Interpretation Response #16-0050 ([Hydro-Test Products, Inc.] [Mr. Tom Sauta])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Hydro-Test Products, Inc.
Individual Name: Mr. Tom Sauta
Location State: FL Country: US
View the Interpretation Document
Response text:
July 25, 2016
Mr. Tom Sauta
Hydro-Test Products, Inc.
85 Hudson Road
Stow, MA 01775
Ref. No. 16-0050
Dear Mr. Sauta:
This responds to your March 15, 2016 letter requesting clarification of the cylinder requalification marking requirements under § 180.213 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request clarification on the use of labels to satisfy the requirements in § 180.213. Your questions are paraphrased and answered as follows:
Q1. Are cylinder requalification markings permitted on the sidewall if the marking is done with a label?
A1. As provided by § 180.213(b)(1), requalification markings may be placed on any portion of the upper end of the cylinder excluding the sidewall.
Q2. Is it acceptable to use a label with the word “CONDEMNED” in lieu of stamping “CONDEMNED” for all cylinders?
A2. The use of a label with the word “CONDEMNED” is authorized only for composite cylinders (see § 180.205(i)(2)).
Q3. Is a label authorized to comply with the requalification marking requirements in § 180.213 for DOT 3HT cylinders?
A4. A label is not authorized for requalification markings on DOT 3HT cylinders (see § 180.213(c)(2)).
I hope this answers your inquiry. If you need additional assistance, please contact the Standards and Rulemaking Division at (202) 366-8553.
Sincerely,
Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division
180.213, 180.213(b)(1), 180.205(i)(2), 180.213(c)(2)