Section 107.36 Carriage of hazardous material. (2018)


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Section 107.36  Carriage of hazardous material.

A small unmanned aircraft may not carry hazardous material. For purposes of this section, the term hazardous material is defined in 49 CFR 171.8.

My Commentary on Section 107.36   Carriage of hazardous material.

Pay attention to the FAA’s statement regarding LIPO batteries, “The FAA disagrees with NTSB’s recommendation that the knowledge test include a topic on the characteristics and proper handling of lithium batteries. Under § 107.36, small UAS are prohibited from carriage of hazardous materials. When installed in the aircraft for use as a power source (as opposed to carriage of spares or cargo), lithium batteries are not considered hazardous material.” See 49 CFR 175.8(a)(2).

Advisory Circular 107-2 on Section 107.36  Carriage of hazardous material

None.

FAA’s Discussion on Section 107.36   Carriage of hazardous material from the Final Small Unmanned Aircraft Rule

the FAA notes that the carriage of hazardous materials poses a higher level
of risk than the carriage of other types of property. For example, in the context of external
load operations conducted under 14 CFR part 133, the FAA has found, that “the transport
of hazardous materials, especially forbidden [by PHMSA] hazardous materials, in external
load operations creates a hazard to persons or property in the surface.”48 Because the
carriage of hazardous materials poses a higher level of risk, part 107 will not allow the
carriage of hazardous materials.

The National Transportation Safety Board (NTSB) suggested that the test content
should include awareness of lost-link failsafe procedures, operator development, use of
maintenance and inspection steps and guides, and the characteristics and proper handling of
lithium batteries. The NTSB referred to an April 2006 accident involving a U.S. Customs
and Border Protection unmanned aircraft and encouraged the FAA to review its
recommendations and supporting information stemming from that accident for potential
lessons learned when developing guidance material and specific content for the written
knowledge tests outlined in proposed part 107.

…….

The FAA disagrees with NTSB’s recommendation that the knowledge test include a
topic on the characteristics and proper handling of lithium batteries. Under § 107.36, small
UAS are prohibited from carriage of hazardous materials. When installed in the aircraft for
use as a power source (as opposed to carriage of spares or cargo), lithium batteries are not
considered hazardous material. See 49 CFR 175.8(a)(2).

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