PHMSA letter of interpretation

Stowed Together

Pipeline and Hazardous Materials Safety Administration · Dec 4, 2003 · Reference No. 03-0232

Interprets: 49 CFR § 175.78

This is in response to your request for clarification of the term "stowed together" as it applies to hazardous materials being transported by aircraft in accordance with the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether the wording "may not be stowed together with that class" in "Note 2" in § 175.78(c)(4) is meant to be more restrictive than the wording "may not be placed next to each other or in a position that would allow a dangerous interaction in the event of leakage" as stated in § 175.78(a).

The answer is no. The meaning of the term "stowed together" in "Note 2" in § 175.78(c)(4) does not have a more restrictive meaning than the wording in paragraph (a) which states that packages containing hazardous materials which might react dangerously with one another "may not be placed next to each other or in a position that would allow a dangerous interaction in the event of leakage." The Federal Aviation Administration (FAA) may require additional aircraft loading and stowage requirements as part of its airworthiness standards. You should check with your FAA-assigned Principal Operations Inspector concerning any additional requirements.

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

A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.