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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 #11-0287 ([USA Shooting] [Mr. Robert K. Mitchell])

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

Interpretation Response Details

Response Publish Date:

Company Name: USA Shooting

Individual Name: Mr. Robert K. Mitchell

Location State: CO Country: US

View the Interpretation Document

Response text:

January 26, 2012



Mr. Robert K. Mitchell
Executive Director " Chief Executive Officer
USA Shooting
1 Olympic Plaza
Colorado Springs, CO 80909

Reference No.: 11-0287

Dear Mr. Mitchell:

This is in response to your November 16, 2011 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they pertain to the commercial air transport of compressed air gun cylinders. Specifically, you ask whether these cylinders when uncharged and unpressurized are regulated as a hazardous material under the HMR.
The air cylinders as described are not regulated as a hazardous material under the HMR provided they are uncharged, unpressurized, and contain only air. In addition, the cylinders cannot contain any flammable or toxic gas, or other regulated material.

Section 173.115(b) of the HMR defines Division 2.2 (non-flammable, non poisonous compressed gas) as any material which exerts in the package a gauge pressure of 200 kPa (29.0 psig/43.8 psia) or greater at 20 °C (68 °F), is a liquefied gas, or is a cryogenic liquid; and does not meet the definition of the Division 2.1 (flammable gas) or Division 2.3 (gas poisonous by inhalation). The uncharged, unpressurized air gun cylinders do not meet these criteria and are therefore not regulated.

For international transportation, the International Civil Aviation Organization's Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions), Transport Canada's Transportation of Dangerous Goods Regulations (Transport Canada TDG Regulations), and the United Nations Recommendations on the Transport of Dangerous Goods: Model Regulations are consistent and also do not consider such uncharged and unpressurized cylinders as dangerous goods (hazardous materials).

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


Charles E. Betts
Standards and Rulemaking Division


Regulation Sections

Section Subject
173.115 Class 2, Divisions 2.1, 2.2, and 2.3-Definitions