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Interpretation Response #00-0238 ([Singapore Airlines Ltd] [Mr. M. Chandran])

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

Interpretation Response Details

Response Publish Date:

Company Name: Singapore Airlines Ltd

Individual Name: Mr. M. Chandran

Country: SG

View the Interpretation Document

Response text:

DEC 19, 2000

Mr. M Chandran                Reference No. 00-0238

Senior Officer

Singapore Airlines Ltd

Airline House 05A

Singapore 819829

Dear Mr. Chandran:

This is in response to your letter dated August 4, 2000, regarding the classification and packaging of aircraft fuel control units under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Your questions are paraphrased and answered as follows:

Ql.       The Federal Aviation Administration published Dangerous Goods Advisory Bulletin (DGAB) 98-02 in 1998.  This document addressed concerns over fuel control units being improperly packaged and leaking while in transportation.  Have any amendments to DGAB 98-02 been published?

Al.        No.

Q2.      The HMR and the International Air Transport Association Dangerous Goods Regulations (IATA DGR) show different proper shipping names for fuel control units: "Fuel, aviation, turbine, engine" and "Dangerous goods in machinery or apparatus," respectively.  Are we in compliance with the HMR by using either description?

A2.      The shipping description "Dangerous goods in machinery or apparatus" was adopted into the HMR in a final rule published on March 5, 1999 (Docket HM-215C; 64 FR 10742).  It is our opinion that "Dangerous goods in apparatus" is the more appropriate shipping description.

Under the conditions specified in § 171.11 of the HMR, we recognize the International Civil Aviation Organization (ICAO) Technical Instructions for the Safe Transport of Dangerous Goods by Air.  Therefore, an aircraft fuel control unit may be shipped in accordance with the ICAO Technical Instructions or the HMR.  The classification and packaging requirements for fuel control units in the IATA DGR are the same as those contained in the ICAO Technical Instructions.

Q3.      Is polystyrene acceptable as an absorbent material when packaged with a flammable liquid?

A3.      Polystyrene may be used as a absorbent material only if it conforms to the conditions prescribed in '' 173.24 and 173.27. In ' 173.24, paragraphs (e)(1) and (2) state that the packaging material must be compatible with the lading.  Section 173.27(e) states that the absorbent material must be capable of absorbing without reacting dangerously with the liquid.

I trust this satisfies your request.  Please contact us if we can be of further assistance.



Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards



Regulation Sections

Section Subject
173.22 Shipper's responsibility