Hazardous Materials Operations Under Part 108

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Operations involving the carriage or dispensing of hazardous materials that fall under 49 CFR Part 175 (beyond standard Part 137 agricultural applications) add significant additional risk and regulatory requirements under Part 108. These specialized operations — such as heavy-lift application of certain Classes of hazardous materials directly to structures for cleaning, painting, and maintenance — generally require enhanced training, procedures, oversight, and often the operating certificate pathway. The proposed Part 108 framework will need to address these advanced use cases while integrating existing hazmat air transportation standards.

• Authorization Pathway: Usually requires an Operating Certificate (or specific authorization under a permit) due to elevated risk; some lower-risk agricultural hazmat dispensing may qualify for permit with strict limitations
• Maximum Takeoff Weight: Up to 1,320 pounds when conducted under certificate; lower limits may apply under permit
• Population Density Categories: Heavily restricted — typically Category 1 only for dispensing operations; very limited or prohibited in higher population categories without exceptional mitigation
• Fleet / Scale Limits: More restrictive under permit; greater flexibility under certificate with approved safety management systems
• Additional Requirements: Comprehensive hazmat training program (handling, emergency response, spill procedures), specific recordkeeping, coordination with poison control, compliance with product labeling and federal/state regulations, and prohibition on dispensing directly over people without specific authorization

Operators currently conducting or planning advanced hazmat-related UAS work (including emerging structure application uses) will need robust operations manuals, training programs, and safety cases that address both Part 108 BVLOS requirements and 49 CFR Part 175 hazmat transportation standards. Those who have already developed and received FAA acceptance for harmonized hazmat-capable manuals under current exemptions are significantly ahead in preparing for Part 108 transition. Specialized operations, such as heavy-lift hazmat application to structures, are expected to follow the certificate pathway or require targeted exemptions/waivers during the transition period.