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Interpretation Response #11-0290 ([Department of the Army] [Ms. Sarah Gedrich])

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

Interpretation Response Details

Response Publish Date:

Company Name: Department of the Army

Individual Name: Ms. Sarah Gedrich

Location State: PA Country: US

View the Interpretation Document

Response text:

February 8, 2012



Ms. Sarah Gedrich
Chief, LOGSA Packaging, Storage, and Containerization
Center (AMXLS-AT-L)
Department of the Army
11 Hap Arnold Boulevard
Tobyhanna, PA 18466-5097

Ref. No. 11-0290

Dear Ms. Gedrich:
This responds to your October 12, 2011 letter requesting clarification of the preparation of composite or combination packaging containing compressed oxygen and other oxidizing gases in cylinders or chemical oxygen generators for testing under the Hazardous Materials Regulations (HMR; 49 CFR Part 171-180). In general terms, these articles are required to be placed in a rigid outer packaging that conforms to the testing provisions in Part 178, Subpart M of the HMR or the performance criteria of Airlines for America (A4A), formerly the Air Transport Association of America, Inc. (ATA), Specification No. 300 for a Category I shipping container. See §§ 173.168(d) and 173.302(f)(3). You specifically request clarification of the preparation of packaging for testing.

Your questions are paraphrased and answered in a single response as follows, however, we note that the guidance offered relative to A4A Specification No. 300 is the opinion of this Office and we recommend that you contact A4A for further guidance:

Q. Should the testing be conducted with the cylinder and chemical oxygen generator empty? If so, how are we to account for the weight of the material in a filled cylinder or chemical oxygen generator?

A. Yes. Additives similar to the instruction provided in § 178.602(c) of the HMR can be used to compensate for the weight of the hazardous contents.

I hope this answers your inquiry. If you need additional assistance, please contact this Office at (202) 366-8553.



Ben Supko
Acting Chief, Standards Development Branch
Standards and Rulemaking Division

173.168(d), 173.302(f)(3), 178.602(c)

Regulation Sections

Section Subject
173.168 Chemical oxygen generators
173.302 Filling of cylinders with nonliquefied (permanent) compressed gases or adsorbed gases
178.602 Preparation of packagings and packages for testing