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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #10-0066 ([FedEx Express Corporation] [Mr. David Littlejohn])

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

Interpretation Response Details

Response Publish Date:

Company Name: FedEx Express Corporation

Individual Name: Mr. David Littlejohn

Location State: TN Country: US

View the Interpretation Document

Response text:

April 26, 2011




Mr. David Littlejohn

Corporate Safety Advisor

FedEx Express Corporation

3670 Hack Cross Road

Building G, 2nd Floor

Memphis, TN 38125-8800

Reference No. 10-0066

Dear Mr. Littlejohn:

This is in response to your e-mail and conversations with Mr. Shane Kelley and Ms. Eileen Edmonson of this agency"s Standards and Rulemaking Division, formerly the Office of Hazardous Materials Standards, concerning a package that contains "UN 1845, Carbon dioxide, solid (Dry ice), 9 (miscellaneous), PG III" and no other hazardous material. You state the package is prepared for air transportation in conformance with the International Civil Aviation Organization"s Technical Instructions for the Transport of Dangerous Goods by Air (ICAO Technical Instructions). You ask if a shipping paper or alternative paperwork is required and if the latter document would be subject to the shipping paper retention requirements. We apologize for the delay in responding and any inconvenience this may have caused.

Both the ICAO Technical Instructions and the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) (see 49 CFR 173.217(c)) except dry ice from the shipping paper requirements provided alternative written documentation is supplied and certain other requirements are met. Part 7.4.10 of the ICAO Technical Instructions requires operators to retain only the "dangerous goods transport documents" and not alternative documents, such as those prescribed for dry ice packages meeting the conditions prescribed in Packing Instruction 904. A hazardous material that is excepted from the shipping paper requirements under the HMR is also excepted from having to comply with the shipping paper retention requirements prescribed in §§ 172.201(e) and 175.33(c). Neither the HMR nor the ICAO Technical Instructions require retention of documentation when a shipping paper (transport document) is not required.

I hope this satisfies your request.


T. Glenn Foster

Chief, Regulatory Review and Reinvention Branch

Standards and Rulemaking Division

173.217(c), 172.201(c), 175.33(c)

Regulation Sections

Section Subject
172.201 Preparation and retention of shipping papers
173.217 Carbon dioxide, solid (dry ice)
175.33 Shipping paper and notification of pilot-in-command