Anti-icing additive
Pipeline and Hazardous Materials Safety Administration · Oct 11, 2007 · Reference No. 07-0167
Interprets: 49 CFR § 175.8
Reggie’s quick take
A company asked whether 20 oz cans of flammable aerosol anti-icing additive for aircraft fuel are excepted from the Hazardous Materials Regulations. The agency said yes, but only if the FAA requires the cans to be carried on the aircraft under its airworthiness rules or operating regulations. In that case, § 175.8(a)(2) excepts them from the HMR. If the FAA does not require them, the exception does not apply and the HMR cover the cans.
Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.
This is in response to your letter dated August 20, 2007 in regard to hazardous materials carried on board an aircraft under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if 20 oz cans of flammable aerosols, used as anti-icing additive for your aircraft fuel, are excepted from the HMR.
In accordance with § 175.8(a)(2), hazardous materials required aboard an aircraft in accordance with the applicable airworthiness requirements and operating regulations are excepted from the requirements of the HMR. Therefore, if the aerosols cans of anti-icing additive are required aboard the aircraft by airworthiness requirements or operating regulations provided by the Federal Aviation Administration, these items would not be subject to the HMR. If the FAA does not require the carriage of the aerosol cans, then the exceptions in § 175.8(a)(2) do not apply and the aerosol cans of anti-icing additive are subject to the requirements of the HMR.
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.