Arkansas Children's Hospital — Hazardous Materials Safety Interpretation

Page 1400 Seventh St., S.W. Washington, D.C. 20590 dministration JUN 16 2003 Mr. Wes Ware, BS, RRT, NREMT Arkansas Children's Hospital Ref No.: 03-0018 Angle One Transport 800 Marshall Street Little Rock, Arkansas 72202 Dear Mr. Ware: This is in response to your letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180), regarding the transportation of compressed gases cylinders by aircraft. Specifically, you request confirmation that cylinders of compressed gases, necessary to protect the life and treat patients who are being transported on a stretcher in an ambulance, may be transported under the provisions in § 175.10(a)(14). The answer to your question is no. As specified in § 175.10(a)(14), a transport incubator unit from the HMR provided: (1) the compressed gas used to operate the unit is in an authorized DOT specification cylinder and is marked, labeled, filled and maintained as prescribed by the HMR; (2) each battery used in the operation of the unit is of the non-spillable type; (3) the unit is constructed so that valves, fittings, and gauges are protected from damage; (4) the pilot in command is advised when the unit is on board, and when it is intended for use; (5) the unit is accompanied by a person qualified to operate it; (6) the unit is secured in the aircraft in a manner so as not to restrict access to or use of any required emergency or regular exit or of the aisle in the passenger compartment and; (7) there is no smoking within 10 feet of the unit. It is the opinion of this office that a patient that is being transported aboard an air ambulance on stretcher, is not being transported in a transport incubator, and, therefore the exception in § 175.10(a)(14) does not apply. However, § 175.10(a)(7) excepts from the HMR oxygen, or any hazardous material used for the generation of oxygen, for medical use by a passenger, which is 175.10(a)(14) 030018#

Page 2furnished by the aircraft operator in accordance with 14 CFR §§121.574 or 135.91. Thereforc, cylinders of supplemental oxygen for medical use by a passenger, which are furnished by the aircraft operator in accordance with § 175.10(a)(7), are not subject to the HMR. I hope this information is helpful. Please contact us if you require additional assistance Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards#

Page 3Relerford 8175.10()(14) Air Exceptions 03 - 0018 800 Marshall "St • Litle Rock, AR 72202-3591 • 501/320-1100 or TDD 501/320-1184 • www.archildrens.org TAIN •ALI Mr. Bchvard Mazzullo Offoe of Hazardous Materials Standards Dear Sir, I have been conversing with the people at the Hazardous Materials Information Contex, as questions and pointing me in the right direction. They informed me that I need to talk to well as the people al the Exemptions Brauch. They were very helpful in answering my you or someone in your office and get a lettes of clarification. I would like a clarification interpretation on Tidle 49 CFR 175.10 soction A(14). This life. It goes on to talk about using compressed gases that are ased to operate that exemption deals with using a transport incubator on an aircraft that is necessary to protect incubator and in turn provide modical treatment to the patient. and freal patients in an air ambulance. The difference is that not all the palients ave The clarification I am seeking deals with using compressed gases necessary to protect life aircraff the same syay an incubator is. Does Title 49 CFR 175.10 section a (1.4) also transport are in an incubator. Many of them are on a stretcher that is socured inside the apply to stretchers? We do not transport compressed gasses for commerce. We transport compressed gases in critically ill people. the cabin of our air ambulances and ground ambulances for the purpose of treating If you need more information or bave other questions please contact the. Thank You Arkausas Children's Hospital Wes Ware, BS, RRT, NREMT 800 Marshall Street Angel One Transport 501-766-0643 Littic Rock, Arkansas 72202 Rax 501-364-6431• WeslcyW732@aol.com Warewo@anchildrens.org • -. A maior carding office of the Winemy of Artarsa for Maccal sciences#