A.
_ USG-13 (d) stipulates the restrictions airlines must follow in loading dangerous goods aboard an aircraft to/from or transiting the United States. To begin with, USG-13 (d) excludes several items that do not fall under this restriction, i.e., it spells:?gExcept for?eOther Regulated Materials?fas defined in 49 CFR 173.144, substances of Class 9, radioactive material, aircraft batteries transported as items of replacement, and those articles and substances considered to be dangerous under these Regulations but which are not subject to CFR Parts 171-180, ?c.?h

_49 CFR 173.144 referred to in this phrase stand for ORM-D Material which are material such as a consumer commodity, which although otherwise subject to the regulations, presents a limited hazard during transportation due to its form, quantity and packaging. Each ORM-D material and category of ORM-D material is listed in the 172.101 table. This table is similar to the blue pages of the DGR showing a list of all dangerous goods. The passage where it says, ?gand those articles and substances considered to be dangerous under these Regulations but which are not subject to CFR Parts 171-180, ?c.?hmeans items classified as dangerous goods under ICAO/IATA but not so designated by US CFR. 49 CFR Parts 171 through 180 meaning the entire dangerous goods regulations. Since these variations are exhaustive, in practice, the 25 kg rule is applied to all dangerous goods so defined by ICAO/IATA.

_Therefore, USG-13 (d) stipulates that except for those aforementioned items which are excluded, when loading dangerous goods under the situations given below, no more than 25 kg net weight of dangerous goods plus no more than 75 kg of non-flammable gas can be loaded on an aircraft.

1)_ in an inaccessible cargo compartment,

2)_in any freight container within an accessible cargo compartment, or

3)_ in any accessible cargo compartment of a cargo aircraft if the dangerous goods are loaded so as to be inaccessible unless in a freight container. Each package containing dangerous goods acceptable for cargo aircraft only must be loaded so that it is accessible during flight.

_For transport by cargo aircraft the following additional substances are also exempted from the variation:

a)_Division 6.1 (poisonous) materials (except those labeled FLAMMABLE),

b)_Materials in Division 6.2 (etiologic or infectious substances),

c)_Class 3 (flammable liquid) materials with a flashpoint above 23?? that do not meet the definition of another hazard class.

_ In plain language, the foregoing means, you can load net weight 25 kg of DG plus net weight 75 kg of RNG in each lower Dec hold, i.e., the FWD HOLD and the AFT HOLD per 1) above.

_In addition, you can load in the Main Dec of a freighter aircraft, net weight 25 kg of DG plus net weight 75 kg of RNG in each Upper Dec Container with solid walls per 2) above.

_Finally, if you are loading DG using a main Dec pallet/net and you have buried the DG thus making it inaccessible, you can only load a total of 25 kg net weight of DG plus net weight 75 kg of RNG for the entire main Dec , not counting the DG loaded in the main Dec container with solid walls. Even if you use a pallet/net but you do not bury the DG but show it on the surface of the pallet/net, you are free from the USG-13 (d) 3) restriction.

_Confirming the foregoing, you can load 25 kg net weight in FWD HOLD, 25 kg net weight in AFT HOLD, 25 kg net weight in the Main Dec if you bury the DG in a pallet/net, and 25 kg net weight of DG for each Main Dec Container with solid walls. Of course, you can load the additional 75 kg net weight of RNG to each of these positions.