{"operation":"document","citation":"00-0028","title":"Trans World Airlines, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2000-02-17","effective_on":null,"summary":"00-0028 response to Trans World Airlines, Inc. concerning 175.75.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0028.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0028.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0028","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000028.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\n•\n400 Seventh Street, S.W.\nWashington, D.C.\n20590\nResearch and\nAdministrations\nFEB 1 8 2000\nMr. Les Adolph\nRef. No. 00-0028\nSr Manager-Hazardous Materials Transportation Programs\nTrans World Airlines, Inc.\n9200 N. W. 112'h Street\nP.O. Box 20126\nKansas City, MO 64195\nDear Mr. Adolph:\nThis is in response to your letter dated January 17, 2000, regarding the proper shipping description for\ncrew member personal breathing equipment (PBE) manufactured by Essex PB&R Corporation.\nSpecifically, you ask if the proper shipping description for the PBE described in your letter is \"Life-\nsaving appliance, not self-inflating, 9, UN3072.\"\nUnder 49 CFR 173.22, it is the shipper's responsibility to properly describe a material in accordance\nwith Parts 172 and 173. Such determinations are not required to be verified by this Office. In your\nletter, you describe a PBE which contains two small compressed oxygen cylinders, each having a\nvolumetric capacity of approximately 3.3 ounces, and approximately 0.2 kilograms of lithium\nhydroxide, and otherwise complies with the conditions and limitations of § 173.219. We agree that the\nproper shipping name for this article is \"Life-saving appliance, not self-inflating, 9, UN3072.\" In\naddition, it is our opinion that the limitations in § 175.85(i)(1) and (2) which limit the number of\ncylinders of compressed oxygen in certain cargo compartments do not apply to articles which may be\ndescribed as \"Life-saving appliance, not self inflating.\"\nI trust this information is of use to you. If we can be of further assistance, please contact us.\nSincerely,\nDirector, Office of Hazardous Materials Standards\n17575\n000028\n-\n\n<<<PAGE 2>>>\n\nTRANS WORLD AIRLINES. INC.\nTWA\n9200 N. W. 112'h Street. - P.O. Box 20126 - Kansas City, Missouri 64195\nGale\nJanuary 17, 2000\n$175.75\nU.S. Department of Transportation\nResearch and Special Programs Administration\n8172.101(1)\nOffice of Hazardous Materials Standards\nAttn: Ed Mazzullo\nHeadquarters (DHM-10)\nle saving\n400 Seventh Street, S.W.\naipliance\nWashington, DC 20590\n00-0028\nDear Mr. Mazzullo,\nI am writing to you requesting a formal interpretation of the proper shipping name for Crew Member\nPersonal Breathing Equipment (PBE) manufactured by Essex PB&R Corporation. It is my suggestion\nthat an appropriate proper shipping name for these devices would be Life-saving appliances, not self-\ninflating, UN3072. However, at this time there does not appear to be agreement from your agency on\nthis point.\nI want to assure you that this request is only for the type of PBE, which uses compressed oxygen, and\nIS NOT to be associated in anyway with the PBE's that use oxygen generators.\nI am enclosing copies of correspondence I have had with DOT on this subject as well as information\nfrom the manufacturer that describes the device. Perhaps due to a misunderstanding on my part, I\ninough we already had achieved the ability to use Life-saving appliances, not self-inflating.\nUN3072. However, the manufacturer uses two proper shipping names for each PBE that is shipped:\nand they are, Oxygen, compressed, UN1072 and Corrosive solid, n.o.s. (Anhydrous lithium\nhydroxide), UN1759.\nThere are some important justifications for preferring UN3072 for these devices.\nFirst, they contain relatively small amounts of each of their hazardous constituents. The\namounts of both of the products is minimal - i.e., two small cylinders of oxygen totalling\n0.048kg and 0.2 kg of lithium hydroxide which is used as a carbon dioxide scrubber.\nSecond, they function together in the operation of this device, when it operates as a PBE.\n• Third, and perhaps most importantly from a handling point of view, the presence of\nOxygen, compressed, UN1072, in this device links it directly to the loading restrictions (i.e.,\nin Docket HM-224A.\nno more than six oxygen cylinders per Class D compartment), introduced in the Final Rule\nI have been in discussions with the manufacturer who also supports the change to Life-saving\nappliances, not self-inflating, UN3072.\n-\n\n<<<PAGE 3>>>\n\nThis letter is part of a two-fold approach. Through ATA, the air carrier industry has asked for an\nemergency exemption that seeks to exclude these small units from the limitation of six oxygen\ncylinders per aircraft, in inaccessible cargo compartments, which becomes effective March 1, 2000.\nWhile that exemption would be valuable to every operator, I still feel that Life-saving appliances, not\nself-inflating, UN3072 is the most appropriate proper shipping name that represents the minimal\nhazards associated with this device but I would like a formal interpretation that supports its use.\nBest regards,\nLes Cafe\nLes Adol6\nSr. Manager-Hazardous Materials Transportation Programs\nTrans World Airlines, Inc.\nChairman-Air Transport Association-HAZMAT COMAT TASK FORCE\nAttachments:\nCc: Frank Black - ATA\nWayne Kerley - PB&R Essex Corporation","truncated":false,"body_characters":4907}