Bombardier (Aerospace) — Hazardous Materials Safety Interpretation

Page 1U.S. Department 1200 New Jersey Avenue SE of Transportation Washington. DC 20590 Pipeline and Hazardous Materials Safety AUG 1 9 2015 Administration Jeff Christafore Dangerous Goods Compliance Specialist Bombardier (Aerospace) 2400 Aviation Way Bridgeport, WV 26330 Ref. No. 15-0041 Dear Mr. Christafore: This responds to your March 3, 2015. e-mail requesting clarification on the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to life-saving appliances. In your e-mail, you describe a small cylinder carrying "UN1072, Oxygen, compressed," a Division 2.2 compressed gas, which you have suggested could be incorporated in an "oxygen box assembly" for purposes of use on a passenger aircraft, and subsequently re- classified as "UN3072, Life-saving appliances, not self-inflating," a Class 9 hazardous material. You have also provided a schematic diagram of the assembly. Your questions are paraphrased and answered as follows. Q1. Can compressed oxygen contained in a cylinder manufactured according to DOT-SP 14399 and incorporated in the above described assembly be re-classified as "UN3072, Life- saving appliances, not self-inflating"? Al. Under § 173.22, it is the shipper's responsibility to classify a hazardous material. This Office does not normally perform this function. However, based on the information provided, it is the opinion of this Office that the assembly could be re-classified as "UN3072, Life-saving appliances, not self-inflating" provided that the assembly as configured during transportation is intended to perform a life-saving function. Q2. You state that the cylinder, which would form part of the life-saving appliance, is manufactured according to a special permit (i.e., DOT-SP 14399). Is the shipper required to identify the special permit on the outer package and prepare copies of the special permit for the carrier? A2. Yes. Section 172.301(c) requires the outside of each package authorized by a special permit to be durably marked "DOT-SP" followed by the special permit number assigned. The special permit in question does not waive this requirement. In addition, under § 173.22a(c), "...the offeror shall furnish a copy of the current exemption or special permit to the carrier before or at the time a shipment is tendered." Further, in DOT-SP 14399, paragraph 10, modal requirements, states, "A current copy of this special permit must be carried aboard each cargo vessel, aircraft or motor vehicle used to transport packages#

Page 2covered by this special permit. The shipper must furnish a copy of this special permit to the air carrier before or at the time the shipment is tendered." Compressed oxygen contained in a cylinder manufactured according to DOT-SP 14399 would need to comply with the provisions under § 173.302(f)(3), (4), and (5) (Thermal Resistance Test, Flame Penetration Test, and marking requirements) when transported by aircraft. If a DOT-SP 14399 cylinder containing compressed oxygen is re-classed as "UN3072, Life-saving appliances, not self-inflating," it would still be required to comply with § 173.302(f)(3), (4), and (5) as the requirements in § 173.219(b)(1) provide that "Division 2.2 compressed or liquefied gases must be packed in cylinders in accordance with the requirements of this subchapter [C]" I hope this answers your inquiry. If you need additional assistance, please contact this Office again. Sincerely Dirk Der Kinderen Acting Chief, Standards Development Branch Standards and Rulemaking Division#

Page 3Lesto 5173. 219 Life saver; appliances Dodd, Alice (PHMSA) 15-0041 From: Ciccarone, Michael CTR (PHMSA) Sent: Tuesday, March 03, 2015 4:07 PM To: Hazmat Interps Subject: FW: Letter of Interpretation Requested Attachments: 20141216_150627 jpg; 20141216_150534 jpg; 20141216_150613.jpg; DOC.PDF Shante/Alice, Please submit this for a formal letter of interpretation. Mr. Christafore spoke with Shelby in the HMIC. Thanks, Mike From: Jeff Christafore [mailto: jeff.christafore@aero.bombardier.coml Sent: Tuesday, March 03, 2015 11:59 AM To: PHMSA HM InfoCenter Subject: Letter of Interpretation Requested Good afternoon, I am in need of some assistance with the possible reclassification of a part. I know that your office does not provide classifications, but I was hoping that some guidance could be provided. I have reviewed some other interpretations, but DOT Interpretation Ref No. 00-0028 provided for Essex PB&R Corporation seems to be the most relevant. We are currently required to ship small Oxygen, compressed cylinders to customers worldwide. • The dimensions of the bottle are 9.2" L x 2.75" D • They are used on aircraft to supply emergency oxygen to passengers in the lavatory and are being used to replace oxygen generators that were previously installed. • These cylinders are manufactured under DOT-SP 14399, which is basically a DOT-39 cylinder with some exceptions. • When this cylinder is sent separately it is classified as UN1072 Oxygen, compressed. 1. I need to determine, if the same cylinder is attached to a panel, can be reclassified as UN3072 Life-saving appliances, not self-inflating. (Pictures attached) 2. Also, if acceptable to reclassify as UN3072, since the cylinder is manufactured under a special permit, is there still a need to identify the DOT-SP 14399 on the outer package and paperwork as required by the regulations? (UN3072 is not currently an allowable proper shipping name under the terms of the special permit) Per my understanding there are other life-saving appliances with attached special permit cylinders that are not required to have the special permit identified. 49CFR 173.219 for Life-saving appliances, allows them to contain 2.2 compressed gases packaged in cylinders that are an integral part of the appliance and the only reference to size is that the quantities don't exceed those appropriate for the actual appliance when in use. In addition to the pictures referenced above, I have also attached details and drawings for the part. 1#

Page 4I would greatly appreciate any assistance you can provide. Thank you and have a great day! Jeff Christafore Aerospace Dangerous Goods Compliance Specialist jeff.christafore@aero.bombardier.com 2400 Aviation Way Bridgeport, WV 26330 Office: Mobile: 304-975-4229 304-848-5202 BOMBARDIER the evolution of mobility If you are not the intended recipient or received this communication by error, please notify the sender CONFIDENTIALITY NOTICE - This communication may contain privileged or confidential information. and delete the message without copying, forwarding and/or disclosing it. 2#

Page 5CID Number 890201602581 of 1 7066213 Serial Number Page REGIONAL JET 200 siB: 3868303-25-A-OZ 2015/01/14 Production order num Expiry Date Mode1 Alt Item <+D Issued ety Authorized Parts list Kit Qty Cage Code 56135 REV NC KIT, OXYGEN DISPENSING ASSEMBLY 601R35-020K350 890101608500 SB 601r-35-020 Description KIT, LAVATORY SB BOMBARDIER Rit Description CID Number for Kit Kit number Part number Expiry Revision#

Page 6ZODIAC CABIN INTERIORS C&D ZODIAC AEROSPACE SERVICE BULLETIN H. ELECTRICAL LOAD DATA Not affected. I. REFERENCES The following documents were used as data sources in preparation of this Service Bulletin: References Table 1 Document N° Title CDK386-30 Lavatory - SB Kit 115082-01 Oxygen Box Assembly 115R82-02 Oxygen Box Assembly 3868303-101 Oxygen Box Assembly 9326246 Mask Packing Instruction (AD) 2012-11-09 FAA Airworthiness Directive CDR3868-8-1 Qualification Test Plan CDR3868-8-11 Qualification Test Results CDR458.2-2 Fire Properties Similarity Report CF-2011-03R2 TC Airworthiness Directive J. PUBLICATIONS AFFECTED Component Maintenance Manual (CMM) 53-10-03. 2. MATERIAL INFORMATION A. MATERIAL - PRICE AND AVAILABILITY Refer to Bombardier Aerospace Service Bulletin for terms and conditions. B. MATERIAL NECESSARY FOR EACH SPARE The parts required to modify one oxygen box assembly are included in Kit: 100K386-30% Lavatory - SB Kit Table 2 New PN Description Qty Disposition CDPL604-1-3868303-25-A-02 SB Incorporation Placard Install New 386830361013 Oxygen Box Assembly 01 Install New Initial Issue : Jul 04/14 Revision 0 : Jul 04/14 3868303-25-A-02 Page 2 of 12#

Page 7TA 12 SEE SEPARATE PARTS UST OXYGEN BOX ASSEMBLY ROTOONE 58135 3868303-101 CICE 20 19--11 020 C. USE B ONICA! 2 PL 4.3 SEE PARTS LIST SEE PARTS LIST NO NOT SCALE ON CAMPING DOOR ASSEMBLY 2 PL CA.121X LEED CH APPLICATION 3802317.1 9326240-3 001844332 • 03 AVE) (2)- © MASK 12 -D/A ID PLACARO APPROX LOCATION HEWPA... 3880303-10: A41 A-/ VIEW SHOWN WITHOUT DOOR /(iS) TABLE 1 REPLACEMENE PINS TOR 3806301/3008302 ASSLMBIIES OLD PIN 3908301-101 3868301-103 3368302-101. MASK #1 HOSE MASK #2#

Page 8CID Number 890101605345 890101319180 890101564955 of 1 7065172 Serial Number Page 1 REGIONAL JET 200 2015/01/12 Production order num Expiry Date Model Alt Item Issued ety Authorized Parts list Kit lty Cage Code 56135 80205 80205 REV NC KIT, OXYGEN DISPENSING ASSEMBLY 601R35-020K1 890101606788 SB 601r35-020 Description WASHER, FLAT, REDUCED OD BOX ASSY, OXYGEN SCREW, PAN HD BOMBARDIER Kit Description CID Number for Kit Kit number Part number Expiry Revision 3868303C101 MS35206-230 NAS620-6#

Page 9• SERVICE BULLETIN 601R-35-020 3. MATERIAL INFORMATION A. Kit Information For Aircraft 7003 thru 7067, 7069 thru 7074, 7076 thru 7098, 7100 thru 7135, 7137 thru 7139, 7141 thru 7151, 7153 thru 7175, 7177 thru 7350, 7352 thru 7390 Kit Contents: KIT 601R35-020K350 I PART NUMBER QTY NAME ALTERNATIVE NOTES CDK386-30 1 Oxygen Box Assembly Retrofit Kit - 3868303-25-A-02. I For a list of the kit contents, refer to C&D Zodiac Service Bulletin For Aircraft 7391 thru 7635, 7637 thru 7672, 7684, 7690, 7697, and 7704 Kit Contents: KIT 601R35-020K1 PART NUMBER QTY NAME ALTERNATIVE NOTES 386830301017 1 Oxygen Box Assembly MS35206-230 5 Screw NAS620-6 5 Washer B. Consumable Information For a list of consumables, refer to the C&D Zodiac service bulletin and to the different tasks that are given as references in this service bulletin. C. Special Tools and Equipment There are no special tools and equipment for this service bulletin. D. Disposition of Parts The table that follows shows the disposition of parts on the aircraft (or spares), and the relationship between these parts to the new parts to be installed during the incorporation of this service bulletin. Oct 30/2014 SB 601R-35-020 Page 16 of 17#

Page 109888303-101 SEE SEPARATE PARTS LIST OXYGEN BOX ASSEMBLY .... CAD ZODIAC CAN COUR 56135 1968303.101 20001 12203 S FULLER ! ZONE (11) настой O SEE PARTS LIST ST BADTO SIT winam DOOR ASSEMBLY PL CA.1200 APPLICATION 386×3:7.1 9326240-3 001844932 /NO (NiS 2 PL 2 MASK #2 2 pL ID PLACARD 1 APPROX LOCATION USU DIN 3868303-101 A 4 1 110(15) VIEW SHOWN WITHOUT DOOR TABLE 1 RLPLACEMENT PINS FOR J8C6301/8U0302 ASSEMBLIES OLD PIN 16A2301-101 3408301.100 ¿ REQD! unce MASK #1 HOSE MASK #2#

Page 116/1 62 63 6/4 65 6/6 J72 6/7 68 6/9 710 7/1 8 •40-0571 9 16 THS 11022704 josE#

Page 12OXYGEN SUPPLY REMOVE TO ARM RELEASE PIN AFTER INSERTING 11022704 10F25 Cisco sat Nig#

Page 136/1 62 6 3 6|4 6/5 6/6 40-0571 172 6/7 68 619 70 7/1 S SHI 91#