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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #22-0128

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

Interpretation Response Details

Response Publish Date:

Company Name: D.T. Gruelle Company Group LLC

Individual Name: Mr. James F. Thornton

Location State: PA Country: US

View the Interpretation Document

Response text:

August 15, 2023

Mr. James F. Thornton
Compliance Manager
D.T. Gruelle Company Group LLC – FMC 012187N
301 Moon Clinton Road
Moon Township, PA  15108

Reference No. 22-0128

Dear Mr. Thornton:

This letter is in response to your November 28, 2022, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of cartridges, small arms by aircraft. Specifically, you ask whether "UN0012, Cartridges, small arms, 1.4S" is subject to the quantity limitations specified in United States (U.S.) Variation 13 of the International Civil Aviation Organization (ICAO) Technical Instructions.

The answer is no, provided "UN0012, Cartridges, small arms, 1.4S" meets the requirements specified in § 173.63(b) of the HMR.  When a country's provisions vary from the ICAO Technical Instructions, those "variations" are published in Attachment 3, Chapter 1 as "State Variations." In accordance with U.S. Variation 13, operators must comply with all requirements of part 175 of the HMR. These requirements include, but are not limited to, the cargo limits in paragraph (d), which states that: “Except for limited or excepted quantity materials, substances of Class 9, articles of UN0012, UN0014, or UN0055 meeting the requirements of 49 CFR 173.63(b)." Therefore, the quantity limitation established in U.S. Variation 13, paragraph (d)(1) does not apply to the materials described—including "UN0012, Cartridges, small arms, 1.4S." Please note that although not subject to the limitation in U. S. Variation 13, paragraph (d)(1), the packaging limitation in Columns 9A and 9B of the § 172.101 Hazardous Materials Table (HMT) and the maximum gross weight limit of 30 kg per package apply under the provisions in § 173.63(b)(2).

I hope this information is helpful. Please contact us if we can be of further assistance.


T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

172.101, 173.63(b), 173.63(b)(2)

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
173.63 Packaging exceptions