U.S. Department of Transportation Issues Flammable Solid Exemption for RMS Reload Kits
12/21/93 The U.S. Department of Transportation (DOT) has issued a fourth revision of exemption DOT-E-7887 which allows the shipment of most AeroTech RMS reload kits as flammable solids, class 4.1, UN1325. This exemption was granted December 6, 1993. A copy of the exemption is attached.
A significant advantage of the flammable solid designation over the previous 1.4C classification is that reload kits are now shippable by passenger-carrying or cargo-only aircraft. Both Federal Express and UPS one and two-day air shipments are authorized.
A secondary advantage is that the inner packaging requirements formerly imposed are superseded by restricted-quantity gross weight limits. Packages shipped under the exemption may not exceed 25 pounds gross weight when individual propellant grains contain not more than 30 grams of propellant and may not exceed 10 pounds gross weight when individual propellant grains contain not more than 62.5 grams of propellant each.
The document contains a stipulation that packages covered by the exemption may be reoffered for transportation "provided no modifications or changes are made to the packages...". This wording precludes the use of the exemption by a reshipper such as a distributor who must break up larger shipments and repackage smaller quantities for delivery to hobby retailers. To remedy this situation, AeroTech has filed a request for "party to" status on behalf of its reshippers in order that these retailers and distributors may be able to use the exemption. It is expected that the DOT will grant this request in 90 to 120 days. Copies of the exemption will be mailed by the DOT directly to the reshippers granted party status.