Trans World Airlines, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department • 400 Seventh Street, S.W. Washington, D.C. 20590 Research and Administrations FEB 1 8 2000 Mr. Les Adolph Ref. No. 00-0028 Sr Manager-Hazardous Materials Transportation Programs Trans World Airlines, Inc. 9200 N. W. 112'h Street P.O. Box 20126 Kansas City, MO 64195 Dear Mr. Adolph: This is in response to your letter dated January 17, 2000, regarding the proper shipping description for crew member personal breathing equipment (PBE) manufactured by Essex PB&R Corporation. Specifically, you ask if the proper shipping description for the PBE described in your letter is "Life- saving appliance, not self-inflating, 9, UN3072." Under 49 CFR 173.22, it is the shipper's responsibility to properly describe a material in accordance with Parts 172 and 173. Such determinations are not required to be verified by this Office. In your letter, you describe a PBE which contains two small compressed oxygen cylinders, each having a volumetric capacity of approximately 3.3 ounces, and approximately 0.2 kilograms of lithium hydroxide, and otherwise complies with the conditions and limitations of § 173.219. We agree that the proper shipping name for this article is "Life-saving appliance, not self-inflating, 9, UN3072." In addition, it is our opinion that the limitations in § 175.85(i)(1) and (2) which limit the number of cylinders of compressed oxygen in certain cargo compartments do not apply to articles which may be described as "Life-saving appliance, not self inflating." I trust this information is of use to you. If we can be of further assistance, please contact us. Sincerely, Director, Office of Hazardous Materials Standards 17575 000028 -#

Page 2TRANS WORLD AIRLINES. INC. TWA 9200 N. W. 112'h Street. - P.O. Box 20126 - Kansas City, Missouri 64195 Gale January 17, 2000 $175.75 U.S. Department of Transportation Research and Special Programs Administration 8172.101(1) Office of Hazardous Materials Standards Attn: Ed Mazzullo Headquarters (DHM-10) le saving 400 Seventh Street, S.W. aipliance Washington, DC 20590 00-0028 Dear Mr. Mazzullo, I am writing to you requesting a formal interpretation of the proper shipping name for Crew Member Personal Breathing Equipment (PBE) manufactured by Essex PB&R Corporation. It is my suggestion that an appropriate proper shipping name for these devices would be Life-saving appliances, not self- inflating, UN3072. However, at this time there does not appear to be agreement from your agency on this point. I want to assure you that this request is only for the type of PBE, which uses compressed oxygen, and IS NOT to be associated in anyway with the PBE's that use oxygen generators. I am enclosing copies of correspondence I have had with DOT on this subject as well as information from the manufacturer that describes the device. Perhaps due to a misunderstanding on my part, I inough we already had achieved the ability to use Life-saving appliances, not self-inflating. UN3072. However, the manufacturer uses two proper shipping names for each PBE that is shipped: and they are, Oxygen, compressed, UN1072 and Corrosive solid, n.o.s. (Anhydrous lithium hydroxide), UN1759. There are some important justifications for preferring UN3072 for these devices. First, they contain relatively small amounts of each of their hazardous constituents. The amounts of both of the products is minimal - i.e., two small cylinders of oxygen totalling 0.048kg and 0.2 kg of lithium hydroxide which is used as a carbon dioxide scrubber. Second, they function together in the operation of this device, when it operates as a PBE. • Third, and perhaps most importantly from a handling point of view, the presence of Oxygen, compressed, UN1072, in this device links it directly to the loading restrictions (i.e., in Docket HM-224A. no more than six oxygen cylinders per Class D compartment), introduced in the Final Rule I have been in discussions with the manufacturer who also supports the change to Life-saving appliances, not self-inflating, UN3072. -#

Page 3This letter is part of a two-fold approach. Through ATA, the air carrier industry has asked for an emergency exemption that seeks to exclude these small units from the limitation of six oxygen cylinders per aircraft, in inaccessible cargo compartments, which becomes effective March 1, 2000. While that exemption would be valuable to every operator, I still feel that Life-saving appliances, not self-inflating, UN3072 is the most appropriate proper shipping name that represents the minimal hazards associated with this device but I would like a formal interpretation that supports its use. Best regards, Les Cafe Les Adol6 Sr. Manager-Hazardous Materials Transportation Programs Trans World Airlines, Inc. Chairman-Air Transport Association-HAZMAT COMAT TASK FORCE Attachments: Cc: Frank Black - ATA Wayne Kerley - PB&R Essex Corporation#