{"operation":"document","citation":"03-0018","title":"Arkansas Children's Hospital — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2003-06-16","effective_on":null,"summary":"03-0018 response to Arkansas Children's Hospital concerning 175.10.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0018.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0018.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0018","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2003/030018.pdf","body":"<<<PAGE 1>>>\n\n400 Seventh St., S.W.\nWashington, D.C. 20590\ndministration\nJUN 16 2003\nMr. Wes Ware, BS, RRT, NREMT\nArkansas Children's Hospital\nRef No.: 03-0018\nAngle One Transport\n800 Marshall Street\nLittle Rock, Arkansas 72202\nDear Mr. Ware:\nThis is in response to your letter requesting clarification of the Hazardous Materials Regulations (HMR;\n49 CFR Parts 171-180), regarding the transportation of compressed gases cylinders by aircraft.\nSpecifically, you request confirmation that cylinders of compressed gases, necessary to protect the life\nand treat patients who are being transported on a stretcher in an ambulance, may be transported under\nthe provisions in § 175.10(a)(14).\nThe answer to your question is no. As specified in § 175.10(a)(14), a transport incubator unit\nfrom the HMR provided: (1) the compressed gas used to operate the unit is in an authorized DOT\nspecification cylinder and is marked, labeled, filled and maintained as prescribed by the HMR; (2) each\nbattery used in the operation of the unit is of the non-spillable type; (3) the unit is constructed so that\nvalves, fittings, and gauges are protected from damage; (4) the pilot in command is advised when the\nunit is on board, and when it is intended for use; (5) the unit is accompanied by a person qualified to\noperate it; (6) the unit is secured in the aircraft in a manner so as not to restrict access to or use of any\nrequired emergency or regular exit or of the aisle in the passenger compartment and; (7) there is no\nsmoking within 10 feet of the unit.\nIt is the opinion of this office that a patient that is being transported aboard an air ambulance on\nstretcher, is not being transported in a transport incubator, and, therefore the exception in\n§ 175.10(a)(14) does not apply. However, § 175.10(a)(7) excepts from the HMR oxygen, or any\nhazardous material used for the generation of oxygen, for medical use by a passenger, which is\n175.10(a)(14)\n030018\n\n<<<PAGE 2>>>\n\nfurnished by the aircraft operator in accordance with 14 CFR §§121.574 or 135.91. Thereforc,\ncylinders of supplemental oxygen for medical use by a passenger, which are furnished by the aircraft\noperator in accordance with § 175.10(a)(7), are not subject to the HMR.\nI hope this information is helpful. Please contact us if you require additional assistance\nSincerely,\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nRelerford\n8175.10()(14)\nAir\nExceptions\n03 - 0018\n800 Marshall \"St • Litle Rock, AR 72202-3591 • 501/320-1100 or TDD 501/320-1184 • www.archildrens.org\nTAIN •ALI\nMr. Bchvard Mazzullo\nOffoe of Hazardous Materials Standards\nDear Sir,\nI have been conversing with the people at the Hazardous Materials Information Contex, as\nquestions and pointing me in the right direction. They informed me that I need to talk to\nwell as the people al the Exemptions Brauch. They were very helpful in answering my\nyou or someone in your office and get a lettes of clarification.\nI would like a clarification interpretation on Tidle 49 CFR 175.10 soction A(14). This\nlife. It goes on to talk about using compressed gases that are ased to operate that\nexemption deals with using a transport incubator on an aircraft that is necessary to protect\nincubator and in turn provide modical treatment to the patient.\nand freal patients in an air ambulance. The difference is that not all the palients ave\nThe clarification I am seeking deals with using compressed gases necessary to protect life\naircraff the same syay an incubator is. Does Title 49 CFR 175.10 section a (1.4) also\ntransport are in an incubator. Many of them are on a stretcher that is socured inside the\napply to stretchers?\nWe do not transport compressed gasses for commerce. We transport compressed gases in\ncritically ill people.\nthe cabin of our air ambulances and ground ambulances for the purpose of treating\nIf you need more information or bave other questions please contact the.\nThank You\nArkausas Children's Hospital\nWes Ware, BS, RRT, NREMT\n800 Marshall Street\nAngel One Transport\n501-766-0643\nLittic Rock, Arkansas 72202\nRax 501-364-6431•\nWeslcyW732@aol.com\nWarewo@anchildrens.org\n• -.\nA maior carding office of the Winemy of Artarsa for Maccal sciences","truncated":false,"body_characters":4231}