USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

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

Interpretation Response #23-0034

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

Interpretation Response Details

Response Publish Date:

Company Name: KTM North America, Inc.

Individual Name: Mr. John Hinz

Location State: CA Country: US

View the Interpretation Document

Response text:

July 25, 2023

Mr. John Hinz
KTM North America, Inc.
38429 Innovation Court
Murrieta, CA  92563

Reference No. 23-0034

Dear Mr. Hinz,

This responds to your February 22, 2023, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to accumulators. Specifically, you are requesting an updated letter of interpretation (LOI) pertaining to the carriage of accumulators in closed-case suspension systems on board passenger-carrying aircraft. You reference LOI No. 15-0220, previously issued to you on February 22, 2016, for the purpose of clarity and confirmation for air carriers of the permitted status of your accumulators. In your most recent letter, you ask whether accumulators meeting the criteria specified in § 173.306(f)(4) and the International Civil Aviation Organization (ICAO) Technical Instructions Special Provision "A114" are subject to the HMR.

The answer is no. Accumulators meeting the criteria specified in § 173.306(f)(4) and ICAO Technical Instructions Special Provision "A114" are not subject to the HMR. Provided that your accumulators continue to meet these criteria, shipments of your accumulators would continue to not be subject to the HMR.

I hope this information is helpful. Please reach out if you have any further questions.


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


Regulation Sections

Section Subject
173.306 Limited quantities of compressed gases