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Interpretation Response #15-0016

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

Interpretation Response Details

Response Publish Date: 03-24-2015
Company Name: American Airlines    Individual Name: Mr. Michel A. Wentz
Location state: TX    Country: US

View the Interpretation Document

Response text:

March 24, 2015

Mr. Michel A. Wentz
Manager, Dangerous Goods Compliance
Safety, Security, & Environmental
American Airlines
4333 Amon Carter Blvd.
Fort Worth, TX 76155

Reference No. 15-0016

Dear Mr. Wentz:

This responds to your December 22, 2014 letter requesting clarification on transporting Class 7 materials under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) aboard passenger aircraft. Section 175.700(a) prescribes that no person may carry any Class 7 materials aboard a passenger-carrying aircraft unless that material is intended for use in, or incident to research, medical diagnosis or treatment. Regardless of its intended use, no person may carry a Type B(M) package aboard a passenger-carrying aircraft, a vented Type B(M) package aboard any aircraft, or a liquid pyrophoric Class 7 material aboard any aircraft.

You ask if a passenger aircraft operator may transport Type B(U) packages containing vials of liquid radioactive Molybdenum 99 (Mo99) and the return of empty Type B(U) containers as Type A packages, provided the requirements applicable to radioactive materials incident to research, medical diagnosis or treatment are satisfied.

The answer to your question is yes. Radioactive materials in Type B(U) and Type A packages that do not exceed a transport index of 3.0 and intended for use in or incident to research, medical diagnosis, or treatment may be transported on board passenger-carrying aircraft in accordance with §§ 173.448(f) and 175.700(a).

I trust this information is helpful. If you have further questions, please do not hesitate to contact this office.



Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division

173.448(f), 175.700(a)

Regulation Sections

Section Subject
§ 175.700 Special limitations and requirements for Class 7 materials