Interpretation Response #98-0410 ([United Parcel Services] [Mr. Samuel S. Elkind])

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

Interpretation Response Details

Response Publish Date: 01/21/1998

Company Name: United Parcel Services

Individual Name: Mr. Samuel S. Elkind

Location State: KY Country: US

View the Interpretation Document

Response text:

JAN 21, 1998

Mr. Samuel S. Elkind

Air Dangerous Goods

United Parcel Services

1400 North Hurstbourne Pkwy

Louisville, Kentucky 40223

Dear Mr. Elkind:

This is in response to your December 8, 1997 letter to Mrs. Beth Romo of the Federal Aviation Administration's Dangerous Goods/Cargo Security Program concerning the distribution of shipping papers with a signed shipper's certification for UPS hazardous materials shipments transported by air. Your letter has been forwarded to this Office for reply.

In your letter, you described the following scenario:

The UPS eight-ply hazardous materials shipping paper with the signed shipper certification is affixed to a package, the top copy is removed at the original acceptance location, and subsequent copies are removed as the package moves through the UPS system. Except for the copy required to accompany the shipment, if all other copies of the original paperwork are distributed, a unreplacement" shipping paper is generated, on which all relevant descriptive information is re¬copied, with the exception of the certifying signature. In lieu of the signature, the phrase USignature on File" is entered, since the original acceptance location possesses the required file copy. The ureplacement" paper is then affixed to the package in such a way that the last copy of the original shipping document remains unobscured. This method ensures that the certification is in both required locations " the acceptance point and accompanying the shipment.

You further explained that, to deliver shipments destined for extended areas of Alaska, you utilize the services of an indirect air carrier to interline these shipments with air carriers flying into remote locations. The indirect air carrier you use has traditionally requested and received copies of each shipping document with the original certification to provid~ the air carriers. You asked if this movement is considered to be a conventional interline movement with UPS Airlines serving as the originating aircraft operator. If SOl you believe that the presence of the signed shipperls certification in the origin files and on the package would satisfy all requirements specified in Part 175 of the Hazardous Materials Regulations (HMRi 49 CFR Parts 171-180).

Your understanding is correct. One copy of a properly described and certified shipping paper must be retained by UPS as the originating aircraft operator and one copy must accompany the shipment during transport by air (see 49 CFR 175.30(a) (2) and 175.35(a} I respectively). The UPS procedures described above satisfy these requirements.

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

Sincerely,

Edward T. Muzzullo

Directorl Office of Hazardous

Materials Standards

175.30(a)(2)

Regulation Sections