Oxygen transport policy for NEMT vehicles: cylinders, concentrators, and securing them

Who may ride with oxygen, and who does what

A rider who runs their own portable oxygen may ride with you, and your staff handle the vehicle side only. Federal ADA rules do not let a provider prohibit a rider’s portable oxygen (49 CFR 37.167(h)), and the portable oxygen entry explains what level of vehicle each rider needs. This page is the written policy behind it, a companion to the oxygen paragraph of your ADA policy.

State programs draw the same line in different words. MTM Health’s Virginia handbook says drivers cannot assist with oxygen unless the trip is by ambulance. Georgia’s manual says it is the member’s job to supply or administer oxygen, because NEMT vehicles and drivers are not equipped to. New York lets a stretcher service carry a rider who gives themselves their own oxygen, but its employees may never assist with it, and a stretcher ambulette may not be equipped with oxygen or oxygen delivery supplies. The policy below follows all three.

An insurer’s exclusion is not a reason to turn a rider away. FTA’s ADA guidance uses an insurer that refuses coverage when riders carry portable oxygen as its own example of what 49 CFR 37.5(g) forbids a provider to act on. If your insurance agent raises it, point to the rule and do not add oxygen to a list of excluded riders. Check the same rule before you add a per-trip oxygen fee to your rate sheet: 49 CFR 37.5(d) bars special charges to individuals with disabilities for services the ADA rules require or that are otherwise necessary to accommodate them.

The template

[Company name] oxygen on board policy

Applies to: riders, escorts, drivers, and dispatchers | Effective date: [date] | Owner: [role] | Next review: [date]

1. What riders may bring

Riders may bring their own portable oxygen, either a cylinder or a portable concentrator. We do not refuse a rider because they use oxygen. [We do not add a charge for carrying a rider’s own oxygen.]

2. What our staff do and do not do

1. We do not supply, start, stop, adjust, or change oxygen, and our vehicles carry no oxygen of their own.
2. The rider, an escort, or the rider’s supplier runs the equipment. A rider who needs someone else to give or manage oxygen, or who needs monitoring, needs a different level of service. Dispatch tells the broker, facility, or family so they can book it.
3. Drivers carry and secure the cylinder or concentrator in the vehicle when the rider asks.

3. At booking

Dispatch records on the trip:

1. Cylinder (with its size) or concentrator (with its model).
2. The flow setting, in liters per minute for a cylinder.
3. The minutes of oxygen the rider has, taken from the rider or the rider’s supplier.
4. The trip time, plus any wait, plus [30] minutes of margin.
5. A spare cylinder or battery, and a car power cord for a concentrator on a long trip.
6. Who manages the oxygen on the ride, and whether an escort is coming.

If the supply is shorter than the trip, the wait, and the margin together, dispatch asks the rider to bring a spare or shortens the wait before the trip is confirmed.

4. Cylinders in the vehicle

1. A cylinder is secured against shifting before the vehicle moves, in the vehicle’s holder where one is fitted or strapped in place [describe the holder or strap point your vehicles use].
2. Cylinders ride in the passenger area, never in a closed cargo space or trunk, and are never left in a parked vehicle.
3. No more than [2] cylinders per rider and [4] per vehicle.
4. Home-size and hospital-size cylinders are not carried [portable sizes only].
5. Liquid oxygen units: [carried / not carried].

5. Concentrators

1. A rider may use a concentrator for the whole ride and keeps control of it. We do not require a particular place for it.
2. The unit and its cord stay clear of securement straps, the aisle, and exits.
3. The driver does not plug in, reset, or restart a concentrator.

6. Fire and smoking

1. No smoking, vaping, or open flame in the vehicle at any time. A “NO SMOKING” sign is posted where every rider can see it.
2. No one lights anything within [6] feet of the vehicle while oxygen is aboard.
3. Riders may not smoke while using oxygen. Staff follow our conduct policy when a rider will not comply.

7. If something goes wrong

1. Supply low or an alarm. The driver pulls over somewhere safe and calls dispatch. The rider or escort changes the cylinder or battery.
2. Trouble breathing, or the rider looks unwell. The driver calls 911, then dispatch.
3. Fire, or a smell of burning. Stop, get everyone out, call 911.
4. Dispatch calls the rider’s family, facility, or broker and starts an incident report the same day.

8. Training and records

Every driver and dispatcher reads this policy at hire and each year after, and the date goes in the training log. Booking records stay with the trip.

Part B: Oxygen booking record

What federal hazmat rules say about cylinders

Federal hazardous materials rules limit how much a vehicle may carry, and a handful of portable cylinders stays far below the limit. FTA’s ADA guidance sends compressed oxygen cylinders to 49 CFR 177.870(e), the section for motor vehicles carrying passengers for hire, and tells providers to take cylinder questions to PHMSA. That paragraph limits the gross weight of any hazard class other than explosives to 45 kg (99 pounds), and all such articles together to 225 kg (496 pounds). It also says “A cylinder secured against shifting while in transit and not exceeding 113 kg (250 pounds) gross weight may be transported.”

Gross weight is the weight of a packaging plus its contents (49 CFR 171.8), so the cylinder and its gas both count. One manufacturer’s specification sheet (Rev 9/21) lists an ME cylinder (680 liters of oxygen) at 7.8 pounds empty and an M6 (170 liters) at 2.3 pounds. Four portable cylinders stay well under 99 pounds even with the gas added, and a larger home-size cylinder is where the count starts to matter.

A separate exception, for materials of trade, covers hazardous materials carried to protect a vehicle’s passengers (49 CFR 171.8). It allows a nonflammable gas cylinder up to 100 kg (220 pounds) gross and 200 kg (440 pounds) of all such materials on the vehicle, with cylinders secured against shifting and the driver told what is aboard (49 CFR 173.6). Which set of limits governs a rider’s own oxygen on a for-hire van is a question for PHMSA. Keep the counts in section 4 of the template under both.

Concentrators need no set place on the vehicle

A concentrator can ride wherever it is safe for the rider to keep it. FTA’s guidance says the commonly used portable concentrators are not hazardous materials and do not need the special handling of compressed cylinders. It concludes that an agency cannot require riders to secure a concentrator in a particular place, such as behind forward-facing seats, and that riders must be allowed to use it as needed on board. Section 5 of the template leaves the unit with the rider for that reason.

Run time is the booking question for both devices, because a concentrator’s battery and a cylinder’s liters each have to outlast the ride. The long-distance trip guide has the cylinder minutes table and the makers’ battery run times. For this policy the rule is in section 3: the rider’s own supply has to outlast the trip, the wait, and the margin, and the rider or the rider’s supplier gives the figure.

Heat, storage, and fire

Keep oxygen away from flame, heat, and closed spaces that get hot. Oxygen makes things burn faster. The U.S. Fire Administration warns that a flame or spark near medical oxygen can set off an explosion, and that oxygen switched off can still catch fire. MedlinePlus (reviewed January 2026) tells patients to keep oxygen out of trunks, boxes, and small closets, and 6 feet clear of heaters, candles, and fireplaces. UCSF Health’s patient guidance puts the highest safe temperature for an oxygen tank at 125 degrees Fahrenheit and says cylinders are stored upright and secured in an approved cart or storage device. That is why section 4 keeps cylinders out of closed compartments and parked vans.

Virginia’s fee-for-service rules require every vehicle to be tobacco and smoke free, including vapor and e-cigarettes, with a “NO SMOKING” sign. MTM’s Pennsylvania agreement requires a “NO SMOKING” sign in all vehicles, and Illinois requires one in every licensed stretcher van. The state and broker rules are in no smoking or vaping in NEMT vans.

What states ask of stretcher vans

Several states write oxygen rules into their stretcher van requirements.

• Illinois. A stretcher van must have a quick-release bracket, rated crash-stable, for every oxygen cylinder it carries (77 Ill. Adm. Code 515.840(h)). It may not carry a rider whose supplemental oxygen is not self-administered (515.845(e)).
• New York. Oxygen tanks must be secured while in the vehicle.
• Virginia. Self-administered oxygen on a stretcher van must be secured to AMD Standard 003, the Oxygen Tank Retention System Test. The portable oxygen entry covers how that fits with wheelchairs.
• Missouri. Non-emergency ambulance is the mode for a participant who needs equipment only an ambulance has, and the manual’s example is non-portable oxygen.

Riders on ventilators or life-support equipment are a different booking, covered in the guide to tracheostomy and ventilator transport.

Matching oxygen riders to vehicles in HealthRide

Dispatch sees a rider’s oxygen need on the trip, and HealthRide matches it to a vehicle that can carry it when the trip is assigned on the dispatch board. At the start of every shift, drivers check their van in the app. Fleet and credentials explains how vehicles are set up.