Interpretation Response #18-0091
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Hazmat Safety Consulting LLC
Individual Name: Bob Richard
Location State: VA Country: US
View the Interpretation Document
Response text:
October 25, 2019
Bob Richard
Hazmat Safety Consulting LLC
10036 Lake Occoquan Drive
Manassas, VA 20111
Reference No. 18-0091
Dear Mr. Richard:
This letter is in response to your June 18, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to exceptions for passengers, crewmembers, and air operators. Specifically, you ask if a passenger may carry a 30-milliliter sterilization cartridge of nitric acid (Packing Group II, with not more than 20 percent) aboard a passenger aircraft in accordance with § 175.10 of the HMR. You state that the product in question is meant for doctors conducting humanitarian relief to sterilize medical tools in remote areas without access to electricity.
The answer is no. It is the opinion of this Office that the material in the quantity specified would not be permissible for carriage aboard passenger aircraft under § 175.10(a)(1). Section 175.10(a)(1) allows non-radioactive medicinal and toilet articles for personal use to be carried in carry-on and checked baggage. The sterilization cartridges as described in your scenario are not for personal use. However, it should be noted that these cartridges can be transported as cargo 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
Standards and Rulemaking Division
175.10, 175.10(a)(1)
Regulation Sections
| Section | Subject |
|---|---|
| 175.10 | Exceptions for passengers, crewmembers, and air operators |