DANGEROUS GOODS PANEL (DGP)
TWENTY-SECOND MEETING
Montréal, 5 to 16 October 2009
Agenda Item 6: Other business
REQUIREMENTS FOR TRANSPORT OF OXYGEN, OXYGEN GENERATORS, AND
OXIDIZING GASES
(Presented by R. Richard)
SUMMARY
This paper updates the DGP on the implementation of changes to the
requirements for the transport of oxygen, oxygen generators, and oxidizing
gases when transported to, from, or within the United States.
The Panel is invited to share this information with affected parties involved in
the transport of such materials.
1. INTRODUCTION
1.1 During the 2007 DGP Working Group of the Whole Meeting (DGP-WG07, Memphis,
30 April to 4 May 2007), the working group considered DGP-WG/07-IP/7 – “Enhanced Requirements for Transport of Oxygen, Oxygen Generators, and Oxidizing Gases”. The paper summarized recent
enhancements to the requirements for the transport of such materials to, from, or within the United States.
1.2 In summary, the effect of the amendments to the U.S. Hazardous Materials Regulations
(see Docket No. RSPA–04–17664 (HM–224B)) were to:
a) require cylinders of compressed oxygen and other oxidizing gases and packages of
chemical oxygen generators to be placed in an outer packaging that meets certain
flame penetration and thermal resistance requirements when transported aboard an
aircraft. In order to meet these requirements, the cylinder must be placed in a rigid
outer packaging that is capable of passing, as demonstrated by design testing, a
specified Flame Penetration Resistance Test. In addition, the cylinder and the outer
packaging must be capable of passing, as demonstrated by design testing, a specified
Thermal Resistance Test.
b) revise the pressure relief device setting limit on cylinders of compressed oxygen and
other oxidizing gases transported aboard aircraft; and
c) limit the types of cylinders authorized for transporting compressed oxygen aboard
aircraft to DOT specification 3A, 3AA, 3AL, and 3HT cylinders, and UN pressure
receptacles conforming to ISO specifications 9809–1, 9809–2, 9809–3 and 7866.
1.3 Currently, US Variation 18 broadly addresses these new requirements and brings them
into effect for the transport of such materials to, from, or within the United States. The purpose of this
information paper is to provide updated information to the Panel relevant to these changes, which came into effect fully on 1 October, 2009. We will be updating the US Variations to specifically state this
requirement in the next edition of the Technical Instructions. An advisory notice containing additional
information is attached in the Appendix to this IP.
APPENDIX
US DOT ADVISORY ALERT
Advisory Alert
June, 2009
Upcoming October 1, 2009 Compliance Date for Outer Packagings that Meet Certain
Flame Penetration and Thermal Resistance Requirements when Transported Aboard Aircraft
This advisory is intended to alert persons that after September 30, 2009, cylinders of compressed oxygen and other oxidizing gases and packages of chemical oxygen generators must be placed in outer packagings that meet certain flame penetration and thermal resistance requirements when transported aboard an aircraft.
PHMSA adopted the outer packaging requirement in a final rule developed in cooperation with the
Federal Aviation Administration and published January 31, 2007. We indicated in a subsequent
September 28, 2007 final rule that PHMSA and FAA planned to closely monitor the availability of the
required outer packagings and would consider an extension of the October 1, 2009 compliance date if we determine that a sufficient supply of the required outer packagings is not available. We have determined there are currently a sufficient number of packaging manufacturers available to supply the required outer packagings. Therefore, we are not extending the October 1, 2009 compliance date. After September 30, 2009, cylinders of compressed oxygen and other oxidizing gases and packages of chemical oxygen generators must be placed in rigid outer packagings that meet the specified flame penetration and thermal resistance requirements when transported aboard an aircraft and certain additional requirements.
A. For a cylinder containing compressed oxygen and other oxidizing gases intended for transportation by
aircraft, the following requirements apply:
1. The cylinder must be placed in a rigid outer packaging that is capable of passing, as demonstrated by
design testing, the Flame Penetration Resistance Test in Appendix E to 49 CFR Part 178.
2. The cylinder and the outer packaging must be capable of passing, as demonstrated by design testing,
the Thermal Resistance Test specified in Appendix D to 49 CFR Part 178.
3. The cylinder and the outer packaging must both be marked and labeled in accordance with Subparts D
and E of 49 CFR Part 172. The additional marking, “DOT31FP” is allowed to indicate that the cylinder
and the outer packaging are capable of passing, as demonstrated by design testing, the Thermal
Resistance Test.
4. Prior to each shipment, the package must be visually inspected to verify that all features of the
packaging are in good condition, including all latches, hinges, seams, and other features, and that the
packaging is free from perforations, cracks, dents, or other abrasions that may negatively affect the flame
penetration resistance and thermal resistance characteristics of the packaging.
5. A cylinder of compressed oxygen that has been 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 § 173.302.
B. For a chemical oxygen generator and a chemical oxygen generator installed in equipment and intended
for transportation by cargo-only aircraft, the following requirements apply:
1. The device must be placed in a rigid outer packaging that is capable of passing the Flame Penetration
Resistance Test in Appendix E to 49 CFR Part 178 and the Thermal Resistance Test specified in
Appendix D to 49 CFR Part 178.
2. None of the following conditions may occur when one generator in the package is actuated:
a. Actuation of other generators in the package;
b. Ignition of the packaging materials; and
c. A temperature above 100 °C (212 °F) on the outside surface temperature of the package.
3. All features of the packaging must be in good condition, including all latches, hinges, seams, and other
features, and the packaging must be free from perforations, cracks, dents, or other abrasions that may
negatively affect the flame penetration resistance and thermal resistance characteristics of the packaging, verified by a visual inspection of the package before each shipment.
The full text of the revised regulations can be found on the PHMSA website at:
