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Interpretation Response #09-0147 ([AP Training, Inc.] [Mr. Hank Baird])

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

Interpretation Response Details

Response Publish Date:

Company Name: AP Training, Inc.

Individual Name: Mr. Hank Baird

Location State: VA Country: US

View the Interpretation Document

Response text:

August 12, 2009




Mr. Hank Baird

General Manager

AP Training, Inc.

22815 Glenn Drive, Suite101

Sterling, VA 20164

Ref. No. 09-0147

Dear Mr. Baird:

This responds to your letter dated June 25, 2009, regarding shipping paper requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask about the requirement applicable to Class 1 materials for the net explosive mass of the material or article. Your questions are paraphrased and answered as follows:

Q1. Is the requirement in §172.202(a)(5)(i) to communicate on shipping papers the "net explosive mass" of a Class 1 material or article required for those articles offered for transportation by aircraft?

A1. In accordance with § 172.202(a)(6), for transportation by aircraft, a shipping paper must indicate the total net mass of hazardous materials in a package, unless a gross mass is indicated in the Hazardous Materials Table (HMT) in § 172.101, in which case the gross mass per package must be shown. For Class I materials transported by aircraft, the shipping paper must include an indication of the net explosive mass of the material. For explosive articles, the net explosive mass may be expressed in terms of either the net mass of the article or the explosive materials contained in the article.

Q2. Is it permissible to enter both the "net explosive mass" and the "gross mass" on the shipping paper for those explosive articles or devices offered for transportation by aircraft?

A2. The HMR require only the "net explosive mass" to be entered on the shipping paper for explosive articles offered for transportation by aircraft. However, nothing in the

HMR prohibits the inclusion of both the net explosive mass of the material or article and the gross mass of the package on the shipping paper.

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

Sincerely yours,

Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
172.202 Description of hazardous material on shipping papers