# Polar Air Cargo — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 99-0083
- **title:** Polar Air Cargo — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 1999-06-07
- **effective on:** Not available
- **summary:** 99-0083 response to Polar Air Cargo concerning 173.220.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-99-0083.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-99-0083.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-99-0083
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1999/990083.pdf
**body:**

<<<PAGE 1>>>

:
U.S. Department
of Transportation
Washington, D.C.
400 Seventh Street, S.W.
20590
Research and
Administration
Special Programs
JUN - 7 1999
"%:.
Mr. Paul J. Zinza
Ref. No.
99-0083
Supervisor, Dangerous Goods
Polar Air Cargo
100 Oceangate, 15th Floor
Long Beach, CA 90802
Dear Mr. Zinza:
This is in response to your letter dated March 23, 1999,
concerning the proper shipping name of a fuel pump that
contains aircraft fuel. Specifically you
ask if rather than
utilizing the UN number and shipping description as contained
in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171
to 180), UN1863 and either the shipping description, Fuel,
aviation, turbine engine, or Residue, last contained fuel,
aviation, turbine engine, it is more appropriate to utilize
the number ID 8001 with either the proper shipping name
Dangerous Goods in Apparatus, or
Dangerous Goods in Machinery.
It is the opinion of this office that Dangerous Goods in
Apparatus is the most appropriate shipping description. Fuel
control units or engine parts containing residual amounts of
flammable liquid must be packaged
to conform with the
packaging requirements of packing instruction 916 of the ICAO
Technical Instructions or Part 173 of the HMR. In addition,
the fuel control unit must be capable of withstanding pressure
requirements in 49 CFR 173.27 (c) .
In Docket HM-215C, published March 5, 1999, the Hazardous
Materials Regulations were amended to include a listing in the
HMT fOr Dangerous Goods in Machinery of Dangerous Goods in
990083
173.220

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Apparatus, NA 8001, which may be used for domestic
transportation. The full text of Docket HM-215C can be
obtained from our website, http://hazmat.dot.gov.
I hope this information is helpful. If you have further
questions, please do not hesitate to contact this office.
Sincerely,
Those
orne A. Oll
Thomas G. Allan
Acting Director, Office of Hazardous
Materials Standards

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POLAR AIR CARGO
helson
$173.22
March 23, 1999
99-0083
Mr. Edward T. Mazzullo, Director
Office of Hazardous Materials Standards
Research & Special Projects Administration
U.S. Department of Transportation
Washington, DC 20590-0001
Dear Mr. Mazzullo:
Please find attached a copy of Charles Lovinski's Federal Aviation Administration Civil
Aviation Security Dangerous Goods Advisory Bulletin (DGAB-98-02), dated April 7,
1998. I am writing for official written clarification concerning whether or not aircraft
fuel pumps would be afforded the same hazardous materials shipping status as fuel
control units.
Simply stated, does Mr. Lovinsky's official document overlag to include the shipment of
aircraft jettison fuel pumps as UN1863; under the proper shipping name "Fuel, aviation,
turbine engine?" Or, would it be more appropriate to utilize ID8001 with the proper
shipping name "Dangerous goods in apparatus" or "Dangerous goods in machinery"
since technically speaking, a fuel pump is not a turbine engine? Kindly bear in mind that
I am referring to fuel pumps that have not been cleaned or purged.
Your prompt official written interpretation may be sent directly to me at the following
address:
Paul J. Zinza,
Supervisor Dangerous Goods
Polar Air Cargo
100 Oceangate, 15" Floor
Long Beach, CA 90802
Thank you in advance for taking the time to clarify this important matter.
Sincerely;
Paul J. Zaza
Supervisor Dangerous Goods
ENC
100 OCEANGATE, 15TH FLOOR + LONG BEACH, CA.90802 U.S.A. +
TEL: (562) 436-7471
+
FAX: (562| 436-9333 → SITA: LG8KUPO

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04-15-96 12:01PM
CO POLAR HO
P002/003
Federal Aviation Administration
Civil Aviation Security
Dangerous Goods Advisory Bulletin
Information of Concern to Air Carriers
Subject: Fuel Control Units
Number: DGAB-98-02
Date: April 7, 1998
INFORMATION: Federal Aviation Administration (FAA) Dangerous Goods and
Cargo Security inspectors are encountering fuel control units containing residual
amounts of aviation fuel or flammable cleaning solvents which are being
transported by air as undeclared or improperly declared shipments. These units
are common aircraft parts considered to be air carrier company material
(COMAT) and often are being returned to the manufacturer for ongoing
maintenance. The units typically are packaged inside a standard fiberboard box,
and many of these packages are leaking. If residual amounts of flammable
aviation fuel or cleaning solvents remain in the unit, domestic and international
hazardous materials regulations apply and the unit must be prepared for
transport as follows:
49 CFR
A fuel control unit containing residual aviation fuel is properly described under
49 CFR as follows:
Fuel, aviation, turbine engine, 3 UN 1863, PG (lI or Ill)
Residue, last contained Fuel, aviation, turbine engine 3, UN 1863, PG (Il or (il)
The unit may contain a flammable cleaning solvent instead of the fuel and thus
more accurately described using a technical name listed in the 49 CFR 172.101
Hazardous Materials Table or generic description such as "flammable liquid,
n.o.s." with the addition of the technical name. (See 49 CFR 172.203(k))
The outer packaging must be marked with the proper shipping name and
identification number and display a Class 3 label.
The unit qualifies for limited quantity exceptions if the net capacity of the unit is
not more than 1 L (for PG II) or 5 L (tor PG III).. Net capacity means the unit is
not designed to contain more than 1L or 5L, respectively. If the unit meets the
net capacity limitation, it can be packaged in a non-specification (not UN tested
and certified) packaging. However, the package must meet general packaging

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04-15-90 12:01PM
. POLAR
r0U3/U03
-
•
Non-regulated fuel control units
Fuel control units which have been re-filled with a non-regulated material prior to
being shipped to the maintenance facility are not subject to either domestic or
international hazardous materials regulations.
Charles N. Lovinski
Program Manager
Dangerous Goods and Cargo Security
- **truncated:** false
- **body characters:** 5965
