Dry Ice

[Hugh Johnson]

Ok Captains, I got a call from someone for a charter to take "three packages of bodily fluids, sealed, refrigerated with dry ice."

My contention is as long as it is packaged and weighted in accordance with sub par (i) of sub para (iii) fully legal with no restrictions.

Anyone run into this scenario and how it would relate to "hazmat"?

Tks.

(13) Carbon dioxide, solid (dry ice) when:
(i) In quantities not exceeding 2.3 kg (5.07 pounds) per package packed as prescribed by §173.217 of this subchapter and used as a refrigerant for the contents of the package. The package must be marked with the name of the contents being cooled, the net weight of the dry ice or an indication that the net weight is 2.3 kg (5.07 pounds) or less, and also marked “Carbon Dioxide, Solid” or “Dry Ice”;

(ii) Intended for use in food and beverage service aboard aircraft; or

(iii) In quantities not exceeding 2 kg (4.4 pounds) per passenger when used to pack perishables in carry-on baggage provided the package permits the release of carbon dioxide gas.

 

[avbug]

Under what regulation subpart are you operating (eg, 91, 135, etc), and what type aircraft are you flying? What provision exists to vent the cabin?

If you are engaging in air commerce and you are able to fit within the guidelines of HMR 175 as you have quoted, then you should have no issue.

I've flown organs and body parts many, many times in various preservatie media without incident, generally under Part 135.

If you are operating under Part 121 or 135, what guidance do you have in your operations manual? Are you allowed to accept and carry hazmat? Have you received the necessary training in packaging, labeling, recognition, and handling? If so, then this is a non-issue. If not, then you shouldn't be carrying the package at all.

 

[suen1843]

Correct me if I am wrong...it's been about 10 years or so since I went to a 3-day hazmat course. Isn't dry ice classified as "ORM" (Other Regulated Material)? Not really hazmat, but not really not hazmat. When I went through the class (taught by FEDEX, the leader in hazmat knowledge) I remember that you did not have to have authority granted for hazmat to carry the 5 or so pounds, but had to have the training required to identify and classify it.

Also, hazmat rules apply to ALL aircraft, not just 135/121. Isn't hazmat authority granted by a different office within the FAA, not the FSDO directly (used to be a part of the security division) ?

A word of caution...carriage of real hazmat without the proper authorization (and 91 operators can get it) is a very serious infraction. The fines can get really big...like in the hundreds of thousands.