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Interpretation Response #09-0105 ([ShipMate, Inc.] [Mr. Steven Charles Hunt])

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

Interpretation Response Details

Response Publish Date:

Company Name: ShipMate, Inc.

Individual Name: Mr. Steven Charles Hunt

Location State: OR Country: US

View the Interpretation Document

Response text:

June 19, 2009




Mr. Steven Charles Hunt

ShipMate, Inc.

780 Buckaroo Trail, Suite D

Sisters, OR 97759-0787

Ref. No.: 09-0105

Dear Mr. Hunt:

This responds to your letter regarding exceptions for the transportation of accumulators on board a passenger-carrying aircraft under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the International Civil Aviation Organizations Technical Instruction for the Safe Transport of Dangerous Goods by Aircraft (ICAO Technical Instructions). Specifically, you ask for confirmation of your understanding that accumulator devices are not subject to the HMR, provided the accumulators meet all of the requirements of §173.306(f)(4), in addition to Special Provision "A114" under the ICAO Technical Instructions.

Your understanding is correct. Accumulators intended to function as shock absorbers, struts, gas springs, pneumatic springs or other impact or energy-absorbing devices are not subject to the HMR, provided they meet the criteria as specified in § 173.306(f)(4). In addition, articles, containing gas, intended to function as shock absorbers, including impact energy absorbing devices, or pneumatic springs are not subject to the ICAO Technical Instructions, provided they meet the conditions of Special Provision "A114," when shipped by aircraft.

I hope this satisfies your inquiry. If we can be of further assistance, please contact us.


Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards

173.306(f)(4), 172.102 SP A114

Regulation Sections

Section Subject
173.306 Limited quantities of compressed gases