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Interpretation Response #18-0139

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

Interpretation Response Details

Response Publish Date:

Company Name: SorbTech, Inc.

Individual Name: Joanna Kilburn

Location State: IN Country: US

View the Interpretation Document

Response text:

March 28, 2019   

Joanna Kilburn
SorbTech, Inc.
1305 Veterans Parkway, Suite 600
Clarksville, IN  47129

Reference No. 18-0139

Dear Ms. Kilburn:

This letter is in response to your November 2, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to limited quantity shipments by air.  Specifically, you seek clarification of the shipping paper requirements for domestic and international shipments of limited quantities by air originating in the United States.
 
The HMR define “limited quantity” as the maximum amount of a hazardous material for which there is a specific labeling or packaging exception.  Although excepted from certain HMR requirements (i.e., specification packaging and placarding), a limited quantity package requires an accompanying shipping paper when offered for transportation or transported by air or vessel (see §§ 173.150 through 173.155).  Section 172.203(b) of the HMR states that when a shipping paper is required for a material offered for transportation as a “limited quantity,” it must include the words “Limited Quantity” or “Ltd Qty” following the basic description.

While your email references the International Air Transport Association (IATA), please note that the HMR do not officially recognize the IATA Dangerous Goods Regulations for purposes of transporting hazardous materials.  However, § 171.22 of the HMR authorizes use of the International Civil Aviation Organization’s (ICAO) Technical Instructions for the Safe Transport of Dangerous Goods by Air (Technical Instructions) provided shipments offered under the ICAO Technical Instructions conform to the applicable requirements of §§ 171.23 and 171.24.  The ICAO Technical Instructions provide exceptions for limited quantities under Part 3; Chapter 4.  Specifically, the dangerous goods transport document must include the applicable limited quantity packing instruction identified by the prefix letter “Y” indicated in Column 10 of the Dangerous Goods List (see Part 5; Chapter 4.1.5.8.1 of the ICAO Technical Instructions).  Therefore, the “Y” packing instruction would replace the words “Limited Quantity” or “Ltd Qty” when shipping limited quantity packages internationally in accordance with the ICAO Technical Instructions.

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
Standards and Rulemaking Division

173.150, 173.155, 172.203(b), 171.23, 171.24

Regulation Sections

Section Subject
171.23 Requirements for specific materials and packagings transported under the ICAO Technical Instructions, IMDG Code, Transport Canada TDG Regulations, or the IAEA Regulations
171.24 Additional requirements for the use of the ICAO Technical Instructions
172.203 Additional description requirements
173.150 Exceptions for Class 3 (flammable and combustible liquids)
173.155 Exceptions for Class 9 (miscellaneous hazardous materials)