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.”

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Fire Hazard: B/E Protective Breathing Equipment (PBE), P/N 119003-11

The FAA has revised a proposed Airworthiness Directive (AD) for the B/E Aerospace protective breathing equipment (PBE) part number 119003-11.

This AD is in the NPRM stage. This means that it is a proposal – not yet a regulation – but that the FAA intends to issue a final regulation related to this article. A previous NPRM required inspection of the units, but it appears that the FAA has decided that inspection is insufficient; the FAA has changed its remedy to inspection and replacement of units that fail inspection.

The FAA reports that there have been incidents of fires when the PBEs were activated.  Problems with these PBEs have been reported in the past, and B/E Aerospace issued Service Bulletin 119003-35-5 (April 19 2010) addressed certain PBE problems in this part number (but only for a limited range of serial numbers).  Note that the current proposed AD would affect all serial numbers.

The newly issued NPRM would supersede a 2011 final AD against a limited number of serial numbers of the same units. That AD required inspection of the units.  A June 2015 NPRM would have required inspection of all units (regardless of serial number) but the FAA has decided that the inspection instruction (alone) is inadequate.  This AD is being issued as a supplemental NPRM (in addition to the June 2015 NPRM) in order to permit comments due to the burden being changed; but it is very likely that this will go to final rule.  In 2011,the FAA received comments opposing the original AD and implemented it anyway, explaining that there was an safety danger.

If an operator has a faulty unit, then the FAA has directed that they replace it with either B/E Aerospace P/N 119003-21 or any other serviceable, FAA-approved, PBE.

Distributors should take two different messages from this NPRM:

  • First, if you have these units in stock, you should consider how best to safely disposition them.  Remember, PBEs are class five hazardous materials (oxidizers).  You should only be shipping them if you are properly trained under the regulations.
  • Second, operators who may have inspected the limited run of serial numbers in 2011 (pursuant to the original AD) and then retained them in service will need replacements when the AD becomes final.  In addition, operators who have units of all serial numbers may require replacements.  This could be a sales opportunity for some distributors!

 

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