Shipping PBEs: They Aren’t Always Chemical Oxygen Generators

A member identified to us a new type of Protective Breathing Equipment (PBE) and sent us a copy of the Safety Data Sheet (SDS).  The member was confused because the manufacturer classified the unit as UN3072 (life saving equipment) and not the usual UN3356 (chemical oxygen generator).  The U.S. Regulations affirmatively recognize that PBEs may contain chemical oxygen generators (49 C.F.R. 172.101 – Table Entry for “oxygen generator, chemical”).

The member frequently ships smoke hoods and PBE’S as ‘’CARGO AIRCRAFT ONLY’’ and is used to seeing them designated as UN3356.  He asked whether it is OK (under US law) to ship the PBE as UN3072 (as per the manufacturer’s SDS).

The US regulations permit classification of a unit that will be shipped by air according to ICAO Technical Standards.  49 C.F.R. 171.24.  These are republished in the IATA Dangerous Goods regulations book.

It is important to look at the actual composition of the unit in order to classify it the right way.  For clarity, oxygen generators are defined in Appendix A (the glossary) of the ICAO Technical Instructions.  The definition explains that this proper shipping name reflects “[a] device containing chemicals which upon activation releases oxygen as a product of chemical reaction.”  Typically such devices have an oxidizing salt (like a peroxide or a perchlorate) that releases both heat and oxygen when mixed with one or more other chemicals in the oxygen generator.

UN 3356 is the UN number for “chemical oxygen generators.”  Many PBEs use chemical oxygen generators to efficiently produce oxygen for the unit.  So it is natural to assume that a PBE would include an oxygen generator.  However, an oxygen generator is not necessary in a PBE – in fact FAA TSO C116A describes the oxygen generator as an acceptable alternative to an oxygen tank.   So it is possible to have a PBE that does not include a chemical oxygen generators.

In this case, the SDS made it clear that the PBE used compressed oxygen gas as the mechanism for delivering oxygen.  This means that there is a tank of oxygen, which is a compressed gas regulated as a class two hazardous material (and a class five oxidizer).  based on the SDS information, it was clear that the unit was appropriately described under UN 3072 (“life saving appliances, not self inflating”).

One important note – under US regulations (49 C.F.R. 171.24), if you ship any package containing compressed oxygen, you are subject to the “superpack” requirements – this means that the outer packaging must resist thermal and flame penetration according to the standards published at 49 C.F.R. Part 178 appendices D and E.  That holds true even if shipped under the proper shipping name “life saving appliances, not self inflating.”


About Jason Dickstein
Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. Since 1992, he has represented aviation trade associations and businesses that include aircraft and aircraft parts manufacturers, distributors, and repair stations, as well as both commercial and private operators.

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