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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 #99-0083 ([Polar Air Cargo] [Mr. Paul J. Zinza])

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

Interpretation Response Details

Response Publish Date:

Company Name: Polar Air Cargo

Individual Name: Mr. Paul J. Zinza

Location State: CA Country: US

View the Interpretation Document

Response text:

June 7, 1999


Mr. Paul J. Zinza                               Ref. No. 99-0083

Supervisor, Dangerous Goods

Polar Air Cargo

100 Oceangate, 15th Floor

Long Beach, CA 90802

Dear Mr. Zinza:

This is in response to your letter dated March 23,1999, concerning the proper shipping name of a fuel pump that contains aircraft fuel.  Specifically you ask if rather than utilizing the UN number and shipping description as contained in the Hazardous Materials Regulations (HMR;49 CFR Parts 171 to 180), UN1863 and either the shipping description, Fuel, aviation, turbine engine, or Residue, last contained fuel, aviation, turbine engine, it is more appropriate to utilize the number ID 8001 with either the proper shipping name Dangerous Goods in Apparatus, or Dangerous Goods in Machinery.

It is the opinion of this office that Dangerous Goods in Apparatus is the most appropriate shipping description.  Fuel control units or engine parts containing residual amounts of flammable liquid must be packaged to conform with the packaging requirements of packing instruction 916 of the ICAO Technical Instructions or Part 173 of the HMR.  In addition, the fuel control unit must be capable of withstanding pressure requirements in 49 CFR 173.27(c).

In Docket HM-215C, published March 5, 1999, the Hazardous Materials Regulations were amended to include a listing in the HMT for Dangerous Goods in Machinery or Dangerous Goods in Apparatus, NA 8001, which may be used for domestic transportation. The full text of Docket HM-215C can be obtained from our website, http://hazmatdot.qov.

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.



Thomas G. Allan

Acting Director, Office of Hazardous

Materials Standards


Regulation Sections

Section Subject
173.220 Internal combustion engines, vehicles, machinery containing internal combustion engines, battery-powered equipment or machinery, fuel cell-powered equipment or machinery