USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

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

Interpretation Response #10-0145 ([KLM Royal Dutch Airlines] [Mr. Michael van der Velde])

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

Interpretation Response Details

Response Publish Date:

Company Name: KLM Royal Dutch Airlines

Individual Name: Mr. Michael van der Velde

Country: NL

View the Interpretation Document

Response text:

December 3, 2010



Mr. Michael van der Velde

KLM Royal Dutch Airlines

P.O. Box 7700

1117 ZL Schiphol Airport

The Netherlands

Ref. No.: 10-0145

Dear Mr. van der Velde:

This responds to your June 25, 2010 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding quantity limitations and cargo location for carriage by aircraft under § 175.75 and United States (U.S.) Variation 13 in the International Civil Aviation Organization Technical Instructions for the Safe Transport of Dangerous Goods by Air. Your questions are paraphrased and answered below:

Q1. Please clarify the quantity limitations for hazardous materials transported in freight containers loaded in an accessible cargo compartment.

A1. As specified in § 175.75 and U.S. Variation 13, each package containing hazardous materials acceptable for transport aboard passenger aircraft, no more than 25 kg (55 pounds) net weight of hazardous materials and in addition thereto, 75 kg (165 pounds) net weight of Division 2.2 (non-flammable compressed gas) may be loaded in an inaccessible manner. This includes materials loaded in a freight container in an accessible cargo compartment. In the case of cargo freight containers, if the cargo compartment is accessible, the HMR and U.S. Variation 13 permit 25 kg of hazardous materials (reference to the Division 2.2 limit will be ignored for the sake of simplicity) in each freight container, regardless of the number of containers in the cargo compartment. If the cargo compartment is inaccessible, the 25 kg limit applies to the cargo compartment.

Q2. Please advise how an air carrier is expected to comply with the 25 kg weight limitation when the quantity of hazardous materials is indicated on the shipping paper by volume?

A2. As provided by § 172.202(a)(6), for transportation by aircraft, the total net mass per package, must be shown unless a gross mass is indicated in Columns (9A) or (9B) of the §172.101 table in which case the total gross mass per package must be shown. For transportation by aircraft, the HMR require the total quantity per package be expressed as a net

mass. However, if the net quantity shown on shipping documents is expressed as a volume (e.g. liters) the net mass expressed in kilograms may be calculated from the net volume by multiplying the volume of the liquid expressed in liters by its specific gravity.

I hope this answers your inquiry. If you have further questions, please do not hesitate to contact this office.


Ben Supko

Acting Chief, Standards Development

Standards and Rulemaking Division

175.75, 172.202

Regulation Sections

Section Subject
172.202 Description of hazardous material on shipping papers
175.75 Quantity limitations and cargo location