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Interpretation Response #10-0089 ([Essex Cryogenics of Missouri, Inc.] [Mr. Ken Seise])

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

Interpretation Response Details

Response Publish Date:

Company Name: Essex Cryogenics of Missouri, Inc.

Individual Name: Mr. Ken Seise

Location State: MO Country: US

View the Interpretation Document

Response text:

June 25, 2010




Mr. Ken Seise

Quality Assurance/

Regulatory Compliance Manager

Essex Cryogenics of Missouri, Inc.

8007 Chivvis Drive

St. Louis, MO 63123-2395

Ref. No. 10-0089

Dear Mr. Seise:

This is in reference to your email requesting a clarification of the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to an oxygen converter that is part of a component permanently installed in ambulances and other emergency response vehicles. You state the converter encompasses a 10 - 25 liter non-DOT specification liquid oxygen cylinder.

According to the design and construction specifications you submitted (Federal Specification for the Star-of-Life Ambulance, KKK-A-1822E, General Services Administration, June 1, 2002), the cylinder is to be installed at the time the vehicle is placed in service. A cylinder installed in a motor vehicle as part of equipment necessary for the safety of its operator or passengers is not subject to the HMR requirements but may be subject to the requirements of other Federal, State or local agencies. Also the filled cylinder would be subject to the HMR if it is removed from the vehicle and offered for transportation in commerce.

I hope this information is helpful. If you need further assistance, please do not hesitate to contact us.


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
171.1 Applicability of Hazardous Materials Regulations (HMR) to persons and functions