{"operation":"document","citation":"98-0258","title":"Cook Children's Medical Center — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1998-08-28","effective_on":null,"summary":"98-0258 response to Cook Children's Medical Center concerning 175.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0258.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0258.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0258","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1998/980258.pdf","body":"<<<PAGE 1>>>\n\nU.S.Department\nof Transportation\nResearch and\n20590\nSpecial Programs\nAUG 28 1998\nAdministration\nMr. Ray Crain\nRef. No. 98-0258\nTeddy Bear Transport\nCook Children's Medical Center\n13725 Stone Road\nBurleson, TX\n76028\nDear Mr. Crain:\nThis is in response to your letter of March 21, 1998,\nrequesting clarification of the Hazardous Materials Regulations\n(HMR; 49 CER parts 171-180) regarding the transportation of an\nincubator unit by aircraft. Specifically you request\nconfirmation that a compressed gas mixture containing 800 ppm\nof nitric oxide in nitrogen may be transported under the\nprovisions of § 175.10 (a) (14) •\nAs provided by § 175.10 (a) (14), a transport incubator unit\nnecessary to protect life transported by aircraft is not\nregulated under the HMR when: (1) the compressed gas used to\noperate the unit is in an authorized DOT specification cylinder\nwhich 1s marked, labeled, filled and maintained as prescribed\nby the HMR; (2) any batteries used in its operation are of the\nnon-spillable type; (3) the unit is constructed so that valves,\nin command is advised that the unit is onboard and when it is\nfittings, and gauges are protected from damage; (4) the pilot\nintended for use; (5) it is accompanied by a person qualified\nto operate it; (6) it is secured in the aircraft in a manner\nthat does not restrict access to or use of any required\nemergency or regular exit or of the aisle in the passenger\ncompartment;\nand (7)\nunit.\nthere is no smoking within ten feet of the\nA compressed gas mixture properly classed as Division 2.2 (non-\nflammable gas) is not regulated when transported by aircraft\nwhen the above conditions are met.\nIt is the opinion\n\n<<<PAGE 2>>>\n\npets\n-2-\nof this Office that a compressed gas mixture containing 800 pm\nof nitric oxide in nitrogen is properly classed as Division\n2.2. Therefore, you may transport the incubator unit as\ndescribed above.\nI hope this information is helpful.\nSincerely,\nThomas I. Aller\nThomas G. 'Allan\nSenior Transportation Specialist\nOffice of Hazardous Materials Standards\n:\n\n<<<PAGE 3>>>\n\nAUG-28-99\n09:41\nTeady Bear Transport\n817 447 3137\nP.ø2\n.\"\n801 Seventh Avenue\nTeddy Bear Transport\n817-886-5001\nFort Worth, Texas 76104-2790\nCookChildren's\nTwitty\n8175.10\nMarch 21, 1998\nDr. Richard Tarr\nU.S. D.O.T..\n400 7th Street, SW.\nWashington, D.C. 20590-0001\nDear Sir,\nTo follow up on our telephone conversion last Friday 3/20/98, enciosed are copies of my\ncorrespondence with DOT on the Nitric Oxide issue so far.\nIf you have found that we do not require an exemption to carry and administer NO on board our\naircraft, please send me a letter stating such with the reasons why. We need to provide\nlocumentation to the FAA and the part 135 Air Carrier who operates our aircraft. This will show\nthat we will not be in violation of any hazardous material regulations when we use this on board\nthe aircraft to treat some of our most critical Neo-Natal patients.\nIf you need any further information please call.\nSincerely,\n98-0258\nRay Crain, Base Manager\nTeddy Bear Transport\nCook Children's Medical Center\nSpinks Airport,\n13725 Stone Road,\nBurleson, IX 76028.\n(817) 447-2327 office\n(817) 447-3137 fax\nEnclosures\n\n<<<PAGE 4>>>\n\n...\nAUG-28-98 09:41 AM\n:\nTeady Bear Transport\n817 447 3137\nP.03\nTeddy Bear Transport\nFort Worth, Texas 76104-2790\n801 Seventh Avenue\n817-885-5001\ncookChildren's\nTo '\nWhom it may concern,\n12-23-96\nMy name is Frank Milano, manager of Respiratory Therapy for Cook Children's Teddy\nBear Transport, a critical care neonatal and pediatric transport tear in Fort Worth, Texas. I\nam writing you to obtain approval for our facility to transport using Nitric Oxide(NO), via air\nand ground medical transports.\nget to vital organs. The patients requiring this gas are very critical and need immediate\nattention due to failure of conventional treatments. Included, but not limited, are patients with\npersistent pulmonary hypertension, meconium aspiration, hyaline membrane disease and\ncongenital diaphragmatic hernia. These patients have the greatest risk of mortality unless\nintervened with immediately.\ncarrying NO in it's pure form. We will be carrying one tanksof dilutional NO containing\nNO, in it's pure form, is toxic and forbidden on moving vehicles. We will not be\n100\npim\n400ppm(parts per million) secured in a canister specially made and permanently secured to\nPc\nour isolette system. NO is also a common air pollutant and is present in concentrations of\n150-650ppm in cigarette smoke and up to 1200ppm in cigars and pipes. NO has been found\nto be produced in small quantities by our own bodies during inhalation.\nThe National Institute for Occupational Safety and Health and the Environmental\nProtection Agency have given a threshold limit value(TV) as a time weighted average(TWA)\nof 25ppm for NO. The TLV-TWA is the concentration to which a person may be exposed\ncontinuously throughout a normal work week without adverse effects. Our patients will be\nstarted on 20ppm and reach a max of 80ppm(if necessary) to achieve desired effects, although\nthe majority of babies will receive 20ppm or less.\nSome hazards to patients receiving NO are pulmonary toxicity and methemoglobinemia.\nPulmonary toxicity is associated with the conversion of NO to NO2(Nitric Dioxide). When\ncontamination of inspired gas has been carefully controlled, little evidence of toxicity exists at\nlow concentrations. Studies have clarified this by controlling contamination of inhaled NO by\nNO2. They report that when exposed to concentrations of 1000ppm for 30 minutes no\npulmonary toxicity or lung damage occurs. Methemoglobinemia levels were followed and no\nsignificant increases were observed in patients breathing 20, 40, 80ppm for 10 minute periods.\nCrew exposure would be very minimal. If a tank did suddenly empty into the air, it would\nbe desirable to dilute the concentration of NO by circulating as much air as possible, open\nwindows, turn on fans, etc. Other than this, little else would be medically necessary. Our\naircraft has a complete molecule change out every 30 minutes due to pressurization of the\ncabin, so crew exposure would be very minimal even if a tank did suddenly discharge. If this\nwould happen, the pressurization would be dropped, 02 masks discharged and put on,\nambient air analyzed, and patient care resumed. NO and NO2 analyzers will be on board for\ncontinuous monitoring. In air at room temperature, NO at a concentration of 400ppm will be\n50% oxidized to NO2 in 9 minutes, and at a concentration of 10ppm it will take almost 7hrs\nto become 50% oxidized to NO2.\n\n<<<PAGE 5>>>\n\n:AUG-28-98\n-мі'\n09:42\nTeady\nTransport\n817 447 3137\nP.04\nTeddy Bear Transport\nFort Worth, Toxas 76104-2798\n801 Seventh Avenue\n817-885-3901\nCookChildren's\nIf you have any questions please feel free to contact me, frank Milano, or our dick tog\nRAY CRAIN Bob Yeolker, at 1-800-544-3075. Thank you for your consideration. This will be a great\naccomplishment for Cook Children's Teddy Bear Transport.\nFrank Milano RN, RRI\nTransport rapist anagerT\nTeddy Bear Transport","truncated":false,"body_characters":7035}