Interpretation Response #10-0035 ([High Angle Construction, Inc.] [Mr. Eric Lieberman])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 07/01/2010

Company Name: High Angle Construction, Inc.

Individual Name: Mr. Eric Lieberman

Location State: CA Country: US

View the Interpretation Document

Response text:

July 1, 2010

Mr. Eric Lieberman

President

High Angle Construction, Inc.

11200 Donner Pass Road #126

Truckee, CA 96161

Ref. No. 10-0035

Dear Mr. Lieberman:

This responds to your letter regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to your helicopter-based avalanche mitigation company. Specifically, you ask whether the HMR apply to the Daisybell operation you describe that is used for avalanche control while suspended from a cargo-only helicopter. The Daisybell system utilizes two lead-acid batteries (24V) to power controlled explosions created by a compressed hydrogen and oxygen mixture. Gases are independently packaged in two hydrogen cylinders and one oxygen cylinder and are injected separately into an explosion chamber. The Daisybell system is activated while suspended 3-meters above the ground and the resulting explosion creates an overpressure of 80 millibars measured at ground level and for 12-meters horizontally.

Under the conditions set forth in § 175.9(f), the avalanche control operations you describe using the Daisybell system are not subject to the HMR. The operational guidelines and handling procedures manual specified in § 175.9(f)(2) is, however, subject to approval by the Federal Aviation Administration"s Principal Operations Inspector assigned to the operator.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.

Sincerely,

Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

175.9(f)

Regulation Sections