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Interpretation Response #12-0200 ([Events Air Cargo] [Mr. Vincent F. Staregowski])

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

Interpretation Response Details

Response Publish Date:

Company Name: Events Air Cargo

Individual Name: Mr. Vincent F. Staregowski

Location State: AK Country: US

View the Interpretation Document

Response text:

December 5, 2012

Mr. Vincent F. Staregowski
Hazmat Specialist
Events Air Cargo
6111 Lockheed
Anchorage, AK  99518

Reference No.: 12-0200

Dear Mr. Staregowski:

This is in response to your September 05, 2012 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  You present a scenario in which you utilize an electric battery- powered pallet jack to move pallets from the door of the aircraft to their assigned position on the aircraft.  The pallet jack then travels with the aircraft and is utilized to move pallets back to the door for offload at destination.  Finally the pallet jack returns with the aircraft to its final destination.  You ask if shipping papers are required for the movement of this pallet jack.

As specified in § 175.8(a)(2), hazardous materials required aboard an aircraft in accordance with the applicable Federal Aviation Administration (FAA) airworthiness requirements and operating regulations are excepted from the requirements of the HMR.  If the pallet jack is not eligible for the exception in § 175.8(a)(2) requirements for transporting battery- powered equipment for transportation by aircraft are found in § 173.220.  Various exceptions are also provided in § 173.220(h).  It should be noted that shipping papers are not excepted for battery- powered machinery when offered for transport by aircraft.

I trust this satisfies your inquiry.  Please contact us if we can be of further assistance.


Delmer Billings
Senior Regulatory Advisor  
Standards and Rulemaking Division


Regulation Sections

Section Subject
173.220 Internal combustion engines, vehicles, machinery containing internal combustion engines, battery-powered equipment or machinery, fuel cell-powered equipment or machinery
175.8 Exceptions for operator equipment and items of replacement