, 1991) [55 FR 52685, Dec. 21, 1990, effective transportation are impracticable or not cargo aircraft only where other means of be made. craft swing and compass calibration may §175.85 Cargo location. available, package may be carried in ac- cordance with procedures approved in [50 FR 48419, Nov. 25, 1985] Jan. 1, 1983] [47 FR 54817, Dec. 6, 1982, effective writing by the FAA Air Transportation Security Field Office responsible for the §175.88 Inspection of unit load devices. person may carry a hazardous (a) Except as provided in §175.10, operator's overall aviation security pro- on an aircraft unless the device has been A unit load device may not be loaded subject to the requirements of this sub- curity Division in the region where the ram or the FAA Air Transportation Se. inspected and found to be free from any chapter in the cabin of a passenger-carry- evidence of leakage from, or damage to, ing aircraft or on the flight deck of any (3) When packages of hazardous ials. any package containing hazardous mater- aircraft. Hazardous materials may be car- a passenger-aircraft provided that the ried in a main deck cargo compartment of passenger-carrying aircraft are carried on materials acceptable for cargo-only or [47 FR 54817, Dec. 6, 1982, effective and that it meets all certification require- compartment is inaccessible to passengers small, single pilot, cargo aircraft only be- Jan. 1, 1983} ing used where other means of transporta- ion are impracticable or not available, §175.90 Damaged shipments. partment as provided in 14 CFR ments for a Class B aircraft cargo com- itation as specified in §175.75 in a loca- they may be carried without quantity lim- Jan. 1, 1983] [47 FR 54817, Dec. 6, 1982, effective ous material acceptable only for cargo air- (b) Each package containing a hazard- tion that is not accessible to the pilot if- (i) No person other than the pilot, an hazardous materials must be inspected for (a) Packages or overpacks containing that a crew member or other authorized craft must be loaded in such a manner of the material or a representative of the FAA inspector, the shipper or consignee from an aircraft. When packages or damage or leakage after being unloaded person can see, handle and when size and shipper or consignee so designated in writ- ing, or a person necessary for handling the are carried in a unit load device, the area overpacks containing hazardous materials from other cargo during flight. weight permit, separate such packages material is carried on the aircraft; (ii) The pilot is provided with written must be inspected for evidence of leakage where the unit load device was stowed paragraph (b) of this section— (c) Notwithstanding the provisions of instructions on characteristics and proper handling of the materials; and moval of the unit load device from the or contamination immediately upon re- hazardous materials are carried on cargo (1) When packages of the following while the material is on board, the new (iii) Whenever a change of pilots occurs inspected for evidence of damage or leak- aircraft, and the packages or overpacks location which is inaccessible to a crew- aircraft only, they may be carried in a pilot is briefed under a hand-to-hand sig- nature service provided by the operator of In the event of leakage or suspected leak- age when he unit load device is unloaded. member during flight and are not subject graph (a) (2) of $175.75 to the weight limitation specified in para- age, the compartment in which the pack- [45 FR 6946, Jan. 31, 1980, effective im- age, overpack, or unit load device was car- effective Oct. 1, 1980] mediately; 45 FR 35329, May 27, 1980, and any dangerous level of contamination ried must be inspected for contamination (i) Class 7 (radioactive) materials, [55 FR 52685, Dec. 21, 1990, effective (d) [Reserved] Oct. 1, 1991] (47 FR 54817, Dec. 6, 1982, effective the operator of an aircraft shall (b) Except as provided for in §175.700, (except those labeled FLAMMABLE), (ii) Division 6.1 (poisonous) materials Jan. 1, 1983] (e) No person may carry a material this subchapter that appears to be dam- from the aircraft any package subject to Oct. 1, 1991] 155 FR 52685, Dec. 21, 1990, effective chapter that is acceptable for carriage in subject to the requirements of this sub- aged or leaking. In the case of a package a passenger-carrying aircraft (other than must insure that the remainder of the which appears to be leaking, the operator or infectious substances), (ill) Matcrials in Division 6.2 (etiologic in the aircraft in a place that is inaccessi- (55 FR 52685, Dec. 21, 1990, effective bie to persons other than crew-members. Oct. 1, 1991] ion do not apply to a person operating a (f) Paragraphs (a) and (c) of this sec. been contaminated. als with a flashpoint above 23°C (73 F) (iv) Class 3 (flammable liquid) materi- uf its size and configuration, makes it im- arcraft under §175.310 which, becaus that is damaged or appears to be damage (c) No person shall place a packag hazard class. that do not meet the definition of another pussible for that person to comply. or leaking aboard an aircraft subject to Oct. 1, 1991] [55 FR 52685, Dec. 21, 1990, effective 145 FR 13087, Ecbruary 28, 1980, effec- tive September 1, 1980] rial in Division 8.2 (erioligic or interious materials, and ORM-D materials (v) Class 9 (miscellancous hazardous) (g) No person may load magnetized substance) is found to be damaged or might cause crroncous leaking, the person finding the package Oct. 1, 1991] 155 FR 52685, Dec. 21, 1990. ellecuve in the vicinity of a magnetic compass, or magnetic compass reading) on an aircraft, compass master unit, that is a part of the ISS FR 52685, Dec. 21, 1990, effective Oct. 1, 1991] [Sec. 175.90(d)] DGI - Flight Crew '95 page 84#

Page 9: LIMITATIONS ALL CARGO AIRCRAFT For packages prepared according to a passenger aircraft Packing Instruction; ~ No quantity limitation if loaded in a position that is accessible to crew members or containerized on the main deck. Limited to 25kg (55lbs) net weight of Dangerous Goods and in addition, 75kg . (165lbs) net weight of non-flammable gas if in an inaccessible cargo hold or in any accessible cargo compartment, but loaded on a pallet so as to be inaccessible. and bearings peared in in or are rare only Packing instruction numbere v There is no limitation as long as a crew member or other authorized person can see, handle and when size and weight permit, separate such packages during flight. • The following items only, when transported on a cargo aircraft, may be loaded in an inaccessible location and are not subject to weight restrictions; 1. Class 7, Radioactive Materials 2. Division 6.1, Toxic substances (without a flammable subrisk) anc Division 6.2, Infectious substances 3. Class 3, Flammable liquids, in Packing Group III, without a subsidiary risk. 4. Class 9, Miscellaneous Dangerous Goods and ORM-D materials. For Radioactive Materials; The total combined Transport Index numbers shown on the labels of the individual packages must not exceed 200. • Each individual package may not exceed a Transport Index of 10.0. Note: Other restrictions apply. Read in detail 175.700, 175.702, 175.703 and 175.705. Note: If a person other than a crew member, company employee, an authorized representative of the United States or a person accompanying the shipment is traveling on the aircraft, the rules for passenger aircraft quantities and loading restrictions apply. DGI - Flight Crew '95 page 52#

Page 10Facsimile Cover Sheet To: Jackie Smith Company: OHMS Phone: Fax: 202 366 3753 From: Thomas Kenny Company: FAA ACO-50 Phone: 7 3130 Fax: Date: 12/19/95 Pages including this cover page: 2 Comments: Hi Jackie. Sorry this took so long, had to do some research. Please call if you have questions. Tom Kenny | DB-- 4/2 This letter was focusedied to OpA As you canser becruse I had Restorchedit (with yack help) And WAS still stugaling. the Attachment to this AAX (the Reply) is Among the missing#

Page 1111/30/95 10:21 S202 366 8700 OHMS/RSPA/USDOT 4001 7 You are receiving a FAX from OHMS Office of Hazardous Materials Standards Return FAX Number (202) 366-3753 Number of Pages ins uding Cover). Al. Date: 1/29/95 Time: 5:15pm ĐAX: #75760 Addressee: Cheis Glasow, ACO.50 initiator: Jackie Smith Phone: #73952. Phone: #6414178 Comment: .... hanks!!#