The Govmark Organization, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OCT 0 1 2012 1200 New Jersey Avenue SE Washington. DC 20590 Mr. Salvatore Messina The Govmark Organization, Inc. 96 Allen Boulevard, Suite D Farmingdale, NY 11735-5626, USA Ref. No. 12-0147 Dear Mr. Messina: This responds to your July 2, 2012 request for clarification on testing requirements for cylinders under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You state in your letter that your company is a fire testing laboratory. Specifically, you ask if both the flame penetration resistance and thermal resistance tests specified in § 173.302(f) are required for compressed oxygen and oxidizing gases transported by aircraft. The answer is yes. In accordance with § 173.302(f), both the flame penetration resistance and thermal resistance tests specified are required for compressed oxygen and oxidizing gas transported by aircraft. Specifically, the cylinder must be placed in a rigid outer packaging that is capable of passing the Flame Penetration Resistance Test in Appendix E to part 178. The cylinder and the outer packaging must be capable of passing the Thermal Resistance Test specified in Appendix D to part 178. For your information, in accordance with § 173.302(f)(6), a cylinder of compressed oxygen furnished by an aircraft operator to a passenger in accordance with 14 CFR §§ 121.574, 125.219, or 135.91 is excepted from the outer packaging requirements of paragraph (f)(3)of this section. 1 hope this answers your inquiry. If you need additional assistance, please contact this office at (202) 366-8553. Sincerely, Robert Benedict Chief, Standards Development Branch Standards and Rulemaking Division#

Page 2The Govmark Organization, Inc. 96 Allen Boulevard, Suite 0- Farmingdale, NY 11735-5626- U.S.A. Tel.: +1 631 293 8944 Fax: +1 631 293 8956 Testing Division: info@govmark.com Test Instruments Division: instruments@govmark.com Website: www.govmark.com July 2, 2012 SMC 7333 John A. Gale or T. Glenn Foster Office of Hazardous Materials Standards Pipeline and Hazardous Materials Administration U.S. Department of Transportation 1200 New Jersey Avenue, SE., East Building, 2nd fl, PHH-11 Washington, DC 20590-0001 Tel.: (202) 366-8553 David Catey Office of Flight Standards Service Federal Aviation Administration U.S. Department of Transportation 800 Independence Avenue, SW. Washington, DC 20591 Tel.: (202) 267-3732 Subject: 49 CFR Parts 173, 175 and 178 [Docket No. RSPA-04-17664 (HM-2248)] RIN 2137-AD33 Dear Sirs: Over the last week, I've tried calling you a few times and am getting no response to our voicemail messages. Our company is a fire testing laboratory. The subject document references a flame penetration resistance test and a thermal resistance test. Our question: Are both tests required or does the user have the option of using either one? Cc: Douglas Lipp I'#