Mr. Timothy H. Shaw — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Research and Washington, D.C. JAN 28 2000 Mr. Timothy H. Shaw 484 West Main Street Ref. No. 99-0265 Milan, MI 48160 Dear Mr. Shaw: This is in response to your letter dated September 25, 1999, regarding the requirement for showing the letters, "UN" on shipping documents under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the notification to the Pilot-in-Command may omit the letters "UN" before the corresponding hazardous material identification number. The answer is no. Section 175.33(a)(1), Notification of pilot-in-command, requires that the notification to the pilot contain the identification number of the material as specified in § 172.101, Hazardous Materials Table (HMT), or the International Civil Aviation Organization's (ICAO) Technical Instructions. Section 4.1.2 of Part 4, Chapter 4 of the ICAO Technical Instructions requires that an identification number be preceded by the letters "UN." It is the opinion of this Office that the information provided to the Pilot-in-Command, as specified in paragraph above. 4.1.1 of Part 5, Chapter 4 must be consistent with the documentation requirements identified in the I hope this satisfies your request. Sincerely, Dintellip, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 990265 17533#

Page 2... Milan, MI 48160 484 West Main Street September 24, 1999 helson Mr. Edward Mazzullo Director of Hazardous Materials Standards S175.33 DHM-10 USDOT / RSPA 400 Seventh Street S.W. 99-0265 Washington, DC 20590-0001 VIA FACSIMILE 202-366-3012 Dear Mr. Mazzullo, received a response. On October 1, 1998, I wrote to Mr. Alan Roberts concerning the following issue. To date / have not 49CFR §175.33 details the information that must be given to the Pilot-in Command of any aircraft practicable before flight. transporting hazardous materials aboard (including attached to or suspended from) aircraft as soon as or the ICAO Technical Instructions. 49CFR §175.33(a)(1) requires (among other elements), the UN number as specified in 49CFR §172. 101, (camer customer certilication information deleted) for 'Paint related material, UN1263, shows the UN The enclosed "Dangerous Goods Load Notification to Captain number as "1263." "1263" under the column heading "UN No." 49CFR§172.101 shows this number as "UN1263," the ICAO Technical Instructions shows this entry as Note that the column on the 'Dangerous Goods Load Notification to Captain' is headed "UN / ID Number." Captain' for "Paint Related Material," satisfy the identification number requirement of 49CFR $175.33? My question: Does the entry for UN Number on the enclosed 'Dangerous Goods Load Notification to Command,' Paragraph 4.1.1(b) requires "...and UN number as listed in these instructions;..." (italics The 1999/2000 edition of the ICAO Technical Instructions; Part 5, Chapter 4, 'Information to Pilot-in- added), be provided to the Captain by the operator. The 1999/2000 edition of the ICAO Technical Instructions; Part 4; Chapter 4, 'Documentation' Paragraph "UN"..." 4.1.2 requires the shipper to include on the shipping paper"..'UN number (if any) preceded by the letters Does the 'UN Number "as listed in these instructions" include the prefix 'UN'? Or by virtue of a column circumstances? I realize that the 'UN' identifier is required only for those entries to which a UN identifier heading, is the 'UN number' simply a four-digit identifier, with the prefix necessary only under specific has been assigned. I look forward to your interpretation. Respectfully submitted Timothy H. Shaw 734-439-2475 evenings 734-623-0500 ext. 222 days Encl. (1) 91t769+*01 -#