United Airlines — Hazardous Materials Safety Interpretation

Page 1J.S. Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590 Special Programs Research and Administration MAR 1 0 2000 Mr. Carl B. Kole Ref. No. 99-0294 Administrator, Dangerous Goods United Airlines Box 66100 Chicago, IL 60666 Dear Mr. Kole: This is in response to your letter of October 8, 1999, regarding the transportation of a cylinder of compressed oxygen for passenger use during flight. I am sorry for the delay in responding to your inquiry, I hope it has not caused you any inconvenience. Section 175.10(a)(7) excepts from the Hazardous Materials Regulations (HMR;49 CFR Part171-180) a cylinder of compressed oxygen for medical use by a passenger which is furnished by an aircraft operator in accordance with 14 CFR 121.574 or 135.91. In the scenario presented in your letter, an oxygen cylinder is installed in an aircraft for use by a passenger on a later flight segment. You ask if transportation of the cylinder prior to the segment on which it is used by the passenger is permitted. It is our opinion that this scenario is permitted under the provisions of 49 CFR 175.10(a)(7), if the requirements of 14 CFR 121.574 are met. The Federal Aviation Administration's Flight Standards Service has informed us that your scenario would comply with 14 CFR 121.574 if either of the following were satisfied: (1) the cylinder is installed with data approved by the Administrator of the Federal Aviation Administration; or (2) United Airlines has received a supplemental type certificate for the modification. This response has been coordinated with the Federal Aviation Administration. If we can be of further assistance, please contact us. Sincerely, Elal 7: Mall Edward T. Mazzullo Director, Office of Hazardous Materials Standards 990294 175.10#

Page 2оCT-08-99 12:30 PM P.01 W/ UNITED AIRLINES - October 8, 1999 World Headmartore Gate & 175.10 99-0294 October 8, 1999 Mr. Edward T. Mazzulio Director of Hazatdous Materials Standards Research and Special Programs Administration U.S. Department of Transportation 400 7th Street N.W. Room 8100 Washington, D.C. 20590-0001 Dear Mr. Mazzulio, SUBJECT: INTERPETATION OF HM 224A With the release of HIM 224A the issue of installed oxygen on board commercial aircraft for passenger use has come under discussion by the FAA and many of the carriers it regulates. United specifically has in the past had a process whereby a licensed mechanic has installed in our over-head bins oxygen cylinders for medical use of our passengers. This installation has complied with the requirements of both 14CFR 121.574 and those applicable provisions of 49CFR. With the release of the final rule HM 224A an issue has arisen which HM 224A does not address directly. While HM 224A talks about the Iransport in cargo of oxygen, it does not directly address oxygen that is installed for use by a passenger on a downline segment. The area of interpretasion we are requesting deals with the oxygen bottle which is installed at point A for use on a segment B to C. With the lack of maintenance personnel at many of our smaller communities we serve, it is a matter of practicality that a mechanic install the oxygen cylinder in the over-head bin meeting all of the applicable installation and tie down rules.. By so doing we are assured of a quality installation with an equivalent levcl of safety. We have always considered the installed bottle as part of the ship's equipment. The passenger then boards the flight and uses the bottle on the B-C segment. ADMINISTRATOX DANGEROUS GOODS UNITED AIRLINES WHQSY Bree sell, Chicago. Minis Collate, • Location: 1200 End Alecguin Rone. Elk Corone Toonship. Illinois G0000:#

Page 3Bes selen. Chicage Illinois allbo • Loscalion: 1200 ad AlcoRequin Rond. Elk Cross Tondipo Illinuis 600007 CONTINUE FROM PREVIOUS PAGE 001 After use, the bottle is then removed from the aircraft and is returned to a servicing station in the shipped as cargo mode packed in the ATA Specification 300 packaging. With that as a back ground my question is quite simple. Since we are not shipping installed part of the aircraft equipment for passenger use, are we in compliance with th herapeutic oxygen in cargo for replenishing a downline aircraft or station, but as ar intent of the HMR and HM 224A I look forward to your response and truly hope a favorable decision will forth coming so we may continue to service our passenger's needs in those smaller communities we serve. Sincerely. Mr. Carl B. Kole Administrator Dangcrous Goods United Airlines CK • .#