By Andy Altemos, Senior Technical Advisor    January, 2008

How should Dry Ice be properly shipped?

Section 173.217;
letter dated November 26, 2007 to Mr. David Puhl,
Midwest Airlines

A common misconception held by many shippers and carriers is that certain materials for which broad exceptions are provided in the Hazardous Materials Regulations (HMR) are not considered “hazardous materials”. Hazardous materials classed as ORM-D and described by the proper shipping name “Consumer commodity” are a good example. Indeed, once properly packaged and marked, these materials in surface transportation are for all practical purposes handled more or less in the same way as non-hazardous materials. But, they continue to be hazardous materials under the HMR. The improper assumption that they are not hazardous materials can lead to problems - for example, a failure to recognize that employees preparing and offering such materials for transport are subject to the HMR training requirements. These materials are, in fact, “hazardous materials” for which training of employees is required.

This DOT letter is helpful in illustrating and explaining that although a hazardous material may be excepted from most provisions of the HMR, the material nevertheless remains a “hazardous material”. The particular material in question here is dry ice offered for transportation by aircraft. Section 173.217 of the HMR provides requirements for the transport of dry ice by aircraft and vessel - including a number of exceptions. Under § 173.217(f), packages of dry ice are excepted from “all other” requirements of the HMR provided certain requirements in § 173.217 are met. It results from this that the qualifying package is handled and transported by air essentially as if it were a non-hazardous material. However, although not subject to any “other” requirements of the HMR such as labeling, handling, documentation, loading, and pilot notification, the dry ice remains a “hazardous material” subject to the conditions specified in § 173.217(f).

This article, in its entirety,  is archived in HAZMAT Packager & Shipper's HazMat Database, an optional feature to subscribers. Information on obtaining a subscription to HAZMAT Packager & Shipper and its associated features can be found here.