{"operation":"document","citation":"10-0134","title":"Conax Florida Corporation Cobham Life Support — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2011-08-30","effective_on":null,"summary":"10-0134 response to Conax Florida Corporation Cobham Life Support concerning 173.219.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0134.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0134.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0134","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2010/100134.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department Washington, DC 20590\n1200 New Jersey Ave .. S.E.\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration AUG 3 02011\nMr. Thanh Seybold\nContracts Administrator\nConax Florida Corporation\nCobham Life Support\n2801 75th Street\nPetersburg, FL 33710\nRef:. No.: 10-0134\nDear Mr. Seybold:\nThis responds to your letter requesting guidance on re-classifying an \"inflator\" device packaged\nand shipped under Competent Authority (CA) Approval Number \"EX-9ll 0087\", in accordance\nwith the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You enclosed\ndrawings of the device. According to your letter, this device is a water-activated automatic life\npreserver \"inflator\" which attaches to a life preserver. The \"inflator\" automatically actuates\nwhen immersed in water, assuming the human user is unconscious. These \"inflator\" devices\nare packaged with life preservers and are also packaged and shipped separately. Your\ncompany's primary customer is the U.S. military: the Navy, Marines, and Air Force. The\ndevice is classed and described as \"Cartridges, power device, I.4S, UN0323, PG II\" under CA\n\"EX-9110087.\" You ask ifthis device should be classified as \"Hazard Class 9, Life-saving\nappliances, UN3072.\"\nThe answer is no. The description \"Life-saving appliances, not self-inflating containing\ndangerous goods as equipment (UN3072)\" applies to the overall appliance rather than\nindividual hazardous material used to supplement the appliance, such as those listed in\n§ l73.219(b). The exception is intended to provide relief for a small quantity of a hazardous\nmaterial that is integrated into a life-saving appliance. The \"inflator\" itself, classed and\ndescribed as \"Cartridges, power device, l.4S, UN0323, PG II\" under CA \"EX-911 0087,\" may\nnot be reclassed and described as \"Life-saving appliances, not self-inflating containing\ndangerous goods as equipment (UN3072).\" The inflator must be integrated into a life-saving\nappliance.\nI hope this information is helpful. If we can be of further assistance, please contact us.\n'nc ely, _\n~~S~6e~-\nen Supko\nActing Chief, Standards Development\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nCDElHRm\nCobham Life Support\n2801 75th Street North\nSt. Petersburg, Fl 33710 USA\nT: +1 (727) 345 8000\nF: +1 (727) 3454217\nJune 22,2010 £ngrarYl\nApprovals Branch\nOffice of Hazardous Materials Transportation Department of Transportation\n400 Seventh Street SW, Washington, DC 20590-0001\nAttn: PHH-32, Room 8102\n~113 .2J't\nLire -.5a.viV1j Applt o.YJce S\n, b-ol3j\nSubject: Guidance Regarding Reclassification of PIN 1812-173-01\nDear Sir/Madam,\nConax Florida Corporation is requesting guidance regarding the reclassification of our\nPart Number 1812-173-01 under § 173.219 of 49CFR. This is an \"inflator\".\nThis device is water-activated automatic life preserver \"inflator\" which attaches to a life\npreserver. They automatically actuate when immersed in water when the human user is\nunconscious, the life preserver shelf inflates. These devices are packaged with life\npreservers; however, we also ship them separately. Our main customer is the U.S.\nmilitary: US Navy, Marines, and Air Force.\nThe item was previously classified as Cartridges, Power Device, UN0323, 1.4S, EX9110087.\nHowever, we feel this may be a misclassification.\nAs opposed to the UN0323 classification in 49CFR § 173.219 (b)(6), it describes \"For\nself-inflating life saving appliances only, cartridge power device of Division 1.4S, for\npurposes of the self-inflating mechanism provide that the quantity of explosives per\nappliance does not exceed 3.2g\". We feel our device fits this definition; therefore,\nwhenever they are not directly connected to the life preserver, are we able to ship this\nitem and others similar to them as a Hazard Class 9, Life-Saving Appliance, UN3072?\nOur military customers would prefer this.\nThis new class under 173.219 (b)(6) allows air transport without a Competent Authority\nan aid to normal packing. This is due to the extremely small explosive, self-contained\ngas cartridge and associated with life preserves generally.\nEnclosed are the drawings of these parts listed below:\nPart Number 1812-173-01\nSub-assembly 1612-051-02\nSub-assembly 1612-011-02\nConax Florida Corporation doing business as Cobham Ufe Support. www.cobham.com\n\n<<<PAGE 3>>>\n\nCylinder CC-S01-01\nPrimer CC-114-01, 6Smgbase charge, 20Smg ignition charge\nAt this time, we would appreciate your efforts to review the enclosed reports and\ndrawings and defining the intent of the regulations for classifying Life-Saving Appliances\nand our device/cartridge under that category.\nThank you,\nrrtianli Sey60U\nContracts Administrator\nConax Florida Corporation\n727 -346-2709\nthanh.seybold@cobham.com\nCOnax Florida COrporation doing business as CObham Ufe Support. www.cobham.com","truncated":false,"body_characters":4811}