Hazmat Guru Consulting — Hazardous Materials Safety Interpretation

Page 1= 1 of Transportation U.S. Department Washington, D C 400 Seventh Street, S.W. 20590 Research and Administration Special Programs JUN 2 6 1998 Mr. H.J. Pace Hazmat Guru Consulting President, CEO 6917 Kirkwood Road Fort Worth, TX 76116-9420 Dear Mr. Pace: This is in response to your letter requesting clarification of quantity limits for carriage on the delay in responding. cargo-only aircraft of hazardous materials in inaccessible cargo compartment. I apologize for Your questions have been paraphrased and answered as follows: Question 1. How much hazardous material acceptable for passenger or cargo aircraft may be transported in an inaccessible cargo compartment or freight container? Passenger authorized hazardous materials that are carried aboard passenger aircraft in inaccessible compartments are limited by 49 CFR 175.75(a)(2)(i) to 25 kg. of hazardous materials (reference to the Division 2.2 limit will be omitted for the sake of simplicity) per compartment, whether in a freight container or not. Passenger authorized hazardous materials carried aboard cargo-only aircraft in inaccessible compartments or an inaccessible manner within an accessible compartment are limited to 25 kg. of hazardous material per compartment when not in freight containers. If a passenger authorized hazardous material is carried within freight containers in an accessible cargo compartment, they are limited to 25 kg. of hazardous material per freight container. Question 2. How much cargo-only authorized hazardous materials carried aboard cargo-only aircraft are allowed to be transported in an inaccessible cargo compartment? The answer is none. Section 175.85(b) prohibits the carriage of hazardous materials - accepad in a Cr 1750 aic) hazarous matails prepared acresis ration at andy aircraft must always be accessible by the flight crew.#

Page 2- Your inquiry highlights some of the difficulty which has been experienced in interpreting $$ 175.75 and 175.85. We are currently examining all of the provisions of 49 CFR Part 175, and intend to correct discrepancies in a future rulemaking. I trust this satisfies your inquiry. If this Office can be of further assistance, please contact us. Sincerely, dward I. Mazzu Director, Office of Hazardous Materials Standards#

Page 3MSULTING/TNG INC Fax: 817-732-2933 Voice: 817-732-2933/3819 To: Mr. Ed Mazzulo, Director at: Ofc of HM Standards, RSPA Page 2 of 2 Tuesday, January 20, 1 . = La Valle / HAZMAT GURU CONSULTING/TRAINING INC FORT WORTH, TX 761 16-9420 6917 KIRKWOOD ROAD File: 115,25 FAX: 817-732-2033 817-732-3810 SC: 412, January 20, 1998 MR. EDWARD MAZZULO, DIRECTOR OFFICE OF HAZARDOUS MATERIALS STANDARDS RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION U.S. DEPARTMENT OF TRANSPORTATION 400 7TH STREET, SW • WASHINGTON, DC 20590-0001 DEAR MR MAZZULLO: SUBJECT: REQUEST FOR INTERPRETATION OF TITLE 49 CODE OF FEDERAL REGULATIONS PART 175.75 (a). Basically our question is: 1. On a cargo only aircraft how many kilos of hazardous materials acceptable for passenger or cargo aircraft can be tranported in an inaccessible cargo compartment or freight container ? 2. On a cargo only aircraft how many kilos of hazardous materials acceptable on for cargo aircraft only can be transported in an inaccessible cargo compartment or freight container? Thank for your consideration and if possible prompt response. This effects one of this company's customers involved in transportation of large amounts of hazardous materials on a daily basis and we need to assure that the correct interpretation is provided during training of aircraft loaders and flight crews. Sincerely, H.J. (JERRY) PACE PRESIDENT, CEO#