Interpretation Response #17-0012 ([Couch Helicopter] [Ms. Bridgett Couch])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Couch Helicopter
Individual Name: Ms. Bridgett Couch
Location State: AZ Country: US
View the Interpretation Document
Response text:
June 29, 2017
Ms. Bridgett Couch
Couch Helicopter
P.O. Box 52
Walcott, AR 72474
Reference No. 17-0012
Dear Ms. Couch:
This letter is in response to your February 2, 2017, email and attached letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to reclassifying flammable liquids and placarding. Specifically, you ask about Jet A fuel ("UN1863, Fuel, aviation, turbine engine, 3, III"), which is a flammable liquid that your company transports in shop-built, non-specification tanks.
We have paraphrased and answered your questions as follows:
Q1. You ask for confirmation that "UN1863, Fuel, aviation, turbine engine, 3, III" can be reclassified as "NA1993, Combustible liquid, n.o.s., (Jet-A Fuel), 3, III."
A1. The answer is yes. The Hazardous Materials Table (HMT) allows exceptions for UN1863 material under § 173.150, which authorizes flammable liquids that meet the definition of no other hazard class and that have a flashpoint at or above 38°C (100 °F) to be reclassified as a combustible liquid. Note that when transporting hazardous materials that have been reclassified in accordance with § 173.150, all hazard communications (including placards) should reflect the same identification number—in this case, NA1993.
Q2. You ask whether "UN1863, Fuel, aviation, turbine engine, 3, III" can be carried in a non-specification tank. You note that your company uses home-built rather than factory-built non-specification tanks.
A2. The answer is no. Hazardous materials described as "UN1863, Fuel, aviation, turbine engine, 3, III" and transported in bulk are subject to Department of Transportation (DOT) specification packaging in accordance with § 173.242. However, in instances where UN1863 material is reclassified as a combustible liquid, non-DOT specification tanks suitable for liquids are permitted under § 173.241. The HMR do not distinguish between "home-built" and "factory-built" tanks as long as the non-DOT specification tanks are suitable for the transport of liquids.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
173.150, 173.242, 173.241