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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #00-0285 ([Air Transport International, L.L.C.] [Mr. Jack Hagenmayer])

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

Interpretation Response Details

Response Publish Date:

Company Name: Air Transport International, L.L.C.

Individual Name: Mr. Jack Hagenmayer

Location State: OH Country: US

View the Interpretation Document

Response text:

MAY 30, 2001

Mr. Jack Hagenmayer                    Ref. No. 00-0285


Aircraft Ground Services

Air Transport International, L.L.C.

One Air Cargo Parkway East

Swanton, Ohio 43558-9490

Dear Mr. Hagenmayer:

This responds to your letter regarding the quantity limitation and package containment requirements for hazardous materials transported by cargo-only aircraft under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows:

Q1. Is it acceptable to stow 25 kg net weight of hazardous material and, in addition, 75 kg net weight of Division 2.2 non-flammable compressed gas, in a freight container that is loaded in an accessible cargo compartment on the main deck of a cargo-only aircraft? What limit, if any, is placed upon multiple freight containers containing hazardous materials?

Al. If the cargo compartment is accessible, § 175.75(a) (2) (ii) permits 25 kg of hazardous materials and, in addition, 75 kg net weight of Division 2.2 non-flammable gas, that are acceptable on a passenger-carrying aircraft, to be loaded in each freight container regardless of the number of containers in the compartment. If the cargo compartment is inaccessible, the 25 kg/75 kg limit applies to the entire compartment.

As specified in § 175.85{b), hazardous materials acceptable only on cargo aircraft must be stowed in such a manner that they can be seen, handled, and when size and weight permit, separated from other cargo while in flight. Provided these cargo-aircraft-only hazardous materials are accessible and within an accessible compartment, they may be stowed in a freight container or other suitable containment without regard to the weight limitation. Certain hazard classes that may be carried in an inaccessible location without regard to the § 175.75(a) (2) weight limitation are specified in § l7 5.85 (c) (1) .

Q2. Do pallet and net/strap combinations meet the definition of a freight container? Are accessible pallet and net combinations subject to the weight limitations in § l75.75(a) (2)?

A2. No. A pallet, which is a bottom platform used in combination with a net or straps, does not meet the definition in § 171.8 of a freight container. A pallet, used in combination with a net, would meet the definition in § 171.8 of a unit load device. For transportation by cargo ­only aircraft, passenger authorized hazardous materials loaded on an accessible unit load device within an accessible compartment are not subject to the weight limitations specified in § 175.75{a) (2).

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


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

175.75(a)(2)(iii), 178.8

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
175.75 Quantity limitations and cargo location
175.75 Quantity limitations and cargo location