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Interpretation Response #08-0146 ([L-3 Vertex Aerospace LLC] [Mr. Stephen W. Miller])

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

Interpretation Response Details

Response Publish Date:

Company Name: L-3 Vertex Aerospace LLC

Individual Name: Mr. Stephen W. Miller

Location State: MO Country: US

View the Interpretation Document

Response text:

June 25, 2008




Stephen W. Miller

L-3 Vertex Aerospace LLC

555 Industrial Drive South

Madison, MS 39110

Ref. No. 08-0146

Dear Mr. Miller:

This responds to your May 19, 2008 letter requesting clarification of the proper shipping name for aircraft fuel nozzles under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if nozzles that are removed and sent back to the manufacturer for servicing should be shipped as "Dangerous Goods in Apparatus" or non-hazardous. Your letter indicates that all fuel residue is removed from the nozzles using pressurized air.

Generally, items classified as "Dangerous Goods in Apparatus" (e.g., fuel pumps and injectors, engines, parts, etc.) contain the residue of a hazardous material. If the aircraft fuel nozzles you describe have been completely drained, sufficiently cleaned of residue, and purged of vapors to remove any potential hazard then they are no longer considered hazardous materials. As such, they are not subject to the HMR and may be shipped as non-hazardous (§ 173.22). You should note, however, as the shipper it is your responsibility to properly class the nozzles for transportation; this office cannot make that determination for you.

I hope this information is helpful. Please contact us if you require additional assistance.

Sincerely,

Susan Gorsky,

Acting Chief, Standards Development

Office of Hazardous Materials Standards

173.22 173.222

Regulation Sections

Section Subject
173.22 Shipper's responsibility
173.222 Dangerous goods in equipment, machinery or apparatus