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Interpretation Response #02-0137 ([Singapore Airlines Ltd] [MuthusamyChandran])

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: MuthusamyChandran

Country: SG

View the Interpretation Document

Response text:

June 28, 2002

Mr. Muthusamy Chandran                    Reference No. 02-0137

Senior Officer

Singapore Airlines Ltd.

Airline House 05A

Singapore

Dear Mr. Chandran:

This is in response to your April 16, 2002 letter regarding the classification of a material under the Hazardous Materials Regulations (HMR,49 CFR parts 171-180).  Specifically, you ask if Mobil Jet Oil or Skdrol contained in hydraulic parts is considered a hazardous material for air transportation.

Although you did not provide material safety data sheets (MSDS) for these products, you state that the MSDS for these materials do not indicate they are hazardous for air transportation and that they can be air freighted as normal cargo.  Subsequently, the materials in your hydraulic parts would have to exhibit some characteristic that would make them hazardous for transportation, including by air.  If the materials in your hydraulic parts do not meet the definition of a hazardous material, such as a flammable liquid, and the internal fluid is identical in nature to the material listed in the MSDS, then it would appear that the hydraulic parts you described are not subject to the HMR.

It is up to the offerer to determine if their material is hazardous or not.  Additionally, your material may be subject to applicable requirements of the International Civil Aviation Organization's Technical Instructions.

I hope this satisfies your request.

Sincerely,

Delmer F. Billings

Chief, Standards Development

Office of Hazardous Materials Standards

173.222

Regulation Sections