Interpretation Response #01-0050 ([Mr. Tim Shaw])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name:
Individual Name: Mr. Tim Shaw
Location State: MI Country: US
View the Interpretation Document
Response text:
MAR 9, 2001
Mr. Tim Shaw Ref. No. 01-0050
484 West Main Street
Milan, MI 48160
Dear Mr. Shaw:
This is in response to your letter dated February 7, 2001, requesting clarification on the expression of net mass or net volume on a shipping paper prepared in accordance with the International Civil Air Organization's Technical Instructions for the Safe Transport of Dangerous Goods By Air (ICAD Technical Instructions). Specifically, you ask if the expression "1 Fiberboard Box X Kilograms 41.3111 satisfies Part 4; paragraph 4.1.3(a)(I) of the ICAO Technical Instructions.
Section 171.11 of the HMR authorizes the use of the ICAO Technical Instructions in lieu of the HMR for packaging, marking, labeling, classifying, and describing hazardous materials which are transported by air or by motor-vehicle either before or after being transported by air. Part 4; paragraph 4.1.3(a)(l) of the ICAO Technical Instructions requires that, "except for salvage packagings, when a maximum quantity per package is shown in columns 10 or 12 of Table 2-14, the net mass, the net volume, or the gross mass, as appropriate, for every package of each item of dangerous goods bearing a different proper shipping name or UN number or packing group" must be included on the dangerous goods transport document (i.e., shipping paper).
Though the ICAO Technical Instructions do not state that the unit of measure precede or follow the quantity therein, it is our opinion that the unit of measurement is required and that it must follow the total quantity. Therefore, the expression "1 Fiberboard Box X Kilograms 41.31 n does not satisfy the requirements of Part 4; paragraph 4.1.3(a)(1) of the ICAD Technical Instructions. We are considering proposing clarifying text to the ICAO Technical Instructions.
I hope this satisfies your request.
Sincerely,
John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards
171.11