Interpretation Response #15-0134 ([Alaska Airlines - SEADG] [Mr. Mike Tobin])

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

Interpretation Response Details

Response Publish Date: 09/21/2015

Company Name: Alaska Airlines - SEADG

Individual Name: Mr. Mike Tobin

Location State: WA Country: US

View the Interpretation Document

Response text:

September 21, 2015

Mr. Mike Tobin, CHMM
Manager, Dangerous Goods
Alaska Airlines - SEADG
P.O. Box 68900
Seattle, WA 98168

Ref. No. 15-0134

Dear Mr. Tobin:

This responds to your June 26, 2015 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding quantity limitations and cargo location for carriage aboard passenger-carrying aircraft under § 175.75(c). Your questions are paraphrased and answered in the order you provided.

Q1. Can 100 kg of Division 2.2 (non-flammable compressed gas) be loaded in an inaccessible manner if that is the only hazardous material subject to the quantity limits in § 175.75(c)?

A1. The answer is yes. In accordance with § 175.75(c), for each package containing a hazardous material acceptable for carriage aboard passenger-carrying aircraft, no more than 25 kg (55 pounds) net weight of hazardous material may be loaded in an inaccessible manner. In addition to the 25 kg limitation, an additional 75 kg (165 pounds) net weight of Division 2.2 (non-flammable compressed gas) may be loaded in the same compartment. As such, a package with a net weight of 100 kg of Division 2.2 may be loaded on a passenger-carrying aircraft in a single compartment in an inaccessible manner.

Q2. Please confirm the following three scenarios of different inaccessible aircraft cargo compartments are all in compliance with the regulation--

Compartment A: 25 kg Class 3, PG I, and 75 kg Division 2.2
Compartment B: 50 kg Class 9 and 100 kg Division 2.2
Compartment C: 10 kg Class 3, PG I, and 90 kg Division 2.2

A2. Your understanding is correct. All three scenarios described above meet the quantity limitations prescribed in § 175.75(c) for packages containing hazardous material acceptable for carriage aboard passenger-carrying aircraft loaded in an inaccessible manner.

I trust this satisfies your inquiry. Please feel free to contact us if you need further assistance.

Sincerely,

Duane Pfund
International Standards Coordinator
Office of Standards and Rulemaking

175.75(c)

Regulation Sections