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Interpretation Response #15-0205

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

Interpretation Response Details

Response Publish Date: 03-29-2016
Company Name: Air General Inc.    Individual Name: Mr. Dennis Franco
Location state: VA    Country: US

View the Interpretation Document

Response text:

March 29. 2016

Mr. Dennis Franco
Manager, DG Compliance
Air General Inc.
2200 Columbia Pike, Apt # 711
Arlington, Virginia 22204-4418

Reference No. 15-0205

Dear Mr. Franco:

This letter is in response to your October 17, 2015 e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the Hazardous Materials Table (HMT) entry, “UN1950, Aerosols, poison, Packing Group III (each not exceeding 1 L capacity).”  Specifically, you request confirmation of your understanding that because this material is forbidden for air transportation in Columns 9A and 9B of the HMT, it cannot be transported by air, even when authorized by the international air regulations.

Your understanding is correct.  The International Air Transport Association (IATA) Dangerous Goods Regulations do not have official standing within the United States.  However, § 171.22(a) authorizes use of the International Civil Aviation Organization (ICAO) Technical Instructions as an alternative to compliance with the HMR, provided the requirements of Part 171 Subpart C are met.  Under § 171.22(e), a material that is designated as “forbidden” in Column 9A or 9B of the HMT may not be transported to, from, or within the United States by passenger or cargo aircraft, respectively.

I hope this information is helpful.  Please contact us if we can be of further assistance.


T. Glenn Foster
Chief, Regulatory Review and Reinvention
Standards and Rulemaking Division

171.22(a), 171.22(e)

Regulation Sections

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