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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 #13-0094 ([UPS] [Mr. Samuel Elkind])

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

Interpretation Response Details

Response Publish Date:

Company Name: UPS

Individual Name: Mr. Samuel Elkind

Location State: GA Country: US

View the Interpretation Document

Response text:

June 24, 2013


Mr. Samuel Elkind
Corporate Regulated Goods Manager
United Parcel Service
55 Glenlake Parkway, NE
Atlanta, GA 30328-3474

Ref. No.: 13-0094

Dear Mr. Elkind:

This responds to your May 1, 2013 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to limited quantity packages of mixed contents.  For transportation by aircraft, you ask whether a shipper should use Table 3 in 
§ 173.27(f)(3), or the provisions in § 173.24a(c)(1)(iv) when determining the maximum net quantity of each inner and outer packaging for limited quantity packages of mixed contents.

As provided in § 173.27(f)(2), when a limited quantity of a hazardous material is packaged in a combination packaging and is intended for transportation aboard an aircraft, the inner and outer packagings must conform to the quantity limitations set forth in Table 3.  Table 3 provides the maximum net quantity of each inner and outer packaging for materials authorized for transportation as a limited quantity by aircraft.  For mixed contents of limited quantities by air, the shipper must comply with the maximum authorized net quantity of each outer package (column 4 of 5 in Table 3) and ensure that the total net quantity does not exceed the lowest permitted maximum net quantity per package as shown by hazard class or division for the hazardous materials in the mixed contents package.

However, we do recognize that the intent of Table 3 in § 173.27(f)(3) as compared to § 173.24a(c)(1)(iv) may be ambiguous in regard to limited quantity packages of mixed contents, and may consider revising the text in a future rulemaking.

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


T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

173.27(f), 173.24a(c)

Regulation Sections

Section Subject
173.24a Additional general requirements for non-bulk packagings and packages
173.27 General requirements for transportation by aircraft