ASA Member Bulletin - June 2019 - Shipping an "As Removed" Oxygen Generator

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Recently, an Association member asked us whether one is allowed to ship “As Removed” oxygen generators.

An “As Removed” oxygen generator can be expended or unexpended. A critical distinction for oxygen generators is whether they have been expended (this is the real question – not whether they are “as removed”).  An expended oxygen generator is typically forbidden from transportation on an aircraft but is permitted to be shipped by highway, rail or maritime transportation.  49 C.F.R. § 173.168(f)(2)(ii).

Oxygen generator typically have a manufacturer’s expiration date printed on them. It is also illegal to ship an oxygen generator by air after the manufacturer’s expiration date. 49 C.F.R. § 173.168(f)(2)(i).

In the United States, an unexpended oxygen generator (assuming it was unused, undamaged, and prior to the manufacturer’s expiration date) would be eligible for transport by air consistent with section 173.168.  This is true even when the oxygen generator has been removed from an aircraft.  A similar rule applies to international transportation subject to the ICAO rules – the ICAO standards forbid transport by air of oxygen generator that are unserviceable, have been expended (“used”) or have passed the manufacturer’s expiration date.  ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air, Special Condition A111.

Even when an oxygen generator is permitted to be shipped by air, it is typically limited to ‘cargo aircraft only’ configurations – you can only ship an oxygen generator by passenger aircraft if you receive a special permit that allows this unusual configuration.

If you have an oxygen generator that cannot be shipped by air because of its configuration (e.g. expended, unserviceable, beyond manufacturer’s expiration date, etc.) then you should be looking at ground, rail or maritime transportation as options.