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Interpretation Response #15-0165 ([Air General] [Mr. Dennis Franco])

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

Interpretation Response Details

Response Publish Date:

Company Name: Air General

Individual Name: Mr. Dennis Franco

Location State: VA Country: US

View the Interpretation Document

Response text:

December 15, 2015

Mr. Dennis Franco
Manager DG Compliance
Air General
2200 Columbia Pike, Apt # 7-11
Arlington, VA 22204

Reference No. 15-0165

Dear Mr. Franco:

This is in response to your August 2, 2015 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers.  Your questions are paraphrased and answered below:

Q1. Are the words “Limited Quantity” or “LTD QTY” required to be included on a shipping paper if the shipment is prepared in accordance with the International Civil Aviation Organization Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions)?

A1. No, when offered for transport or transported by air hazardous materials must be described and certified on a shipping paper in accordance with part 172 or as authorized by subpart C of part 171 (see § 175.30(a)). The ICAO Technical Instructions do not require the words “Limited Quantity” or “LTD QTY” to be included on a shipping paper. Consequently, if the shipment is prepared in accordance with the ICAO Technical Instructions any additional information required to be shown on shipping papers is limited to that required by subpart C of part 171.

Q2. Are the words “Limited Quantity” or “LTD QTY” required to be included on the notification to the pilot in command if the shipment is prepared in accordance with the ICAO Technical Instructions?

A2. No, if a hazardous material is described by the proper shipping name, hazard class and identification number appearing in the ICAO Technical Instructions any additional information required to be shown on shipping papers is limited to that required by subpart C of part 171 (see § 175.33(a)(1)).  Examples of such additional information include additional notations required for hazardous substances and hazardous wastes. If the hazardous material is offered for transport in accordance with the HMR any additional description requirements provided in §§ 172.202 and 172.203 must also be shown on the notification. One example is the requirement to include the words “Limited Quantity” or “LTD QTY” for limited quantity shipments.

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

Sincerely,

Duane Pfund
International Standards Coordinator
Standards and Rulemaking Division

175.30(a), 175.33(a)(1), 172.202, 172.203

Regulation Sections

Section Subject
172.202 Description of hazardous material on shipping papers
172.203 Additional description requirements
175.30 Inspecting shipments
175.33 Shipping paper and notification of pilot-in-command