Interpretation Response #16-0067 ([Mr. Francis J. Mendez])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name:
Individual Name: Mr. Francis J. Mendez
Country: PR
View the Interpretation Document
Response text:
August 2, 2016
Mr. Francis J. Mendez
P.O. Box 6362
San Juan, PR 00914
Reference No. 16-0067
Dear Mr. Mendez:
This letter is in response to your March 2, 2016, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the shipment of “UN0044, Primers, cap type, by air.” Specifically, you ask if it is legal and in compliance with the HMR for a person traveling aboard a passenger aircraft to transport in checked baggage primers that are still packed in the original factory packaging, or if they must be shipped by cargo aircraft. You cite memos from the Federal Aviation Administration (FAA) and the Pipeline and Hazardous Materials Safety Administration (PHMSA) that prohibit the transportation of primers in checked baggage. You further add that the listing for “UN0044, Primers, cap type, 1.4S” in the § 172.102 Hazardous Materials Table allows primers to be shipped as hazardous materials aboard passenger aircraft up to 25 kg.
As outlined in the two memos you cited in your letter, § 175.10 prohibits primers that meet the definition of a 1.4S material from shipment in checked baggage on passenger aircraft. The primers you describe would be permitted for shipment aboard a passenger or cargo aircraft, with limitations, when offered to a common carrier in accordance with the HMR.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standard and Rulemaking Division
172.102, 175.10