# James W. Stoddard — Hazardous Materials Safety Interpretation

**Citation:** 02-0146  
**Type / status:** guidance / guidance  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2002-10-18

02-0146 concerning 173.29.

## Document text

<<<PAGE 1>>>

U.S. Department
Research and
of Transportation
Washington, D.C. 20590
400 Seventh St., S.W.
special Programs
dministratior
. OCT 18 2002
Mr. James W. Stoddard
613 Andover Lane
Reference No. 02-0146
Coppell, TX 75019-2858
Dear Mr. Stoddard:
This is in response to your letter dated May 6, 2002, concerning air carriers' reluctancy to
transport your Coleman propane camping stove that you use to participate in chili cook-off
..%.
competitions. You state that you never check the propane cylinders or carry matches, torches,
cic.
Under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180), propane is regulated
as a Division 2.1 (Flammable gas). This material is Forbidden to be offered for transportation
or transported by passenger aircraft and passenger rail. Howéver, § 173:29 states that empty
packagings that meet certain provisions are not subject to the requirements of the HMR.
In the case of a propane stove; any internal reservoir areas and piping must be properly cleaned
of residue and purged of vapors to remove any potential hazard to be considered as not regulated
under the HMR. The methods and limits used for determining what qualifies as "cleaned and
purged" under the HMR are intentionally not defined because they vary greatly depending on the
properties of the particular hazardous material and type of packaging. In the case of propane,
other variables such as purge medium, temperature conditions and internal volume are also
reservoir areas and piping are no longer capable of sustaining combustion. When a properly
factors. We would consider a stove to be sufficiently cleaned and purged when the vapors in any
cleaned and purged propane container is offered for transportation by aircraft, the valve must be
left open to preclude internal pressure buildup.
Air carriers of hazardous materials are subject to the applicable requirements of the HMR. The
HMR specify conditions and constraints for offering and transporting hazardous materials in
commerce. However, we have no authority to compel such transportation. Air carriers may
establish their own non-conflicting internal policies and practices for accepting hazardous
materials for transportation.
I hope this information is helpful.
Sincerely,
Hathe z michell
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
020146
Office of Hazardous Materials Standards
17329

<<<PAGE 2>>>

Betts
/
§173.29
James W. Stoddard
613 Andover Lane
Air
5/21/0
Coppell, TX 75019-2858
Phone: 972-393-1636
02-0146
May 6, 2002
Mr. Edward Mazzullo
Director of OHMS
400 7* Street SW
USDOT/RSPA (DHM-10)
. 1.
5143:
Washington, D. C. 20590
Dear Mr. Mazullo:
I am an International Chili Society competition chili cook and frequently fly to the events. I
propane cylinders or carry any matches, torches; etc?* cr
always check my chili luggage, including a Coleman propane camping stove. "I never check the
The problem, especially after "9-11", is that airlines (particularly South West), are reluctant (or
prohibit) the transportation of these units as checkedfor carry-on baggage. " Their misplaced
concern is that there may be trapped gases that could cause à fire or explosion. You can see this
would be a large problem for a chili cook traveling to participate in a cook-off with no stove.
This has been an 'on-going problem eyen before "9-11",
a letter from The Goleman Companys' senior engineer (attached) stating there was no danger of
, so the International Chili Society elicited
trapped gases igniting/exploding: However; thairlines are taking exception to the term "marine
contacted Coleman and they refused to. get further involved due to scope of authority and legal
vessel transport" in this correspondence pointing, out that it doesn't refer to aviation transport. I
issues after "9-11".
What would be very helpful from you, if you agree there is no danger from the stove, is a letter
from your office stating such. I think the more specific, the better, and a contact number the
circular to the airlines might clear up this concern.
airlines may call to clear up any concerns or questions they may have. Maybe a publisher
I look forward to your expeditious reply: to this matter. 1 also maybe.contacted at:.
972-393-1636 (home):
972-393-0968 (fax)
:S.:
AlienPilot3@attbi.com (email)
Thanks,
•******?
.%
James W. Stoddard

## Provenance

- Official: Yes
- Source: <https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020146.pdf>
- Source ID: `phmsa`
- SHA-256: `a4cbcb81e16d65fdf98bf875e7990e349229fc9d4cb5e3bc4eaa2202344b42f3`
- Retrieved: 2026-08-20T00:59:31.977Z
- Exported: 2026-08-23T13:52:10.619Z
- Document slug: `phmsa-interpretation-02-0146`

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