Interpretation Response #02-0146 ([James W. Stoddard])

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

Interpretation Response Details

Response Publish Date: 10/18/2002

Company Name:

Individual Name: James W. Stoddard

Location State: TX Country: US

View the Interpretation Document

Response text:

Oct 18, 2002

Mr. James W. Stoddard                   Reference No. 02-0146
613 Andover Lane
Coppell, TX-75019-2858

Dear Mr. Stoddard:

This is in response to your letter dated May 6, 2002 concerning air carriers' reluctancy to transport your Coleman propane camping stove that you use to participate in chili cook-off competitions. You state that you never check the propane cylinders or carry matches, torches, etc.

Under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180), propane is regulated as a Division 2.1 (Flammable gas). This material is Forbidden to be offered for transportation or transported by passenger aircraft and passenger rail. However 173.29 states that empty packagings that meet certain provisions are not subject to the requirements of the HMR.

In the case of a propane stove, any internal reservoir areas and piping must be properly cleaned of residue and purged of vapors to remove any potential hazard to be considered as not regulated under the HMR. The methods and limits used for determining what qualifies as "cleaned and purged" under the HMR are intentionally not defined because they vary greatly depending on the properties of the particular hazardous material and type of packaging. In the case of propane, other variables such as purge medium, temperature conditions and internal volume are also factors. We would consider a stove to be sufficiently cleaned and purged when the vapors in any reservoir areas and piping are no longer capable of sustaining combustion. When a properly cleaned and purged propane container is offered for transportation by aircraft, the valve must be left open to preclude internal pressure buildup.

Air carriers of hazardous materials are subject to the applicable requirements of the HMR. The HMR specify conditions and constraints for offering and transporting hazardous materials in commerce. However, we have no authority to compel such transportation. Air carriers may establish their own non-conflicting internal policies and practices for accepting hazardous materials for transportation.

I hope this information is helpful.

Sincerely,

Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards

173.29

Regulation Sections