Dangerous Goods of America, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S.Department Washington, D.C. 400 Seventh Street, S.W. 20590 Special Programs Research and Administration JUN - 7 1999 Mr. Valois Pagan III Ref. No. 99-0098 Dangerous Goods of America, Inc, PO Box 590888 Miami, FL 33159-0888 Dear Mr. Pagan: This is in response to your letter dated April 8, 1999, regarding the classification of aircraft engines. Specifically, you ask how an aircraft engine is classified when offered for air transportation and whether it requires a shipper's Declaration of Dangerous Goods; and if an engine is accompanied by a certificate of drainage, is a declaration required. No person may offer a hazardous material for transportation unless the material is properly classified in accordance with the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- 180). The classification of a hazardous material is the responsibility of the shipper (§ 173.22). Aircraft engines that are offered for transportation by air and have not been completely purged of fuel are subject to the HMR. The engine must be accompanied by a hazardous materials shipping paper (e.g. Declaration of Dangerous Goods) that includes the shipper's certification required by § 172.204. An aircraft engine that is completely purged of all flammable materials is not subject to the HMR. I hope this satisfies your request. Sincerely, Than DOll Thomas G. Allan Acting Director, Office of Hazardous Materials Standards 173.220 990098#

Page 2DANGEROUS GOODS OF AMERICA, INC. nelson 8173.220 99-0098 PO BOX 590888 + MIAMI, FL 33159-0888 + USA E-MAIL: info@dangerousgoods.net • WEB SITE: www.dangerousgoods.net Phone (305) 871-3313 • Fax (305) 871-1388 Mr. Edward Mazzulo Department of Transportation Dangerous Goods/Hazardous Materials 400 7t Street SW Washington D.C. 20590 April 8, 1999 Dear Mr. Mazzulo, Below i have asked two questions in reference to aircraft/jet engines and their respective classification: Q: How do you classify an aircraft/jet engine when offered for air transport and does it require a Shipper's Declaration of Dangerous Goods? Q2: If an aircraft/jet engine is accompanied by a "certificate of drainage", is a Shipper's Declaration of Dangerous Goods required for air transport? Please respond in writing to: Dangerous Goods of America Mr. Val Pagan P O Box 590888 Miami, FL 33159 Please do not hesitate to contact our office should you have any questions. Best regards, Valois Pagan Ill Consultant OFFICE & WAREHOUSE FACILITIES + 1651 NW 68TH AVE • CARGO BLDG 706 • SUTE 213#