{"operation":"document","citation":"02-0146","title":"James W. Stoddard — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2002-10-18","effective_on":null,"summary":"02-0146 concerning 173.29.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0146.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0146.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0146","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020146.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nResearch and\nof Transportation\nWashington, D.C. 20590\n400 Seventh St., S.W.\nspecial Programs\ndministratior\n. OCT 18 2002\nMr. James W. Stoddard\n613 Andover Lane\nReference No. 02-0146\nCoppell, TX 75019-2858\nDear Mr. Stoddard:\nThis is in response to your letter dated May 6, 2002, concerning air carriers' reluctancy to\ntransport your Coleman propane camping stove that you use to participate in chili cook-off\n..%.\ncompetitions. You state that you never check the propane cylinders or carry matches, torches,\ncic.\nUnder the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180), propane is regulated\nas a Division 2.1 (Flammable gas). This material is Forbidden to be offered for transportation\nor transported by passenger aircraft and passenger rail. Howéver, § 173:29 states that empty\npackagings that meet certain provisions are not subject to the requirements of the HMR.\nIn the case of a propane stove; any internal reservoir areas and piping must be properly cleaned\nof residue and purged of vapors to remove any potential hazard to be considered as not regulated\nunder the HMR. The methods and limits used for determining what qualifies as \"cleaned and\npurged\" under the HMR are intentionally not defined because they vary greatly depending on the\nproperties of the particular hazardous material and type of packaging. In the case of propane,\nother variables such as purge medium, temperature conditions and internal volume are also\nreservoir areas and piping are no longer capable of sustaining combustion. When a properly\nfactors. We would consider a stove to be sufficiently cleaned and purged when the vapors in any\ncleaned and purged propane container is offered for transportation by aircraft, the valve must be\nleft open to preclude internal pressure buildup.\nAir carriers of hazardous materials are subject to the applicable requirements of the HMR. The\nHMR specify conditions and constraints for offering and transporting hazardous materials in\ncommerce. However, we have no authority to compel such transportation. Air carriers may\nestablish their own non-conflicting internal policies and practices for accepting hazardous\nmaterials for transportation.\nI hope this information is helpful.\nSincerely,\nHathe z michell\nHattie L. Mitchell\nChief, Regulatory Review and Reinvention\n020146\nOffice of Hazardous Materials Standards\n17329\n\n<<<PAGE 2>>>\n\nBetts\n/\n§173.29\nJames W. Stoddard\n613 Andover Lane\nAir\n5/21/0\nCoppell, TX 75019-2858\nPhone: 972-393-1636\n02-0146\nMay 6, 2002\nMr. Edward Mazzullo\nDirector of OHMS\n400 7* Street SW\nUSDOT/RSPA (DHM-10)\n. 1.\n5143:\nWashington, D. C. 20590\nDear Mr. Mazullo:\nI am an International Chili Society competition chili cook and frequently fly to the events. I\npropane cylinders or carry any matches, torches; etc?* cr\nalways check my chili luggage, including a Coleman propane camping stove. \"I never check the\nThe problem, especially after \"9-11\", is that airlines (particularly South West), are reluctant (or\nprohibit) the transportation of these units as checkedfor carry-on baggage. \" Their misplaced\nconcern is that there may be trapped gases that could cause à fire or explosion. You can see this\nwould be a large problem for a chili cook traveling to participate in a cook-off with no stove.\nThis has been an 'on-going problem eyen before \"9-11\",\na letter from The Goleman Companys' senior engineer (attached) stating there was no danger of\n, so the International Chili Society elicited\ntrapped gases igniting/exploding: However; thairlines are taking exception to the term \"marine\ncontacted Coleman and they refused to. get further involved due to scope of authority and legal\nvessel transport\" in this correspondence pointing, out that it doesn't refer to aviation transport. I\nissues after \"9-11\".\nWhat would be very helpful from you, if you agree there is no danger from the stove, is a letter\nfrom your office stating such. I think the more specific, the better, and a contact number the\ncircular to the airlines might clear up this concern.\nairlines may call to clear up any concerns or questions they may have. Maybe a publisher\nI look forward to your expeditious reply: to this matter. 1 also maybe.contacted at:.\n972-393-1636 (home):\n972-393-0968 (fax)\n:S.:\nAlienPilot3@attbi.com (email)\nThanks,\n•******?\n.%\nJames W. Stoddard","truncated":false,"body_characters":4324}