Interpretation Response #12-0147 ([The Govmark Organization, Inc.] [Mr. Salvatore Messina])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: The Govmark Organization, Inc.
Individual Name: Mr. Salvatore Messina
Location State: NY Country: US
View the Interpretation Document
Response text:
October 1, 2012
Mr. Salvatore Messina
The Govmark Organization, Inc.
96 Allen Boulevard, Suite D
Farmingdale, NY 11735-5626, USA
Ref. No. 12-0147
Dear Mr. Messina:
This responds to your July 2, 2012 request for clarification on testing requirements for cylinders under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You state in your letter that your company is a fire testing laboratory. Specifically, you ask if both the flame penetration resistance and thermal resistance tests specified in § 173.302(f) are required for compressed oxygen and oxidizing gases transported by aircraft.
The answer is yes. In accordance with § 173.302(f), both the flame penetration resistance and thermal resistance tests specified are required for compressed oxygen and oxidizing gas transported by aircraft. Specifically, the cylinder must be placed in a rigid outer packaging that is capable of passing the Flame Penetration Resistance Test in Appendix E to part 178. The cylinder and the outer packaging must be capable of passing the Thermal Resistance Test specified in Appendix D to part 178.
For your information, in accordance with § 173.302(f)(6), a cylinder of compressed oxygen furnished by an aircraft operator to a passenger in accordance with 14 CFR §§ 121.574, 125.219, or 135.91 is excepted from the outer packaging requirements of paragraph (f)(3)of this section.
I hope this answers your inquiry. If you need additional assistance, please contact this office at (202) 366-8553.
Sincerely,
Robert Benedict
Chief, Standards Development Branch
Standards and Rulemaking Division
173.302