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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 #11-0016 ([AllTransPack, 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: AllTransPack, Inc.

Individual Name: Mr. Hank Baird .

Location State: VA Country: US

View the Interpretation Document

Response text:

July 19, 2011



Mr. Hank Baird

General Manager

AllTransPack, Inc.

22815 Glenn Drive

Suite 101

Sterling, VA 20164

Ref. No. 11-0016

Dear Mr. Baird:

This responds to your November 19, 2010 request for clarification on the use of Special Permit DOT-SP 12382 authorizing the transport of certain explosives by aircraft. According to your letter, AllTransPack, Inc. (ATP) has been asked by the State Department to prepare and certify a shipment of explosives (UN 0042; UN 0065; UN 0241; and UN 0288) intended for international air transport using an existing Special Permit DOT-SP 12382. These explosives are forbidden for air transport both by the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the International Civil Aviation Organization (ICAO) Technical Instructions. Specifically, you ask if DOT-SP 12382 meets requirements under

§ 105.5 of Part 105, Part 107, Subpart H of the 49 CFR, and Part 1, Paragraph 1.1 of the International Civil Aviation Organization (ICAO) Technical Instructions as a Competent Authority Approval for international air transport.

The answer is yes. DOT-SP 12382 permits you to ship UN 0042, UN 0065, UN 0241, and UN 0288 in international air transport. 49 CFR 107.1 defines a Competent Authority Approval as "an approval by the competent authority that is required under an international standard" and indicates that a special permit or approval is a competent authority approval. Therefore, DOT-SP 12382 serves as a competent authority approval, permitting you to ship these hazardous materials in international air transport. The Associate Administrator is the competent authority for the United States for purposes of Part 107.

I hope this answers your inquiry. If you need additional assistance, please contact this office at (202) 366-8553.


Ben Supko

Chief, Standards Development Branch

Standards and Rulemaking Division

172.101, 173.27, 173.30

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table