Polar Air Cargo — Hazardous Materials Safety Interpretation

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#

Page 2Apparatus, 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#

Page 3POLAR 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#

Page 404-15-96 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#

Page 504-15-90 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#