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Interpretation Response #09-0207

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

Interpretation Response Details

Response Publish Date: 02-16-2010
Company Name: USA 3000 Airlines    Individual Name: Mr. William J. Hoffmann
Location state: PA    Country: US

View the Interpretation Document

Response text:

February 16, 2010




Mr. William J. Hoffmann
USA 3000 Airlines
335 Bishop Hollow Road, Suite 100
Newtown Square, PA 19073

Ref. No.: 09-0207

Dear Mr. Hoffmann:

This responds to your letter dated September 3, 2009, regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to the transportation of alcohol as company material (COMAT) by aircraft. You state that your airline sells 50 mL (mini) bottles of alcohol to passengers during flights. Specifically, you ask if your airline may transport this alcohol in the cargo holds of the aircraft as COMAT in accordance with § 175.8 to restock inventory at various locations.

The answer is no. Section § 175.8 provides certain exceptions for aircraft operator equipment and items of replacement for air worthiness requirements and operating regulations. Alcoholic beverages carried aboard passenger-carrying aircraft by the operator intended for use or sale on the aircraft in which the product is intended to be used or sold are specifically excepted from the requirements of the HMR (see § 175.8(b)(3)).

I hope this answers your inquiry.


Charles E. Betts
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
§ 175.8 Exceptions for operator equipment and items of replacement