United Airlines Proposed Civil Penalty

8/9/2019 United Airlines Proposed Civil Penalty

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Office of the Chief CounselNew England Region

12 New England Executive ParkBurlington, MA 01803

+

December 30, 2014

CERTIFIED MAILRETURN RECEIPT REQUESTED & FIRST CLASS MAIL

PresidentUnited Airlines, Inc.233 South Wacker Drive, 11th FloorChicago, Illinois 60606

Re: FAA Case Numbers 2013NE700104, 2013GL700253, 2013NM720057, and2013WP700133

NOTICE OF PROPOSED CIVIL PENALTY

FAA CASE # 2013NE700104

Based on a report of investigation, it appears that:

1. Beginning on February 28, 2013, the FAA conducted an inspection of UnitedAirlines, Inc. (hereinafter United) at Logan International Airport in Boston,Massachusetts.

2. The inspection revealed that United accepted shipments of hazardous materials fortransportation by air and transported shipments of hazardous materials by air, as setforth below, without complying with the Hazardous Materials Regulations (HMR)

(Title 49 of the Code of Federal Regulations).

Failure to Provide PIC Accurate Information for United Flight #242:

3. The FAA inspected the Final Dangerous Goods Summary, which was the writteninformation provided to the pilot-in-command before departure of United flight#242, operating from San Francisco International Airport to Logan InternationalAirport on February 28, 2013.

4. The Final Dangerous Goods Summary incorrectly indicated the quantities of thefollowing two (2) shipments of hazardous materials that were transported by air onUnited flight #242:

a. Air Waybill #000 SFO 2677 6293, UN3091, Lithium metal batteriescontained in equipment, hazard class 9, packing group II, 1 Plastic Box x0.01-kg. The quantity was incorrectly stated as 1-LBon the informationprovided to the pilot-in-command.


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b. Air Waybill #000 SFO 2677 6385, UN2079, Diethlenetriamine, hazard class8, packing group II, 1 Fiberboard Box x 0.10-L. The quantity was incorrectlystated as 1-LBon the information provided to the pilot-in-command.

5. Based on the above, United transported a hazardous material in commerce when the

hazardous material was not transported in accordance with applicable requirementsof the HMR (49 C.F.R. parts 171, et seq.).

6. Based on the above, United carried hazardous material onboard an aircraft and failedto provide the pilot-in-command with accurate written information before departureof the aircraft, specifying the net quantity or gross weight, as applicable, for eachpackage.

FAA Record Review of Notification to Pilot-In-Command (NPIC) for United Flights:

7. As part of the above-referenced FAA inspection of United, the FAA reviewed ninety

(90) days of electronic NPIC documents for United flights and discovered thefollowing:

a. Date: 1/2/2013, flight #840, Melbourne International Airport (MEL)Sydney Airport, Australia (SYD)Los Angeles International Airport (LAX),AWB: 016MEL36220844. The shipment was declared as, UN3363,Dangerous Goods in Apparatus, 9, 1 fiberboard x gross weight totals 2-kg.The net weight of the hazardous material was not annotated on the ShippersDeclaration for Dangerous Goods.

Based on the above, United accepted a hazardous material fortransportation aboard an aircraft and failed to ensure the hazardousmaterial was described and certified on a shipping paper inaccordance with the HMR.

b. Date: 1/4/2013, flight #917, Frankfurt Airport (FRA)Washington DullesInternational Airport (IAD), AWB: 016FRA35742523. The shipment wasdeclared as UN3363, Dangerous goods in apparatus, 9, 2 fiberboard boxes x0.40-L and 2 fiberboard boxes x 0.48-L. The NPIC incorrectly indicated theshipment consisted of UN3363, Dangerous goods in apparatus, 9, 4fiberboard boxes x 4-lb net. The net quantity of the hazmat shipped is asfollows: 2 packages x .4-L or .88-lband 2 packages x .48-L or 1.1-lb.

Based on the above, United carried hazardous material onboard anaircraft and failed to provide the pilot-in-command with accuratewritten information before departure of the aircraft, specifying the netquantity or gross weight, as applicable, for each package.

c. Date: 1/4/2013, flight #908, OHare International Airport (ORD) -Amsterdam Airport Schiphol (AMS), AWB: 016ORD10687902. TheShippers Declaration for Dangerous Goods described the shipment as,


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UN1409, Metal Hydrides, Water Reactive, N.O.S. (Barium hydride), 4.3,II. The NPIC incorrectly described the packing group of the shipment asIII.

Based on the above, United carried hazardous material onboard an

aircraft and failed to provide the pilot-in-command with accuratewritten information before departure of the aircraft, specifying theadditional description requirements provided in 172.202 includingthe packing group, in Roman numerals, as designated for thehazardous material in Column (5) of the 172.101 table.

d. Date: 1/5/2013, flight #0828, GUMNarita International Airport (NRT),AWB: 016GUM73303366. The shipment was declared as, UN3166,Engine, Internal combustion, flammable liquid poweredon the ShippersDeclaration for Dangerous Goods. The NPIC incorrectly described theproper shipping name as DHL.

Based on the above, United carried hazardous material onboard anaircraft and failed to provide the pilot-in-command with accuratewritten information before departure of the aircraft, specifying theproper shipping name of the material, as specified in 172.101 of theHMR.

e. Date: 1/6/2013, flight #0869, ORDSan Francisco International Airport(SFO)Hong Kong International Airport (HKG), AWB: 016ORD10446435.The shipment was declared as 25 packages, each containing 1-L of UN2735,Amines, liquid, corrosive, n.o.s., (contains Alphalic Amines), 8, III and 4.62kg G of UN3082, Environmentally hazardous substance, n.o.s., 9, III. TheNPIC incorrectly stated that each of the 25 packages contained 50-lb net(22.68kg)of UN2735, Amines, liquid, corrosive, n.o.s. (contains AlphalicAmines, 8, III) and 275-lb gross weight eachof UN3082, Environmentallyhazardous substance, liquid, nos, 9, III. The net quantity of the Amines,liquid, corrosive, n.o.s., (contains Alphalic Amines) in each package was 1-Lor 2.2-lb. The gross weight of each package that contained UN3082,Environmentally hazardous substance, liquid, nos, 9, III was 4.62 kg or10.16-lb.


f. Date: 1/9/2013, flight #0201, HNLGUM, AWB: 016HNL70527984. TheShippers Declaration for Dangerous Goods indicated the shipment contained2 packages, 3-L each, of UN1219, Isopropanol, 3, II. The NPIC incorrectlystated the shipment consisted of 2 packages, 13-lb (ie 5.9-kg)each, ofUN1219, Isopropanol, 3, II. The net quantity per package was 3-L or 6.6-lb.


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Based on the above, United carried hazardous material onboard anaircraft and failed to provide the pilot-in-command with writteninformation before departure of the aircraft, specifying the netquantity or gross weight, as applicable, for each package.

g. Date: 1/9/2013, flight #0916, IADFRA, AWB: 016IAD10632204. Theshipment was declared as:

UN3316, Chemical kit, 9, II, 1 box x 0.380-kg;UN3316, Chemical kit, 9, II, 1 box x 0.228-kg;UN3316, Chemical kit, 9, II, 1 box x 0 .456-kg;UN3316, Chemical kit, 9, II, 1 box x 0.15-kg;UN1760, Corrosive liquid, n.o.s., (Guanidlnethlocyanatephenol), 8, II, 3fiberboard boxes x 1-L; andUN1760, Corrosive liquid, n.o.s., (Guanidlnethlocyanatephenol), 8, II, 1

fiberboard box x 0.2-L, overpack used.

The NPIC incorrectly indicated the shipment consisted of 1 packageat 3-lbnet of UN3316, Chemical kit, 9, II, and 1 packagex 7-lb net of UN1760,Corrosive liquid, n.o.s., (Guanidlnethlocyanatephenol), 8, II, overpackused. The NPIC failed to indicate there were 4 packagesof UN3316,Chemical kits and 4 packagesof UN1760, Corrosive liquid, n.o.s.,(Guanidlnethlocyanatephenol). The net weight of the chemical kits are .38-kg or .84-lb; .228-kg or .5-lb; .456-kg or 1-lb, and .15-kg or .33-lb.Therefore, the net quantities of the corrosive liquid shipped are 1-L or2.2-lb.and.2-L or.44-lb.

Based on the above, United carried hazardous material onboard anaircraft and failed to provide the pilot-in-command with accuratewritten information before departure of the aircraft, specifying thetotal number of packages.


h. Date: 1/9/2013, flight #200, GUMHNL, AWB: 016YAP71313664. Theshipment was declared as UN2814, Infectious substance, affecting humans(mycobacterium tuberculosis), 6.2, two fiberboard boxes x 35-ml each,overpack used. The NPIC incorrectly listed mycobacterium tuberculosisas the PSN and incorrectly indicated the net weight of the shipment as 17-lbper package. The net quantity per package was 35-ml or .77-lb.

Based on the above, United carried hazardous material onboard anaircraft and failed to provide the pilot-in-command with accurate


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written information before departure of the aircraft, specifying theproper shipping name of the material, as specified in 172.101 of theHMR.

Based on the above, United carried hazardous material onboard an

aircraft and failed to provide the pilot-in-command with accurateinformation before departure of the aircraft, specifying the netquantity or gross weight, as applicable, for each package.

i. Date: 1/11/2013, flight #0895, ORD-HKG, AWB: 016ORD54658590. Theshipment was declared as UN2735, Amines, liquid, corrosive, n.o.s.(aliphatic amines), 8, III, 6 fiberboard boxes x 2.72-L each. The NPICincorrectly indicated the shipment consisted of 6 boxes at 36-lb eachofUN2735, Amines, liquid, corrosive, n.o.s. (aliphatic amines), 8, III. The netquantity per package was 2.72-L or 6-lb.


j. Date: 1/11/2013, flight #718, Benito Juarez International Airport (MEX)SFO, AWB: 016MEX26760182. The NPIC incorrectly indicated theshipment consisted of UN1072, Oxygen, compressed, 2.2/5.1, 1 package x44-lb gross weight. The net quantity should have been entered on the NPIC,not the gross weight.


k. Date: 1/12/2013, flight # 0803, IAD-NRT, AWB: 016IAD10632344. Theshipment was declared as UN3316, Chemical kit, 9, II, 1 box x 0.509-kg andUN1760, Corrosive liquid, n.o.s., (Guanidlnethlocyanatephenol), 8, II, 1fiberboard box x 0.25-L, 6 fiberboard boxes x 0.4-L, and 2 fiberboard boxesx 1.0-L, overpack used. The NPIC incorrectly indicated the Chemical kit was1.3-lb netand the Corrosive liquid, n.o.s. consisted of 1 package x 11-lb net.The net quantity of the Chemical kit was 1.12-lb. There were 9 packagesofCorrosive liquid, n.o.s. The net quantity of each Corrosive liquid, n.o.s.shipment was as follows: 1 package x .25-L or .55-lb, 6 packages x .4-L or.88-lb, 2 packages x 1-L or 2.2-lb.



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l. Date: 1/12/2013, flight #972, ORD-BRU, AWB: 016ORD54377551. Theshipment was declared as UN3363, Dangerous goods in apparatus, 9, 2fiberboard boxes x 0.72-kg overpack used. The NPIC indicated the shipmentconsisted of 2 boxes at 8-lb eachof UN3363, Dangerous goods in apparatus,9, overpack used. The net quantity of each package was 0.72-kg or 1.58-lb.


m. Date: 1/13/2013, flight #972, ORD- Brussels Airport (BRU), AWB:016ORD54376932. The shipment was declared as UN3363, Dangerousgoods in apparatus, 9, 4 fiberboard boxes x 1-kg, overpack used. The NPICincorrectly indicated the shipment consisted of 1-box at 9-lbnet of UN3363,Dangerous goods in apparatus, 9, with an overpack. The net quantity of eachpackage was 2.2-lb.



n. Date: 1/16/2013, flight #0987, Denver International Airport (DEN)ORD,and flight #942, ORDCharles De Gaulle (CDG), AWB:016DEN10416711. The shipment was declared as UN1805, Phosphoric acid,solution, 8, III, 8 fiberboard boxes x 1.0-L. The NPIC incorrectly indicatedthe shipment consisted of 8 packages x 18-lb netof UN1805, Phosphoricacid, solution, 8, III. The net quantity per package is 1-L or 2.2-lb.



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o. Date: 1/17/2013, flight #0803, IAD-NRT, AWB: 016IAD10632694. TheShippers Declaration for Dangerous Goods indicated the shipment consisted

of:

UN1760, Corrosive liquids. n.o.s. (Guanidlnethlocyanale-phenol) 8, II, 1

fiberboard box x 0.200-L;UN1760, Corrosive liquids. n.o.s. (Guanidlnethlocyanale-phenol), 2fiberboard box x 0.800-L;UN1760, Corrosive liquids. n.o.s. (Guanidlnethlocyanale-phenol), 8fiberboard boxes x 0.400-L;UN3316, Chemical kit, 9, II, 1 fiberboard box x 0.206-kg; andUN3316, Chemical kit, 9, II, 1 fiberboard box x 0.112-kg.

The NPIC incorrectly indicated the shipment consisted of 1 package x 9-lbnetof UN1760, Corrosive liquid, n.o.s., and 1 package at 2-lb netofUN3316, Chemical kit, 9. The NPIC failed to state the correct number of

packages of UN1760 Corrosive liquid, n.o.s., or UN3316, Chemical kit. TheNPIC failed to indicate the packing group of UN3316, Chemical kits, or thecorrect net quantities of UN3316, Chemical kit. The net quantities for theshipments of UN3316, Chemical kit are: .206 kg or .45- lb, and .112-kg or.25-lb.

Based on the above, United carried hazardous material onboard anaircraft and failed to provide the pilot-in-command with accuratewritten information before departure of the aircraft, specifying theadditional description requirements provided in 172.202 includingthe packing group, in Roman numerals, as designated for thehazardous material in Column (5) of the 172.101 table.



p. Date: 1/19/2013, flight #0803, IADNRT, AWB: 016IAD10632790. Theshipment was declared as:

UN1760, Corrosive liquid, n.o.s., (Guanidlnethlocyanatephenol), 8, II, 2fiberboard boxes x 1-L, overpack used;UN1760, Corrosive liquid, n.o.s., (Guanidlnethlocyanatephenol), 8, II, 12fiberboard boxes x 0.4-L;


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UN1760, Corrosive liquid, n.o.s., (Guanidlnethlocyanatephenol), 8, II, 1fiberboard box x 0.3-L;UN1760, Corrosive liquid, n.o.s., (Guanidlnethlocyanatephenol), 8, II, 1

fiberboard box x 1.0L;UN1760, Corrosive liquid, n.o.s., (Guanidlnethlocyanatephenol), 8, II, 1

fiberboard box x 0.8-L, overpack used; andUN3316, Chemical kit, 9, II, 1 fiberboard box x .073-kg, 1 fiberboard box x.0352-kg.

The NPIC failed to indicate the correct number of packages (17) for theshipments of UN1760 Corrosive liquid, n.o.s., the correct number ofpackages (2) of UN3316, Chemical kits, or the assigned packing group forthe UN3316, Chemical kits. The NPIC also failed to indicate the correct netquantity per package for the hazardous materials. The net quantities for theshipments of UN3316 Chemical kits were 0.023kg or 0.05-lb and 0.0352or 0.08- lb. The net quantities per package for the shipments of UN1760

Corrosive liquid were 1- L or 2.2-lb, 0.4-L or 0.88-lb, 0.3-L or 2.2-lb, 0.8-Lor 1.76-lb.




q. Date: 1/23/2013, flight #0922, IADLondon Heathrow International Airport(LHR), AWB: 016DEN10416755. The shipment was declared as UN1805,Phosphoric acid, solution, 8, III, 41 fiberboard boxes x 1.0-L. The NPICincorrectly indicated the shipment consisted of 20 boxes x 44-lbnet each ofUN1805, Phosphoric acid, solution, 8, III and 21 boxes x 47-lbnet each ofUN1805, Phosphoric acid, solution, 8, III. The net quantity per package ofthe shipment of UN1805, Phosphoric acid, solution was 1-L or 2.2-lb.

Based on the above, United carried hazardous material onboard anaircraft and failed to provide the pilot-in-command with written


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information before departure of the aircraft, specifying the netquantity or gross weight, as applicable, for each package.

r. Date: 1/25/2013, flight #0944, ORDFRA, AWB: 016DEN10416770. Theshipment was declared as UN1805, Phosphoric acid, solution, 8, III, 8

fiberboard boxes x 1.0- L. The NPIC incorrectly indicated the shipmentconsisted of 8 boxes x 16-lb gross weight eachof UN1805, Phosphoric acid,solution, 8, III. The net quantity per package was 1.0-L / 2.2-lb.


s. Date: 1/25/2013, flight #0432, DENORD and flight #0942, ORDCDG,AWB: 016DEN10416792. The shipment was declared as UN1805,

Phosphoric acid, solution, 8, III, 13 fiberboard boxes x 1.0-L. The NPICincorrectly indicated the shipment consisted of 13 boxes x 26-lb net eachofUN1805, Phosphoric acid, solution, 8, III. The net quantity per package was

1.0-L / 2.2-lb.


t. Date: 1/25/2013, flight #0967, Leonardo da Vinci-Fiumicino Airport (FCO)IAD, AWB: 016FCO28646030. The shipment was declared as UN3089,Metal powder, flammable n.o.s., 4.1, II. The NPIC failed to indicate thepacking group of the hazardous material.


u. Date: 1/25/13, flight #870, SYDSFO. AWB: 016SYD36251666.Description: The NPIC indicated the shipment consisted of UN3363,Dangerous goods in apparatus, 9, 1 package x 28-lb gross weight. The grossweight, not the net quantity, is entered on the NPIC.



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v. Date: 1/26/2013, flight #549, Cleveland Hopkins International Airport (CLE)IAH, AWB: 000CLE71504160. The NPIC indicated the shipment consistedof UN3363, Dangerous goods in machinery, 9, 1 package x 52-lb grossweight. The gross weight, not the net quantity, is entered on the NPIC.


w. Date: 1/29/2013, flight #432, DENORD and flight #940, ORDCDG,AWB: 016DEN10416814. The shipment was declared, in part, as UN1805,Phosphoric acid, solution, 8, III, 9 fiberboard boxes x 1.0-L. The NPICindicated the shipment consisted of 9 boxes x 20-lb net eachof UN1805,Phosphoric acid, solution, 8, III. The net quantity weight per package was

1.0-L / 2.2-lb.


x. Date: 1/29/2013, flight #916, IADFRA, AWB: 016IAD10633302. Theshipment was declared as:

UN1824, Sodium hydroxide solution, 8, II, 24 fiberboard boxes x 0.954-L;UN1824, Sodium hydroxide solution, 8, II, 1 fiberboard box x 0.795-L; andUN1824, Sodium hydroxide solution, 8, II, 2 fiberboard boxes x 0.318-Lwith an overpack.

The NPIC incorrectly indicated the shipment consisted of 27 packages x 54-lb net eachof UN1824, Sodium hydroxide solution, 8, II. The net quantityof the shipments was as follows: 24 packages x 0.954-L or 2.1-lb; 1 packagex 0.795-L or 1.75-lb., and 2 packages x 0.318-L or 0.7-lb.

i. Based on the above, United carried hazardous material onboard anaircraft and failed to provide the pilot-in-command with accuratewritten information before departure of the aircraft, specifying the netquantity or gross weight, as applicable, for each package.

y. Date: 1/31/13 and 2/5/13, flight #846, Ministro Pistarini Airport (EZE)Newark International Airport (EWR), and flight #982, IADKuwaitInternational Airport (KWI), AWB: 016EZE65713432, 016EZE65713443,and 016EZE65713454.The shipments were declared as UN3166, Vehicle,flammable liquid powered. The NPICs for the shipments incorrectlyindicated the proper shipping name as One Motorcycle.


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Based on the above, United carried hazardous material onboard anaircraft and failed to provide the pilot-in-command with writteninformation before departure of the aircraft, specifying the propershipping name, hazard class and identification number of the material,

as specified in 172.101 of the HMR.

z. Date: 2/2/13, flight # 0377, SFOORD, AWB: 000SFO26767355. Theshipment was declared as UN1814, Potassium hydroxide solution, 8, II, 5boxes x 0.95-L. The NPIC incorrectly indicated the shipment consisted ofUN1814, Potassium hydroxide solution, 8, II, 5 boxes x 10-lb-net. The netquantity per package was 0.95-L or 2.09-lb.

Based on the above, United carried hazardous material onboard anaircraft and failed to provide the pilot-in-command with accuratewritten information before departure of the aircraft, specifying the net

quantity or gross weight, as applicable, for each package.

aa.Date: 2/2/13, flight #201, HNLGUM, AWB: 016HNL70601495. Theshipment was declared as UN1791, Hypochlorite solution, 8, III, 2 fiberboardboxes x 4.0-L. The NPIC incorrectly indicated the shipment consisted of 2packages at 18-lb net eachof UN1791, Hypochlorite solution, 8, III. The netquantity of each package was 4-L or 8.8-lb.


bb.Date: 2/3/13, flight #803, IADNRT, AWB: 016IAD10633486. Theshipment was declared as:

UN3316, Chemical kit, 9, II, 1 fiberboard box x 0.322-kg;UN3316, Chemical kit, 9, II, 1 fiberboard box x 3.170-kg;UN3316, Chemical kit, 9, II, 1 fiberboard box x 1.166-kg, overpack used;UN1760, Corrosive liquid, n.o.s., (Guanidlnethlocyanatephenol), 8, II, 10fiberboard boxes x 0.4-L; andUN1760, Corrosive liquid, n.o.s., (Guanidlnethlocyanatephenol), 8, II, 2fiberboard boxes x 1-L, and 1 fiberboard box 0.6-L.

The NPIC incorrectly indicated the shipment consisted of 1 package at 3-lbnet of UN3316, Chemical kit, 9, II and 1 package x 15-lb netof UN1760,Corrosive liquid, n.o.s., (Guanidlnethlocyanatephenol), 8, II. The NPICfails to indicate the correct number of packages of UN3316, Chemical kits (3)and the correct number of packages of UN1760, Corrosive liquid (13). Inaddition, the net weight(s) of the packages of Chemical kits are0.322-kg or0.71-lb, 3.17-kg or 7-lb, and 1.166-kg or 2.57-lb. The net quantities of the


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packages of UN1760, Corrosive liquid, n.o.s., (Guanidlnethlocyanatephenol) are 0.4-L or 0.88-lb., 1-L or 2.2-lb, and .6-L or 1.32-lb.


information before departure of the aircraft, specifying the totalnumber of packages.


cc.Date: 2/5/13, flight #0932, IADFRA, AWB: 016IAD10633696. Theshipment was declared as:

UN1824, Sodium hydroxide solution, 8, II, 3 fiberboard boxes x 0.795-L; andUN1824, Sodium hydroxide solution, 8, II, 20 fiberboard boxes x 0.954-L.

The NPIC incorrectly indicated the shipment consisted of UN1824, Sodiumhydroxide solution, 8, II, 23 packages x 22-lb net each. The NPIC does notindicate the correct net quantity per package. The net quantities per package

were 0.795-L or 1.75-lb and 0 .954-L or 2.1-lb.


dd.Date: 2/9/13, flight #0581, DENIAD, AWB: 016DEN10416906. Theshipment was declared as:

UN1805, Phosphoric acid, solution, 8, III, 5 fiberboard boxes x 1-L; andUN1805, Phosphoric acid, solution, 8, III, 1 fiberboard box x 0.6-L.

The NPIC incorrectly indicated the shipment consisted of UN1805,Phosphoric acid, solution, 8, III, 21 packages x 39-lb gross weight. The netquantities for the shipments are as follows: 5 packages x 1-L or 2.2-lb and 1

package x .6-L or 1.32-lb.




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written information before departure of the aircraft, specifying the netquantity or gross weight, as applicable, for each package.

ee.Date: 2/12/2013, flight #861, IADGRO, AWB: 016IAD10634105. Theshipment was declared, in part, as UN1824, Sodium hydroxide solution, 8, II,

5 fiberboard boxes x 0.954-L and 1 fiberboard box x 0.589-L. The NPICincorrectly indicated the shipment consisted of 6 packages x 12-lb net. Thenet weight is5 packages x 0.954-L or 2.1-lb and 1 x 0.589-L or 1.3-lb.


ff. Date: 2/12/2013, flight #924, IADLHR, AWB: 016IAD0834025.Theshipment was declared as UN0044, Primers, Cap type, 1.4S, 5 fiberboard

boxes x 1.71-kg (.488 kg NEQ), Overpack used x 2. The NPIC incorrectlyindicated the shipment consisted of 2 boxes x 38-lb netof UN0044, Primers,Cap type, 1.4S overpack used. The NPIC should have stated there were 10packages.


gg.Date: 2/16/2013, flight#803, IADNRT, AWB: 016IAD10634396. Theshipment was declared as:

UN3316, Chemical kit, 9, II, 1 fiberboard box x 0.002 kg;UN3316, Chemical kit, 9, II, 1 fiberboard box x 0.148 kg, overpack used; and14 packages of UN1790, Corrosive liquid, n.o.s., (Guanidlnethlocyanatephenol), 8, II.

The NPIC incorrectly indicated the shipment consisted of 1 package x 2-lbnet of UN3316, Chemical kit, 9, II and 1 package x 15-lb-netof UN1790,Corrosive liquid, n.o.s., (Guanidlnethlocyanatephenol), 8, II.


hh.Date: 2/13/13, flight #382, ORDIAD, and flight #0861, IADGRU,AWB: 016ORD10800370. The shipment was declared as UN1247, Methylmethacrylate monomer, stabilized, 3, II, 8 fiberboard boxes x 1-L. The NPIC


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incorrectly indicated the net weight per shipment as 18-lb (8.18-kg).The netquantity per package was 1-L or 2.2-lb.



ii. Date: 2/19/13, flight #483, SFOORD, AWB: 000SFO26772432. Theshipment was declared, in part, as UN1814, Potassium hydroxide solution, 8,II, 2 fiberboard boxes x 0.95-L. The NPIC incorrectly indicated theshipment consisted of UN1814, Potassium hydroxide solution, 8, II, 1package x 4-lb net.


written information before departure of the aircraft, specifying thetotal number of packages.

jj. Date: 2/19/2013, flight #861, IADGRU, AWB: 016IAD10634540. Theshipment was declared as UN1824, Sodium hydroxide solution, 8, II, 22boxes x 0.954-L and 1 box x 0.583-L. The NPIC incorrectly indicated theshipment consisted of UN1824, Sodium hydroxide solution, 8, II, 23 boxes x49-lb net. The net quantities in the shipments were 0.954-L or 2.1-lb. and0.583-L or 1.28-lb.


kk.Date: 2/19/2013, flight #932, IADFRA, AWB: 016IAD10634562. Theshipment was declared as UN1824, Sodium hydroxide solution, 8, II, 20boxes x 0.954-L and 1 box x 0.477-L. The NPIC incorrectly indicated theshipment consisted ofUN1824, Sodium hydroxide solution, 8, II, 21 boxes x45-lb net. The net quantities in the shipments were 0.954-L or 2.1-lb. and0.583-L or 1.28-lb.


ll. Date: 2/20/2013, flight #584, LAXIAD and flight # IAD - Rio de JaneiroInternational Airport (GIG), AWB: 016LAX54737001. The shipment wasdeclared as UN1866, Resin solution, 3, III, 1 fiberboard box x 17.2-L and 1


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fiberboard box x 20-L. The NPIC fails to indicate the packing group of theUN1866, Resin solution.


written information before departure of the aircraft, specifying theadditional description requirements provided in 172.202 includingthe packing group, in Roman numerals, as designated for thehazardous material in Column (5) of the 172.101 table.

mm. Date: 2/21/2013, flight #0903, Munich Airport (MUC)IAD, AWB:016STR35742630. The shipment was declared as UN3363, Dangerous goodsin apparatus, 9, 44 fiberboard boxes x 0.20-L. The NPIC incorrectlyindicated the shipment consisted of UN3363, Dangerous goods in apparatus,9, 30 packages x 14-lb net, 10 packages x 5-lb net.


nn.Date: 2/23/2013, flight #532, DENORD and flight #0928, ORDLHR,AWB: 016DEN10416980. The shipment was declared as UN1803,Phosphoric acid, 8, III, 14 fiberboard boxes x 1-L. The NPIC for both flightsincorrectly indicated the shipment consisted of UN1803, Phosphoric acid, 8,III, 14 packages x 28-lb gross. The net quantity per package was 1.0-L or 2.2-lb.


oo.Date: 2/23/2013, flight #942, ORDCDG, AWB: 016ORD57067533. Theshipment was declared as UN1170, Ethanol solution, 3, III, 7 fiberboardboxes x 3.45-L. The NPIC incorrectly indicated the shipment consisted ofUN1170, Ethanol solution, 3, III, 7 fiberboard boxes x 54-lb net. The netquantity in each package was 3.54-L or 7.79 lb.


pp.Date: 2/24/2013, flight 0851 ORD - Beijing Capital International Airport(PEK), AWB: 016ORD10748975. The shipment was declared as UN1760,Corrosive liquid, n.o.s., (modified amine mixture), 8, III, 9 fiberboard boxesx 0.94-L. The NPIC incorrectly indicated the shipment consisted of UN1760,


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Corrosive liquid, n.o.s., (modified amine mixture), 8, III, 9 packages x 19-lb-net. The net quantity in each package was 0.94-L/kg or 2.07-lb.



qq.Date: 2/24/2013, flight #330, ORDEWR, flight #685, EWRSFO, flight#869, SFOHKG, AWB: 016ORD54663663. The shipment was declared asUN2735, Amines, liquid, corrosive, n.o.s. (aliphatic amines), 8, III, 8fiberboard boxes, each containing 2.72-L. The net quantity of each packagewas 2.72-L or 5.98-lb. The NPIC for flight 330 incorrectly indicated theshipment consisted of UN2735, Amines, liquid, corrosive, n.o.s., (aliphaticamines), 8, III, 9 packages x 54-lb net each. The NPIC for flight 685incorrectly indicated the shipment consisted of UN2735, Amines, liquid,

corrosive, n.o.s., (aliphatic amines), 8, III, 3 packages at 18-lb net each.The NPIC for flight 869 incorrectly indicated the shipment consisted ofUN2735, Amines, liquid, corrosive, n.o.s., (aliphatic amines), 8, III, 3 x 22-lbnet each.



rr. Date: 2/25/2013, flight #0845, ORDGRU, AWB: 016ORD10258555.Theshipment was declared as follows:

UN1210, Printing ink, 3, III, 1 fiberboard box x 8.50-L;UN1210, Printing ink, 3, III, 1 fiberboard box x 7.72-L; andUN1210, Printing ink, 3, III, 1 fiberboard box x 2.30-L.

The NPIC incorrectly indicated the shipment consisted of UN1210, Printingink, 3, III, 3 packages x 41-lb net each. The net quantities contained withinthe packages were 8.5-L or 18.7- lb, 7.72-L or 17- lb, and 2.3-L or 5.1-lb .



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ss. Date: 3/2/2013, flight #971, ORDSFO, AWB: 000ORD2677041. Theshipment was declared as:

UN3363, Dangerous goods in apparatus, 9, 1 fiberboard box x 0.50-L; andUN3363, Dangerous goods in apparatus, 9, 2 plastic boxes x 0.50-L.

The NPIC incorrectly indicated the shipment consisted of UN3363,Dangerous goods in apparatus, 9, 3 packages x 6-lb each. The net quantityper package was 1.1-lb.


FAA Case # 2013GL700253

8. Beginning on August 30, 2013, the FAA conducted an inspection of United atOHare International Airport in Chicago, Illinois.

9. The inspection revealed that United accepted a shipment of hazardous materials fortransportation by air and transported the shipment of hazardous materials by air, asset forth below, without complying with the HMR.

Failure to Provide PIC Accurate Information:

10.The FAA inspected the Final Dangerous Goods Summary, which was the writteninformation provided to the pilot-in-command before departure of United flight#944, operating from OHare International Airport to Frankfurt International Airport,

Frankfurt, Germany on August 30, 2013.

a. The Final Dangerous Goods Summary failed to indicate that the followinghazardous materials were being carried under the terms of a special permit.

Air Waybill #016-1161-0465, UN1072, Oxygen, compressed, hazard class2.2 (5.1), 1 Plastic Box x 3.545-kg, DOT-SP 8162.

Based on the above, United carried hazardous material onboard anaircraft and failed to provide the pilot-in-command with accuratewritten information before departure of the aircraft, specifying anindication, when applicable, that a hazardous material is being carriedunder the terms of a special permit.


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FAA Case # 2013NM720057

11.Beginning on June 4, 2013, the FAA conducted an inspection of United at DenverInternational Airport in Denver, Colorado.

12.The inspection revealed that United accepted shipments of hazardous materials fortransportation by air and transported shipments of hazardous materials by air, as setforth below, without complying with the HMR.


13.As part of the above-referenced FAA inspection of United, the FAA reviewed ninety(90) days of electronic NPIC documents for United flights and discovered thefollowing:

a. Date: 3/15/2013, flight #0737, DENSFO. AWB: 016DEN54393566. The

shipment was declared as, UN1760, Corrosive Liquid,n.o.s.

on theShippers Declaration for Dangerous Goods. The NPIC incorrectly describedthe proper shipping name as Corrosive Liquid.


b. Date: 3/15/2013, flight #0763, DENCalgary International Airport (YYC).AWB: 016DEN54393570. The shipment was declared as, UN1805,Phosphoric Acid, Solution on the Shippers Declaration for DangerousGoods. The NPIC incorrectly described the proper shipping name asPhosphoric Acid.


c. Date: 4/30/2013, flight #1126, Denver International Airport (DEN)NewarkLiberty International Airport (EWR), AWB: 016DEN72054032. The locationof the package aboard the aircraft was not specified on the NPIC and the dateon the NPIC is listed as 30 instead of 4/30/13.

Based on the above, United carried hazardous material onboard anaircraft and failed to provide the pilot-in-command with accurate ewritten information before departure of the aircraft, specifying thelocation of the packages aboard the aircraft.


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Based on the above, United carried hazardous material onboard anaircraft and failed to provide the pilot-in-command with accuratewritten information before departure of the aircraft, specifying thedate of the flight.

d. Date: 5/3/2013, flight #1149, DENIAD, AWB: 016DEN11030401. Thedate on the NPIC is listed as 3 instead of 5/3/13.


e. Date: 5/5/2013, flight #1743, DEN - McCarran International Airport (LAS),AWB: 016DEN84039966. The location of the package aboard the aircraft

was not specified on the NPIC.

Based on the above, United carried hazardous material onboard anaircraft and failed to provide the pilot-in-command with accuratewritten information before departure of the aircraft, specifying thelocation of the packages aboard the aircraft.

f. Date: 5/7/2013, flight #1167, DENLAS, AWB: 016DEN84040191. Thelocation of the package aboard the aircraft was not specified on the NPIC.


g. Date: 5/10/2013, flight #1137, DENLAX, AWB: 016DEN89773940. TheUN identification number of the hazardous material (Dry Ice) was incorrectlyspecified on the NPIC as 1945 instead of 1845.

Based on the above, United carried hazardous material onboard anaircraft and failed to provide the pilot-in-command with accuratewritten information before departure of the aircraft, specifying theidentification number of the material, as specified in 172.101 of theHMR.

h. Date: 5/12/2013, flight #1277, DENORD, AWB: 000DEN26799894. Thelocation of the package aboard the aircraft was not specified on the NPIC.



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written information before departure of the aircraft, specifying thelocation of the packages aboard the aircraft.

i. Date: 5/13/2013, flight #11611, DEN - MinneapolisSaint Paul InternationalAirport (MSP), AWB: 016DEN84040541. The location of the package

aboard the aircraft was not specified on the NPIC.

Based on the above, United carried hazardous material onboard anaircraft and failed to provide the pilot-in-command with writteninformation before departure of the aircraft, specifying the location ofthe packages aboard the aircraft.

j. Date: Date: 5/13/2013, flight #1273, DEN - Spokane International Airport(GEG), AWB: 016DEN84040482. The location of the package aboard theaircraft was not specified on the NPIC.


k. Date: 5/14/2013, flight #1177, DENPortland International Airport (PDX),AWB: 016DEN84040644. The location of the package aboard the aircraftwas not specified on the NPIC.


l. Date: 5/16/2013, flight #1137, DENMexico City International Airport(MEX), AWB: 016DEN54404696. The shipment was declared as UN170,Corrosive liquid, n.o.s., (15% Ammonium Persulphate), 8, III, OneFiberboard Box 1.20 Liters, UN170, Corrosive Liquid, n.o.s., (15%Ammonium Persulphate), 8, III, 0.20 Liters, UN1805, Phosphoric Acid,Solution,8, III, 1.50 Liters, ALL PACKED IN ONE FIBERBOARDBOX. The NPIC incorrectly indicated the shipment consisted of 2 packagesof UN1760 and 1 packageof UN1805. Additionally, the NPIC incorrectlydescribed the proper shipping name as Phosphoric Acid.




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information before departure of the aircraft, specifying the propershipping name of the material, as specified in 172.101 of the HMR.

FAA Case # 2013WP700133

14.Beginning on April 30, 2013, the FAA conducted an inspection of United at SanFrancisco International Airport in San Francisco, California.

15.The inspection revealed that United accepted shipments of hazardous materials fortransportation by air and transported shipments of hazardous materials by air, as setforth below, without complying with the HMR.


16.As part of the above-referenced FAA inspection of United, the FAA reviewed ninety(90) days of electronic NPIC documents for United flights and discovered the

following:

a. Date: 2/1/2013, flight #105, SFOBOS, AWB: 016SFO26766950. Thelocation of the package aboard the aircraft was not specified on the NPIC.

Based on the above, United carried hazardous material onboard an aircraftand failed to provide the pilot-in-command with accurate written informationbefore departure of the aircraft, specifying the location of the packagesaboard the aircraft.

b. Date: 2/5/2013, flight #1154, SFOSEA, AWB: 016SFO72960705. Thetotal quantity of UN1845, Carbon dioxide, solid (dry ice) in each hold aboardthe aircraft was not specified on the NPIC.

Based on the above, United carried UN1845, Carbon dioxide, solid (dry ice)onboard an aircraft and failed to provide the pilot-in-command with accuratewritten information before departure of the aircraft, specifying the totalquantity in each hold aboard the aircraft.

c. Date: 2/7/2013, flight #1219, SFOORD, AWB: 016SFO26769153. Thelocation of the package aboard the aircraft was not specified on the NPIC.The date on the NPIC is listed as 7 instead of 2/7/13.


Based on the above, United carried hazardous material onboard an aircraftand failed to provide the pilot-in-command with accurate written informationbefore departure of the aircraft, specifying the date of the flight.


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d. Date: 2/8/2013, flight #1584, SFOLAX, AWB: 016SFO26769352. Thelocation of the package aboard the aircraft was not specified on the NPIC.

Based on the above, United carried hazardous material onboard an aircraft

and failed to provide the pilot-in-command with accurate written informationbefore departure of the aircraft, specifying the location of the packagesaboard the aircraft.

e. Date: 2/15/2013, flight #73, SFO-HNL, AWB: 016SFO74669840. Page 1 of2 of the shipping paper required by 175.30(a)(2) was not retained by United.

Based on the above, United, the aircraft operator, failed to retain a copy ofthe shipping paper required by 175.30(a)(2) or an electronic image thereof,that is accessible at or through its principal place of business, making theshipping paper available, upon request, to an authorized official of a federal,

state, or local government agency at reasonable times and locations.

f. Date: 2/18/2013, flight#73, SFOHNL, AWB: 016SFO00947483. The totalquantity of UN1845, Carbon dioxide, solid (dry ice) in each hold aboard theaircraft was not specified on the NPIC.


g. Date: 2/23/2013, flight #1139, SFOIAD, AWB: 016SFO26774204. Thelocation of the package aboard the aircraft was not specified on the NPIC.Confirmation that no damaged or leaking packages have been loaded on theaircraft was not specified on the NPIC. The date on the NPIC is listed as 23instead of 2/23/13.


Based on the above, United carried hazardous material onboard an aircraftand failed to provide the pilot-in-command with accurate written informationbefore departure of the aircraft, specifying confirmation that no damaged orleaking packages have been loaded on the aircraft.



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h. Date: 2/28/2013, flight #1570, SFOPDX, AWB: 016SFO26776536. Thelocation of the package aboard the aircraft was not specified on the NPIC.

Based on the above, United carried hazardous material onboard an aircraftand failed to provide the pilot-in-command with accurate written information

before departure of the aircraft, specifying the location of the packagesaboard the aircraft.

i. Date: 3/4/2013, flight #1483, SFOORD, AWB: 016SFO26777505. Thelocation of the package aboard the aircraft was not specified on the NPIC.


j. Date: 3/13/2013, flight #201, SFOHNL, AWB: 016SFO00959976. Thetotal quantity of UN1845, Carbon dioxide, solid (dry ice) in each hold aboardthe aircraft was not specified on the NPIC.


k. Date: 3/14/2013, flight #331, SFOIAD, AWB: 016BNE36106965. Thetotal quantity of UN1845, Carbon dioxide, solid (dry ice) in each hold aboardthe aircraft was not specified on the NPIC.


l. Date: 3/14/2013, flight #331, SFOIAD, AWB: 016BNE36260792. Thetotal quantity of UN1845, Carbon dioxide, solid (dry ice) in each hold aboardthe aircraft was not specified on the NPIC.


m. Date: 3/15/2013, flight #331, SFOIAD, AWB: 016BNE36106943. Thetotal quantity of UN1845, Carbon dioxide, solid (dry ice) in each hold aboardthe aircraft was not specified on the NPIC.


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n. Date: 3/20/2013, flight #417, SFOORD, AWB: 016BNE36163934. TheShippers Declaration for Dangerous Goods described the shipment as,UN1197, Extracts, flavouring, liquid, 3, II. The NPIC incorrectlydescribed the packing group of the shipment as III.

Based on the above, United carried hazardous material onboard an aircraftand failed to provide the pilot-in-command with accurate written informationbefore departure of the aircraft, specifying the additional descriptionrequirements provided in 172.202 including the packing group, in Romannumerals, as designated for the hazardous material in Column (5) of the172.101 table.

o. Date: 3/22/2013, flight #930, SFOLHR, AWB: 016SFO10210922. TheShippers Declaration for Dangerous Goods described the shipment as,UN0367, Fuzes, detonating, 1.4S, 1 Fibreboard box x .352kg NET WT. /

.000708 K.G. N.E.W. The NPIC incorrectly described the number ofpackages as 3 and the net quantity as 19.Additionally, the page of theshipping paper associated with the shipment of UN0173 Release Devices,Explosive, as set forth on the NPIC andrequired by 175.30(a)(2) was notretained by United.

Based on the above, United carried hazardous material onboard an aircraftand failed to provide the pilot-in-command with accurate written informationbefore departure of the aircraft, specifying the total number of packages.

Based on the above, United carried hazardous material onboard an aircraftand failed to provide the pilot-in-command with accurate written informationbefore departure of the aircraft, specifying the net quantity or gross weight, asapplicable, for each package.

Based on the above, United, the aircraft operator, failed to retain a copy ofthe shipping paper required by 175.30(a)(2) or an electronic image thereof,that is accessible at or through its principal place of business, making theshipping paper available, upon request, to an authorized official of a federal,state, or local government agency at reasonable times and locations.

p. Date: 3/23/2013, flight #893, SFO - Incheon International Airport, Incheon,South Korea (INC), AWB: 016SFO10788831. The shipping paper requiredby 175.30(a)(2) was not retained by United.

Based on the above, United, the aircraft operator, failed to retain a copy ofthe shipping paper required by 175.30(a)(2) or an electronic image thereof,


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that is accessible at or through its principal place of business, making theshipping paper available, upon request, to an authorized official of a federal,state, or local government agency at reasonable times and locations.

q. Date: 3/25/2013, flight #195, SFOKona International Airport, Kailua-

Kona, Hawaii (KOA), AWB: 016SFO00986042. The total quantity ofUN1845, Carbon dioxide, solid (dry ice) in each hold aboard the aircraft wasnot specified on the NPIC.


r. Date: 3/27/2013, flight #1606, SFOLAX, AWB: 016SFO75944050. Thetotal quantity of UN1845, Carbon dioxide, solid (dry ice) in each hold aboard

the aircraft was not specified on the NPIC.


s. Date: 3/29/2013, flight #863, SFOSYD, AWB: 016SFO26785172. TheShippers Declaration for Dangerous Goods described the shipment as,UN1263 Paint. The NPIC incorrectly described the shipment as, Life-Saving Appliances, Self-Inflating.

Based on the above, United carried hazardous material onboard an aircraftand failed to provide the pilot-in-command with accurate written informationbefore departure of the aircraft, specifying the proper shipping name of thematerial, as specified in 172.101 of the HMR.

t. Date: 3/30/2013, flight #201, SFOHNL, AWB: 016SFO74780683. TheShippers Declaration for Dangerous Goods described the shipmentas,UN3164, Articles, pressurized, pneumatic. The NPIC incorrectly

described the shipment as, Fiberboard, Pressurized, Pneumatic.


u. Date: 4/5/2103, flight #855, SFOKIX, AWB: 016SFO10288854. Theshipping paper required by 175.30(a)(2) was not retained by United.


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v. Date: 4/7/2013, flight #869, SFOHKG, AWB: 016JFK11061713. TheShippers Declaration for Dangerous Goods described the shipment as, ID8000, Consumer Commodity, 9, 6 Fiberboard Boxes. TheNPICincorrectly describes the number of packages as 1.


w. Date: 4/8/2013, flight #1634, SFOORD, AWB: 016SFO90444841. The

total quantity of UN1845, Carbon dioxide, solid (dry ice) in each hold aboardthe aircraft was not specified on the NPIC.


x. Date: 4/11/2013, flight #556, SFOPhiladelphia International Airport,Philadelphia, PA (PHL), AWB: 016BNE36106954. The total quantity ofUN1845, Carbon dioxide, solid (dry ice) in each hold aboard the aircraft wasnot specified on the NPIC.


y. Date: 4/12/2013, flight #408, SFOIAD, AWB: 016BNE36251131. Thetotal quantity of UN1845, Carbon dioxide, solid (dry ice) in each hold aboardthe aircraft was not specified on the NPIC.


z. Date: 4/13/2013, flight #821, SFOMEX, AWB: 016SFO54393942. Theshipping paper required by 175.30(a)(2) was not retained by United.


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aa.Date: 4/16/2013, flight #102, SFORonal Reagan Washington NationalAirport (DCA), AWB: 016SFO26794401. The location of the packageaboard the aircraft was not specified on the NPIC.


bb.Date: 4/16/2013, flight #1041, SFOPDX, AWB: 016SFO26790956. The

location of the package aboard the aircraft was not specified on the NPIC.


cc.Date: 4/18/2013 & 4/19/2013, flight #886, Kansai International Airport(KIX)SFO, and flight #1171, SFOSEA, AWB: 016KIX46003565. Thedates on the NPIC are listed as 18and 19 instead of 4/18/13 and4/19/13.


dd.Date: 4/19/2013, flight #466, SFOEWR, AWB: 016SFO26791800. TheShippers Declaration for Dangerous Goods describes the shipment as,

UN1950, Aerosols, non-flammable, 2.2. The NPIC incorrectly specifies thehazard class as 2.1.

Based on the above, United carried hazardous material onboard an aircraftand failed to provide the pilot-in-command with accurate written informationbefore departure of the aircraft, specifying the hazard class of the material, asspecified in 172.101 of the HMR.

ee.Date: 4/20/2013, flight #837, SFONRT, AWB: 016SFO10819281. Theshipping paper required by 175.30(a)(2) was not retained by United.

Based on the above, United, the aircraft operator, failed to retain a copy ofthe shipping paper required by 175.30(a)(2) or an electronic image thereof,


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that is accessible at or through its principal place of business, making theshipping paper available, upon request, to an authorized official of a federal,state, or local government agency at reasonable times and locations.

ff. Date: 4/20/2013, flight #837, SFONRT, AWB: 016SFO10535744. The

proper shipping name of UN1845, Carbon dioxide, solid (dry ice) was notspecified on the NPIC.

Based on the above, United carried UN1845, Carbon dioxide, solid (dry ice)onboard an aircraft and failed to provide the pilot-in-command with accuratewritten information before departure of the aircraft, specifying the propershipping name.

gg.Date: 4/22/2013, flight #1263, SFO - Kahului Airport, Kahului, Hawaii(OGG), AWB: 016SFO01026200. The total quantity in each hold aboard theaircraft of UN1845, Carbon dioxide, solid (dry ice) was not specified on the

NPIC.

Based on the above, United carried UN1845, Carbon dioxide, solid (dry ice)onboard an aircraft and failed to provide the pilot-in-command with accuratewritten information before departure of the aircraft, specifying total quantityin each hold aboard the aircraft.

hh.Date: 4/24/2013, flight #885, SFOKIX, AWB: 016SFO10819325. Unitedfailed to accurately specify the net quantity or gross weight, as applicable, foreach package on the NPIC.


ii. Date: 4/26/2013, flight #1178, SFOHNL, AWB: 016SFO74689635. Theshipment was declared as, UN3268, Air bag modules. on the ShippersDeclaration for Dangerous Goods. The NPIC incorrectly described theproper shipping name as Miscellaneous.Additionally, the NPIC incorrectlyprovided the date as 26.

Based on the above, United carried hazardous material onboard anaircraft and failed to provide the pilot-in-command with accuratewritten information before departure of the aircraft, specifying theproper shipping nam of the material, as specified in 172.101 of theHMR.


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jj. Date: 4/26/2013, flight # 680, SFOLAS, AWB: 016SFO26794600. Thegross weight of the hazardous material was not specified on the NPIC.


kk.Date: 4/27/2013, flight #663, SFOHNL, AWB: 016BHX27576065. Thegross weight of the hazardous material was not specified on the NPIC.


ll. Date: 4/28/2013, flight #863, SFOSYD, AWB: 016SFO11088626. The netquantity of the hazardous material was not specified on the NPIC.


mm. Date: 5/1/2013, flight #837, SFOORD, AWB: 016SFO10819395.The Shippers Declaration for Dangerous Goods describes the shipment as,ID 8000, Consumer commodity, 9, 80 Fiberboard Box X 2.5kgG = 200 kgG Total Overpack Used, Y963, DOT-SP 10232. The NPIC failed to specifythe total number of packages, the net quantity or gross weight, as applicable,for each package, and an indication that a hazardous material is being carriedunder the terms of a special permit.




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Based on the above, United carried hazardous material onboard an aircraftand failed to provide the pilot-in-command with accurate written informationbefore departure of the aircraft, specifying an indication, when applicable,that a hazardous material is being carried under the terms of a special permit.

nn.Date: 5/1/2013, flight #837, SFOORD, AWB: 016CDG30734325. The netquantity of the hazardous material was not specified on the NPIC.


oo.Date: 5/1/2013, flight #837, SFOORD, AWB: 016LAX10475113. Thegross weight of the hazardous material was not specified on the NPIC.


pp.Date: 5/2/2013, flight #226, SFOIAH, AWB: 016BNE36279213. The totalquantity in each hold aboard the aircraft of UN1845, Carbon dioxide, solid(dry ice) was not specified on the NPIC.


qq.Date: 5/4/2013, flight #837, SFONRT, AWB: 016SFO10532163. Theshipping paper required by 175.30(a)(2) was not retained by United.


rr. Date: 5/7/2013, flight #930, SFOLHR, AWB: 016SFO10936726. Thegross weight of the hazardous material was not specified on the NPIC.



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ss. Date: 5/8/2013, flight #1154, SFODEN, AWB: 016SFO86530080. Thetotal quantity in each hold aboard the aircraft of UN1845, Carbon dioxide,solid (dry ice) was not specified on the NPIC.

Based on the above, United carried UN1845, Carbon dioxide, solid (dry ice)

onboard an aircraft and failed to provide the pilot-in-command with accuratewritten information before departure of the aircraft, specifying the totalquantity in each hold aboard the aircraft.

tt. Date: 5/11/2013, flight #1715, SFOORD, AWB: 016SFO26799732. Thelocation of the package aboard the aircraft was not specified on the NPIC.


uu.Date: 5/11/2013, flight #885, SFOKIX, AWB: 016SFO10536201. The netquantity or gross weight, as applicable, was not specified on the NPIC.


vv.Date: 5/12/2013, flight #930, SFOLHR, AWB: 016SFO10936763. Thegross weight was not specified on the NPIC.


ww. Date: 5/13/2013, flight #1476, SFOEWR, AWB:016SFO26780482. The location of the package aboard the aircraft was notspecified on the NPIC.


xx.Date: 5/13/2013, flight #1284, EWRSFO, AWB: 016EWR89830134. Thetotal quantity in each hold aboard the aircraft of UN1845, Carbon dioxide,solid (dry ice) was not specified on the NPIC.


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yy.Date: 5/14/2013, flight #926, SFOFRA, AWB: 016SFO72910552. Theproper shipping name of UN1845, Carbon dioxide, solid (dry ice) was notspecified on the NPIC.


zz.Date: 5/15/2013, flight #322, SFOSEA, AWB: 016SFO26800616. Thegross weight was not specified on the NPIC.


aaa. Date: 5/22/2013, flight #837, SFONRT, AWB: 016SFO10819480.The shipping paper required by 175.30(a)(2) was not retained by United.


bbb. Date: 5/25/2013, flight #245, SFOIAD, AWB: 016SFO26803361.The Shippers Declaration for Dangerous Goods described the shipment as,

UN2990, Life-saving appliances, self-inflating. The NPIC incorrectlydescribed the proper shipping name as 1-352-323-3500.


ccc. Date: 5/29/2013, flight #226, SFOIAH, AWB: 016BNE36106976.The total quantity of UN1845, Carbon dioxide, solid (dry ice) in each holdaboard the aircraft was not specified on the NPIC.

Based on the above, United carried UN1845, Carbon dioxide, solid (dry ice)onboard an aircraft and failed to provide the pilot-in-command with accurate


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written information before departure of the aircraft, specifying the totalquantity in each hold aboard the aircraft.

ddd. Date: 5/29/2013, flight# 294, SFODallas / Fort Worth InternationalAirport, Texas (DFW), AWB: 016GUM73242083. The Shippers

Declaration for Dangerous Goods described the shipment as, UN3166,Engine, Internal Combustion, Flammable Liquid Powered, 9, 1 AircraftEngine.The Quantity and Type of Packaging was not set forth on theShippers Declaration for Dangerous Goods as required by 172.202(a)(6)

and 172.202(a)(7). The NPIC failed to specify the net quantity or grossweight, as applicable, for each package.


Based on the above, United accepted a hazardous material for transportationaboard an aircraft and failed to ensure the hazardous material was describedand certified on a shipping paper in accordance with the HMR.

eee. Date: 6/1/2013, flight #889, SFOPEK, AWB: 016SFO26805306.The shipping paper required by 175.30(a)(2) was not retained by United.


fff.Date: 6/7/2013, flight #482, SFODEN, AWB: 016GUM09370255. TheShippers Declaration for Dangerous Goods described the shipment as,UN3091, Lithium metal batteries contained in equipment. The NPICincorrectly described the proper shipping name as United Airlines.Additionally, the NPIC failed to specify the net quantity.




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ggg. Date: 6/7/2013, flight #482, SFODEN, AWB: 016GUM09370292.The Shippers Declaration for Dangerous Goods described the shipment as,UN3091, Lithium metal batteries contained in equipment. The NPICincorrectly described the proper shipping name as United Airlines.Additionally, the NPIC failed to specify the net quantity.



hhh. Date: 8/13/2013, flight #1247, SFOSEA, AWB: 016LYS30713642.The NPIC incorrectly provided the date as 9.Additionally, the location ofthe package aboard the aircraft was not specified on the NPIC.



17.Based upon the foregoing facts and circumstances, United violated the followingDepartment of Transportation Hazardous Materials Regulations (Title 49 of the Codeof Federal Regulations):

a. Section 171.2(e) (49 C.F.R. 171.2(e)), in that United accepted a hazardousmaterial for transportation in commerce when the hazardous material was notproperly classed, described, packaged, marked, labeled, and in the conditionfor shipment required by the HMR (49 C.F.R. parts 171, et seq.).

b. Section 171.2(f) (49 C.F.R. 171.2(f)), in that United transported ahazardous material in commerce when the hazardous material was nottransported in accordance with applicable requirements of the HMR (49C.F.R. parts 171, et seq.).

c. Section 175.3 (49 C.F.R. 175.3), in that United accepted for transportationand transported aboard an aircraft a hazardous material that was not preparedfor shipment in accordance with the HMR.


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d. Section 175.30(a)(2) (49 C.F.R. 175.30(a)(2)), in that United accepted ahazardous material for transportation aboard an aircraft and failed to ensurethe hazardous material was described and certified on a shipping paper inaccordance with the HMR.

e. Section 175.33(a)(1) (49 C.F.R. 175.33(a)(1)), in that United carriedhazardous material onboard an aircraft and failed to provide the pilot-in-command with accurate and legible written information before departure ofthe aircraft, specifying the proper shipping name, hazard class andidentification number of the material, as specified in 172.101 of the HMR.

f. Section 175.33(a)(1)(i) (49 C.F.R. 175.33(a)(1)(i)), in that United carriedhazardous material onboard an aircraft and failed to provide the pilot-in-command with accurate and legible written information before departure ofthe aircraft, specifying the additional description requirements provided in

172.202, and 172.203 of this subchapter.

g. Section 175.33(a)(2) (49 C.F.R. 175.33(a)(2)), in that United carriedhazardous material onboard an aircraft and failed to provide the pilot-in-command with accurate and legible written information before departure ofthe aircraft, specifying the total number of packages.

h. Section 175.33(a)(3) (49 C.F.R. 175.33(a)(3)), in that United carriedhazardous material onboard an aircraft and failed to provide the pilot-in-command with accurate and legible written information before departure ofthe aircraft, specifying the net quantity or gross weight, as applicable, foreach package.

i. Section 175.33(a)(4) (49 C.F.R. 175.33(a)(4)), in that United carriedhazardous material onboard an aircraft and failed to provide the pilot-in-command with accurate and legible written information before departure ofthe aircraft, specifying the location of the packages aboard the aircraft.

j. Section 175.33(a)(5) (49 C.F.R. 175.33(a)(5)), in that United carriedhazardous material onboard an aircraft and failed to provide the pilot-in-command with accurate and legible written information before departure ofthe aircraft, specifying confirmation that no damaged or leaking packageshave been loaded on the aircraft.

k. Section 175.33(a)(7) (49 C.F.R. 175.33(a)(7)), in that United carriedhazardous material onboard an aircraft and failed to provide the pilot-in-command with accurate and legible written information before departure ofthe aircraft, specifying the date of the flight.

l. Section 175.33(a)(10) (49 C.F.R. 175.33(a)(10)), in that United carriedhazardous material onboard an aircraft and failed to provide the pilot-in-


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command with accurate and legible written information before departure ofthe aircraft, specifying an indication, when applicable, that a hazardousmaterial is being carried under the terms of a special permit.

m. Section 175.33(a)(11) (49 C.F.R. 175.33(a)(11)), in that United carried

UN1845, Carbon dioxide, solid (dry ice) onboard an aircraft and failed toprovide the pilot-in-command with accurate and legible written informationbefore departure of the aircraft, specifying the proper shipping name, hazardclass, total quantity in each hold aboard the aircraft, and the airport at whichthe package(s) is to be unloaded.

n. Section 175.33(c)(1) (49 C.F.R. 175.33(c)(1)), in that United, the aircraftoperator, failed to retain a copy of the shipping paper required by175.30(a)(2) or an electronic image thereof, that is accessible at or throughits principal place of business, making the shipping paper available, uponrequest, to an authorized official of a federal, state, or local government

agency at reasonable times and locations.

In accordance with Section 5123(a) of Chapter 51, Title 49 of the United States Codeof Transportation, (49 U.S.C. 5123(a)) United is liable for a civil penalty for eachviolation of the HMRs. United failed to comply with the HMRs in that it failed tocomply with notification of pilot in command and acceptance requirements forhazardous materials. Uniteds numerous HMR violations were detected by FAAagents at four different stations across the country. By reason of the foregoing factsand circumstances, we propose to assess a civil penalty in the amount of $1,301,486.

Enclosed is information concerning Unitedsoptions in responding to this notice.The options include participating in an informal conference with an FAA attorneyand submitting information to the FAA for consideration. United must submit, inwriting, its choice of the alternatives explained on the enclosed information sheet, onor before 30 days after United receives this Notice. If United fails to submit itschoice within that time, we will issue a Final Notice of Proposed Civil Penalty.

Please direct all communications in this matter to Matthew J. Zappala, Office of theRegional Counsel, ANE-7, Federal Aviation Administration, 12 New EnglandExecutive Park, Burlington, MA 01803, telephone number (781) 238-7046.

CHRISTOPHER POREDARegional Counsel

MATTHEW J. ZA

United Airlines Proposed Civil Penalty

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