Interpretation Response #13-0203 ([United Airlines, Inc.] [Mr. William B. Wojtas])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: United Airlines, Inc.
Individual Name: Mr. William B. Wojtas
Location State: IL Country: US
View the Interpretation Document
Response text:
May 1, 2014
Mr. William B. Wojtas
Manager, Dangerous Goods
United Airlines, Inc.
233 South Wacker Drive
Chicago, IL 60606
Ref. No.: 13-0203
Dear Mr. Wojtas:
This is in response to your October 16, 2013 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding the standard for converting liters to kilograms. In your letter, you ask if the specific gravity of a liquid must be used when converting from volume (liters) to net mass (kilograms) in situations when the net mass is required by the HMR such as determining compliance with the loading requirements of § 175.75 and verifying the maximum gross weight authorized as a limited quantity. You state this conversion is difficult for air cargo acceptance personnel because neither the HMR, nor the International Civil Aviation Organization Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO TI) mandate provision of the specific gravity or density as part of the information to be provided by shippers. You ask if a 1 liter to 1 kilogram (1:1 ratio) volume to mass conversion is acceptable for all liquid hazardous material.
In a previous letter of interpretation, 10-0145, dated December 3, 2010, applicable to this scenario, guidance was provided by stating that when 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. However, in this case the HMR do not require the use of a specific method for converting units of measure. Therefore, as an alternative to the use of specific gravity data, a 1:1 conversion ratio where 1 liter is equal to 1 kilogram may be used for the purposes of interpreting the HMR cargo quantity limitations expressed in kilograms.
I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division
175.75
Regulation Sections
| Section | Subject |
|---|---|
| 175.75 | Quantity limitations and cargo location |