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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #00-0028 ([Trans World Airlines, Inc.] [Mr. Les Adolph])

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

Interpretation Response Details

Response Publish Date:

Company Name: Trans World Airlines, Inc.

Individual Name: Mr. Les Adolph

Location State: MO Country: US

View the Interpretation Document

Response text:

February 18, 2000

Mr. Les Adolph                Ref.; No. 00-0028

Sr Manager-Hazardous Materials Transportation Programs

Trans World Airlines, Inc.

9200 N.W. 112th Street

P.O. Box 20126

Kansas City, MO 64195

Dear Mr. Adolph:

This is in response to your letter dated January 17, 2000, regarding the proper shipping description for crew member personal breathing equipment (PBE) manufactured by Essex PB&R Corporation.  Specifically, you ask if the proper shipping description for the PBE described in your letter is "Life­saving appliance, not self-inflating, 9, UN3072."

Under 49 CFR 173.22, it is the shipper's responsibility to properly describe a material in accordance with Parts 172 and 173.  Such determinations are not required to be verified by this Office.  In your letter, you describe a PBE which contains two small compressed oxygen cylinders, each having a volumetric capacity of approximately 3.3 ounces, and approximately 0.2 kilograms of lithium hydroxide, and otherwise complies with the conditions and limitations of § 173.219. We agree that the proper shipping name for this article is "Life-saving appliance, not self-inflating, 9, UN3072." In addition, it is our opinion that the limitations in § 175.85(I)(1) and (2) which limit the number of cylinders of compressed oxygen in certain cargo compartments do not apply to articles which may be described as "Life-saving appliance, not self-inflating."

I trust this information is of use to you.  If we can be of further assistance, please contact us.


Edward T. Mazzullo

Director, Office of Hazardous Materials Standards


Regulation Sections

Section Subject
175.75 Quantity limitations and cargo location