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Interpretation Response #15-0044

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

Interpretation Response Details

Response Publish Date: 10-14-2016
Company Name: Northern Air Cargo    Individual Name: Mr. Mark Smith
Location state: AK    Country: US

View the Interpretation Document

Response text:

October 13, 2016

Mr. Mark Smith
Hazardous Materials Instructor
Northern Air Cargo
3900 Old International Airport Rd.
Anchorage, AK 99502

Reference No. 15-0044

Dear Mr. Smith:

This responds to your December 22, 2014 letter requesting clarification on transporting aerosols under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the International Civil Aviation Organization's Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO TI).  We apologize for the delay in responding and any inconvenience this may have caused.  You note that the ICAO TI dangerous goods list shows seventeen UN1950 “Aerosols” entries with varying primary and subsidiary hazards, while the HMR hazardous materials table (HMT) only lists five “Aerosols” entries.  You further note that no person may offer for transportation or transport a hazardous material that is a forbidden material or package that meets one of the provisions in § 171.22(e).  In your request you provide an example of a product that is described under the ICAO TI as “Aerosols, flammable 2.1 (6.1) PG III”, and noting that this is not an entry in the HMT, ask how an air carrier can ensure the material is not forbidden for transport as required by § 171.22(e) if the material is not listed in the HMT?

Section 173.115(l)(6) prohibits the transportation of substances of Division 6.1, PG I or II, and substances of Class 8, PG I in an aerosol container. This prohibition is in line with the Dangerous Goods List (DGL) entries for similar aerosols in the ICAO TI.  Section 173.115(l)(5) requires that when the aerosol contents are classified as Division 6.1, PG III or Class 8, PG II or III, the aerosol must be assigned a subsidiary hazard of Division 6.1 or Class 8, as appropriate.  The transport conditions and quantity authorizations for the HMT entry “UN 1950 Aerosols, flammable” align with the DGL entry “UN 1950 Aerosols, flammable 2.1 (6.1) PG III.”  In this specific case, in order to verify that the shipment is not forbidden one should consult the appropriate HMT entry for the primary hazard (UN 1950 Aerosols, Flammable).

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

171.22(e), 173.115(l)(6), 173.115(l)(5)


Regulation Sections

Section Subject
§ 171.22 Authorization and conditions for the use of international standards and regulations