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Interpretation Response #07-0236

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 03-17-2008
Company Name: Northern Air Cargo    Individual Name: Mr. Mark Smith
Location state: AK    Country: US

View the Interpretation Document

Response text: March 17, 2008

Mr. Mark Smith
Hazardous Materials Instructor
Northern Air Cargo
3900 Old International Airport Road
Anchorage, AK 99502

Ref. No. 07-0236

Dear Mr. Smith:

This responds to your December 18, 2007 email 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. Please keep in mind that many hazardous materials that qualify as ORM-D consumer commodities under the HMR may not qualify as Class 9 consumer commodities under 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(a)(6) 171.22

Regulation Sections

Section Subject
§ 171.22 Authorization and conditions for the use of international standards and regulations