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Interpretation Response #10-0215 ([Pimpelmees 3] [Mr. Gilbert de Chauvigny de Blot])

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

Interpretation Response Details

Response Publish Date:

Company Name: Pimpelmees 3

Individual Name: Mr. Gilbert de Chauvigny de Blot

Country: NL

View the Interpretation Document

Response text:

November 30, 2010




Mr. Gilbert de Chauvigny de Blot

I4Safety B.V.

Pimpelmees 3

1423 NX Uithoorn

The Netherlands

Ref. No.: 10-0215

Dear Mr. Chauvigny de Blot:

This responds to your October 8, 2010 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for clarification of the regulations pertaining to the packaging for transportation of oxygen cylinders and chemical oxygen generators by cargo only aircraft. Your questions are paraphrased and answered as follows:

Q1) If an outer packaging for an oxygen cylinder is successfully tested in accordance with the "Thermal Resistance Test," specified in Appendix D to Part 178 of the HMR, would it be a compliant outer packaging for oxygen cylinders under the HMR?

A1) Yes, provided: both the cylinder and the outer packaging are capable of passing both the Flame Penetration Test (Appendix E to part 178; attached) and Thermal Resistance Test (Appendix D to part 178; attached); the outer packaging conforms to the requirements of either part 178, subparts L and M at the packing group I or II performance level, or the performance criteria in Air Transport Association (Air Transport Association) Specification No. 300 for a Category I Shipping Container (ATA 300); prior to each shipment, the outer packaging passes a visual examination to ensure that the packaging and its features (i.e., latches, hinges, seams, and other features) are in good condition; and the packaging and its contents otherwise satisfy the requirements in § 173.302(f) (attached).

Q2) If an outer packaging for a chemical oxygen generator is successfully tested in accordance with the "Thermal Resistance Test," specified in Appendix D to Part 178 of the HMR, would it be a compliant outer packaging for oxygen cylinders under the HMR?

A2) Yes, provided the packaging and its contents meet the conditions described in A1 and otherwise satisfy the requirements of § 173.168 (attached).

Q3) How are the drop test requirements for ATA Specification No. 300 for Category I Shipping Containers different than the drop tests for non-bulk performance oriented packagings under the UN Recommendations on the Transport of Dangerous Goods - Model Regulations (UN Recommendations)?

A4) There are several differences, some of which are provided below. ATA 300 requires a series of drops to be conducted on the face, edge, and corner of the prototype package and at least one other container of that design selected at random from the first production lot. The drop test requirements in § 173.603, which are harmonized with the UN Recommendations, require the drop test to be conducted on five samples for a box: flat on bottom; flat on top; flat on long side; flat on short side; and, on a corner. Under ATA 300, the drop height and number of drops conducted on the packaging are dependent upon the gross weight of the package and the dimensions of the outer packaging. Under § 173.603, the drop height is a minimum of 1.8 meters for packing group I packages and 1.2 meters for packing group II packages and is not a function of package weight. We recommend you review ATA 300 for more specific details regarding the drop test requirements and how they differ from drop test criteria under the UN Recommendations.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.


Ben Supko

Acting Chief, Standards Development

Office of Hazardous Materials Standards


178. Appendix D, 173.603.173.302(f)

Regulation Sections

Section Subject
173.168 Chemical oxygen generators
173.302 Filling of cylinders with nonliquefied (permanent) compressed gases or adsorbed gases