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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 #00-0188 ([Morgan Schaffer System] [Mr. Eric Valentine])

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

Interpretation Response Details

Response Publish Date:

Company Name: Morgan Schaffer System

Individual Name: Mr. Eric Valentine

Country: CA

View the Interpretation Document

Response text:

October 13, 2000

Mr. Eric Valentine                Reference No. 00-0188

Customer Support & Training

Morgan Schaffer System

5110 Courtrai Avenue

Montreal, Quebec


Dear Mr. Valentine:

This is in response to your June 6, 2000 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they relate to the domestic and international transportation of gas analytical instruments, identified as a TFGA-P200 Portable Fault Gas Analyzer and a PHA-1000 Portable Hydrogen Analyzer, by passenger aircraft. You state that a DOT 3EI800 cylinder with a capacity of 300 ml is installed inside the instrument housing.  The instrument and a DOT 413240 cylinder with a capacity of 900 ml are packed in an outer packaging.  Your questions are paraphrased and answered in the order posed in your letter.

Questions:      May the package containing the instrument and cylinders be offered for transportation by passenger aircraft if the DOT 3EI 800 cylinder is filled with helium and the DOT 4B240 cylinder is filled with a mixture of 98.6% air and 0.2% each of hydrogen, methane, ethane, ethylene, acetylene, carbon dioxide and carbon monoxide?  Similarly, may the package be offered for transportation by passenger aircraft if the DOT-3EI 800 cylinder is filled with nitrogen and the DOT 413240 cylinder is filled with a mixture of 99% air and 1% hydrogen?

Answer:       The answer to both questions is yes.  A DOT 3E cylinder is authorized for helium and nitrogen by §173.302. A DOT 4B cylinder is authorized for a nonflammable compressed gas mixture by §173.302 (a).  When offered for transportation, the valve on the DOT 3E cylinder installed inside the instrument must be tightly closed.  See § 173.27, 173.34 and 173.3

The package must be declared as a hazardous material shipment.  Helium, nitrogen and the described gas mixtures would be classified as Division 2.2 (nonflammable gas).  The §172.101 Hazardous Materials Table authorizes a maximum net weight, in one package, of a Division 2.2 material of up to 75 kg for transportation by passenger aircraft.  Each package must be labeled with a Division 2.2 label and properly marked with the proper shipping name and identification number of the hazardous materials as required by §172.400 and 172.301 respectively.

 In addition, each shipment must be accompanied by a shipping paper containing a shipper's certification that the hazardous materials have been properly described, packed, marked, labeled and are in proper condition for transportation.  See 49 CFRI72.202 and 172.204.

I hope this information is helpful.  I have also enclosed some informational material on the HMR.  Please contact us if we can be of further assistance.


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table