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.
Sincerely,
Ben Supko
Acting Chief, Standards Development
Standards and Rulemaking Division
175.75, 172.202