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Interpretation Response #99-0247 ([Express One International, Inc.] [Mr. Melvin Starks])

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

Interpretation Response Details

Response Publish Date:

Company Name: Express One International, Inc.

Individual Name: Mr. Melvin Starks

Location State: TX Country: US

View the Interpretation Document

Response text:

February 24, 2000


Mr. Melvin Starks                                       Ref No. 99-0247
Manager, Cargo Loading and
Hazardous Materials
Express One International, Inc.
3890 West Northwest Highway,
Dallas, TX 75220

Dear Mr. Starks:

This is in response to your letter dated August 27, 1999, regarding the definition of a "compartment or bin" under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Your questions are paraphrased and answered as follows:

Is a compartment one pallet position, or is it the entire upper cabin?  The answer to your question is no, a cargo compartment is not one pallet position.  The term, "cargo compartment" as used in the HMR is based on the requirements for cargo compartments of 14 CFR Part 25 Sections 25.855 and 25.857, which were amended by a February 17, 1998 final rule published by the Federal Aviation Administration (63 FR 803 1).  Quantities of dry ice in excess of 441 pounds in any cargo compartment are allowed only when a special written arrangement has been made between the shipper and the operator.

Regarding your question of whether the Office of Hazardous Materials Standards is aware of a formula to calculate the maximum quantity of dry ice for a B-727 aircraft, the answer is no.  The requirement for special written arrangement with an operator for quantities of dry ice in excess of the limitation provided in § 173.217 is based on the range of possible cargo compartment configurations of different aircraft.  The HMR does not specify a formula to be used to determine the maximum amount of dry ice that may be carried on a particular aircraft.

I hope this satisfies your request.



Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.217 Carbon dioxide, solid (dry ice)