Interpretation Response #16-0195 ([CARGOpak Corp.] [Mr. Robert Smith])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: CARGOpak Corp.
Individual Name: Mr. Robert Smith
Location State: NC Country: US
View the Interpretation Document
Response text:
June 26, 2017
Mr. Robert M. Smith
President/Senior Instructor
CARGOpak Corp.
3108 Taylors Ridge Road
Wake Forest, NC 27587
Reference No. 16-0195
Dear Mr. Smith:
This letter is in response to your November 17, 2016, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to "UN1324, Films, nitrocellulose base."
We have paraphrased and answered your questions as follows:
Q1. You ask why "UN1324, Films, nitrocellulose base," is afforded limited quantity provisions in accordance with the International Civil Aviation Organization Technical Instructions on the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions) but not the HMR.
A1. Historically, the HMR have not provided limited quantity provisions for "UN1324, Films, nitrocellulose base." We note that the ICAO Technical Instructions provide limited quantity provisions for this material and may consider amending the HMR to adopt similar provisions in a future rulemaking.
Q2. You ask if a shipper may offer "UN1324, Films, nitrocellulose base," to and from the United States by air in accordance with the limited quantity provisions of the ICAO Technical Instructions.
A2. The answer is yes. A shipment of "UN1324, Films, nitrocellulose base," may be offered for transportation or transported within the United States by air as a limited quantity in accordance with the provisions of the ICAO Technical Instructions as authorized by § 171.22(b) of the HMR.
Q3. You ask if the provision in § 173.183 that permit the use of a canister as an inner packaging means the specified outer packagings are only authorized if tested as a combination packaging.
A3. The answer is yes. Single packagings are not authorized for the transport of "UN1324, Films, nitrocellulose base." This is consistent with the ICAO Technical Instructions.
Q4. You ask if a shipper may offer for domestic transport a single canister of "UN1324, Films, nitrocellulose base," in one of the alternative outer packagings authorized by the ICAO Technical Instructions.
A4. The answer is yes. A shipment of "UN1324, Films, nitrocellulose base," may be offered for transportation or transported within the United States by aircraft in accordance with the provisions of the ICAO Technical Instructions as authorized by § 171.22(b) of the HMR.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division
171.22(b), 173.183