Interpretation Response #07-0232
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Mr. Michael Tobin, CHMM
Manager, Dangerous Goods
Alaska Airlines, Inc.
P.O. Box 68900 SEADG
Seattle, WA 98168
Ref. No. 07-0232
Dear Mr. Tobin:
This responds to your December 17, 2007 e-mail requesting clarification of the shipping paper requirements for consumer commodity (ORM-D) materials under the hazardous materials regulations (HMR; 49 CFR Parts 171-180) and the Internationals Civil Aviation Organization (ICAO) Technical Instructions (TI). You note that under the ICAO TI, for a material described as an "ID8000, consumer commodity, 9," the gross mass may be indicated on the shipping paper using the average gross mass per package (for example, if there are 10 packages and the total gross mass of them is 100 kg, the dangerous goods transport document may show this as "average gross mass per package 10kg"). You ask if the HMR permit the use of average gross mass per package to indicate total quantity on shipping papers for domestic transportation of consumer commodity, ORM-D materials by air.
The answer is no. For transportation by aircraft, the gross mass per package is required to be indicated on the shipping paper for consumer commodity (ORM-D) materials (§ 172.202(a)(6)). The use of average gross mass per package is not authorized by the HMR.
Note that § 171.22 authorizes the use of the ICAO TI for transportation of hazardous materials by aircraft. Therefore, average gross mass per package may be used to describe the quantity of a material on a shipping paper when the material is described as "ID8000, consumer commodity, 9" in accordance with the ICAO TI.
I hope this information is helpful. Please contact us if you require additional assistance.
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
|§ 172.202||Description of hazardous material on shipping papers|