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Interpretation Response #09-0221

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

Interpretation Response Details

Response Publish Date: 02-05-2010
Company Name: The Council on Safe Transportation of Hazardous Articles, Inc.    Individual Name: Mr. Tom Ferguson
Location state: VA    Country: US

View the Interpretation Document

Response text:

February 5, 2010




Mr. Tom Ferguson
Technical Consultant
The Council on Safe Transportation
of Hazardous Articles, Inc.
7803 Hill House Court
Fairfax Station, VA 22039

Ref. No.: 09-0221

Dear Mr. Ferguson:

This responds to your September 24, 2009 letter regarding requirements for oxidizers and compressed oxygen when cylinders are transported by air under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171.180). Specifically, you ask whether oxygen cylinders transported by an airline for use by cabin crews in the event of smoke or depressurization in the cabin are eligible for the exceptions provided in § 175.501(e).

The answer is no. Section 175.501(e) applies only to medical-use compressed oxygen that is either owned or leased by the air carrier for passenger use during flights or offered for transportation by a passenger needing it for personal medical use at a destination. Oxygen cylinders transported by an airline to be used in the event of an emergency on board the aircraft must be transported in accordance with the requirements in § 175.8(a) regarding airworthiness and items of replacement (company material (COMAT)).

I trust this satisfies your inquiry. 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
§ 175.8 Exceptions for operator equipment and items of replacement