Interpretation Response #98-0393 ([Allantoic Systems] [Mr. Lee R. Zwiefelhofer])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Allantoic Systems
Individual Name: Mr. Lee R. Zwiefelhofer
Location State: MN Country: US
View the Interpretation Document
Response text:
APR 3, 1998
Mr. Lee R. Zwiefelhofer
Allantoic Systems
600 Second Street, NE Mail
Station MNIl-2167
Hopkins, MN 55343
Dear Mr. Zwiefelhofer:
This is in response to your letter regarding the proper method of completing the dangerous goods declaration (i.e., shipping paper) for dangerous goods shipped by aircraft under the International Civil Aviation Organization's (lCAO) Technical Instructions for the Safe Transport of Dangerous Goods by Air and the International Air Transport Associations (IATA) Dangerous Goods Regulations. You asked whether the Packing Group and the Packing Instruction are required to be entered on the declaration of dangerous goods document.
The IATA regulations do not have official standing in the United States. For shipments made by aircraft, the regulations authorized in 49 CFR 171.11 as an alternative to compliance with the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) are the ICAO Technical Instructions. Under ICAO Technical Instructions, "4:4.1.2", the declaration of dangerous goods must contain the basic description, which includes the proper shipping name, hazard class, identification number and packing group.
However, the ICAO Technical Instructions do not indicate a packing group for any explosive and therefore none should be included in the basic description. An example of a basic description for an explosive would be: "Articles, explosive, n.o.s. (*Technical name), 1AE, UN 0471", in that sequence. Additional information must be included on the dangerous goods document as specified in ICAO Technical Instructions, "4:4.1.3", including the "packing instruction" citation. The reference to packing instruction 101 is correct in that this packing instruction provides for the competent authority (in this case, the Research and Special Programs Administration) to authorize the appropriate packaging. For your information, the illv1R do not specify a form for a shipping paper.
I hope this information is helpful. If we can be of further assistance, please contact us.
Sincerely,
Delmer F. Billings
Chief, Standards' Development
Office of Hazardous Materials Standards
171.11