Essex Aerospace and Defense — Hazardous Materials Safety Interpretation

Page 1us reportion 400 Seventh Street, S.W. Washington, D.C. 20590 Pipeline and Administration Hazardous Materials Safety MAR 10 2005 Mr. Russell Zavadil Ref. No. 05-0045 Quality Manager Essex Aerospace and Defense 8007 Chivvis Drive St. Louis, MO 63213 Dear Mr. Zavadil: This is in response to your request for a clarification on the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to an oxygen converter that will be mounted onboard ambulances and other emergency response vehicles. You state the converter stores 10 or 25 liters of liquid oxygen that it converts into breathing gas for patients. The vehicles will be operated by Federal, state or local government personnel. The transport of hazardous materials in government vehicles operated by government personnel solely for non-commercial purposes are not subject to the HMR. However, if the purpose is commercial, or if the government entity offers hazardous materials for transportation to commercial carriers, then the HMR would apply. I hope this information is helpful. If you need further assistance, please do not hesitate to contact us. Sincerely, Hotte 7-Mithell Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 171.1 050045#

Page 2Mitckell 81718.1 Mitchell, Hattie <PHMSA> Appucability Sent: From: Russell Zavadil [RZAVADIL@essexind.com] Subject: To: Mitchell, Hattie Tuesday, November 09, 2004 5:08 PM 05-0045 RE: Transport of Compressed gas onboard an ambulance - highway I truly Dear Hattie, have these requests of clarification quite appreciate your help and quick response to my questions, I understand you must The letter you sent to me was clear and I understood the precedence. often. but does not mention Liquid Oxygen. However the letter speaks mainly to compressed gases nitric oxide and nitrogen mixtures I was hopeful that I could gain some clarification as to something more similar to our A simple letter would suffice stating that your position as discussed this afternoon. it into breathing gas for patients. This is mounted as a permanent appliance into the The product is a 10 liter and 25 liter Liquid Oxygen converter which stores LOX and turns ambulance. Taking into account your schedule I understand this may take several days. Any help you could give would be greatly appreciated. at anytime. Hattie all of my contact information is below, if you have any questions please contact me Best Regards, Russi Russell Zavadil Essex Aerospace and Defense Quality Manager 8007 Chivvis Dr. Phone St. Louis Mo 63213 314 832-8077 X316 Cryoger.ics Info 314 :zavadil@essexind.com 644-3000 X311 Manufacturing -----Original Message- Sent: Tuesday, November 09, 2004 3:50 PM From: Mitchell, Hattie [mailto:hattie.mitchell@RSPA.dot.gov] To: Russell Zavadil Subject: FW: Transport of Compressed gas onboard an ambulance - highway From: Mitchell, Hattie ----Original Message----- To: Russ Zavadil (RZavadil@EssexInd.com) Sent: Tuesday, November 09, 2004 4:38 PM Subject: Transport of Compressed gas onboard an ambulance - highway 1#

Page 3<<000172.url>> http://dms.dot.gov/rspa/jul00/000172.pdf#

Page 4Performance Characteristics Capacity 25 Liters of LOX - PN 10C-0043 Service 8.5 Liters of LOX - PN 10C-004C Delivery Rate Temperature: Up to 100 LPM at 50 PSIG Operating Delivery Within 20°F of Ambien 32°F to 120°F (0°C to 49°C Humidity: Non-Operating (Storage) -40°F to 158°F (-40°C to 70°C) Storage (in shipping container) Operating Up to 95% Up to 100% Relief Valve Settings: Safety System 285 PSIG 400 PSIG Optimal Time To Performance After Filling Rupture Disc Burst Pressure 750 PSIG at 72°F (22°C) minutes#