Interpretation Response #13-0014 ([Mr. Jason Spence])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name:
Individual Name: Mr. Jason Spence
Location State: AZ Country: US
View the Interpretation Document
Response text:
February 14, 2013
Mr. Jason Spence
9474 N. Stonebrook Drive
Tucson, AZ 85743
Ref No.: 13-0014
Dear Mr. Spence:
This is a response to your November 30, 2012 email requesting clarification of the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 100-185) with regard to recordkeeping requirements for requalification of cylinders. Specifically, you ask what the term "actual dimensions" refers to with respect to the requalification records for cylinders specified in § 180.215(b).
In accordance with § 180.215(b), requalification records must be kept for examination of DOT specification cylinders by the person who performs the cylinder requalification. These requalification records include information about the cylinder such as the "actual dimensions" of the cylinders. Although the HMR does not define "actual dimensions", the term as used in § 180.215(b), refers to the outside diameter and the length of the cylinder in inches. Although it is not incorporated by reference in the HMR, this interpretation is consistent with the practices found in CGA pamphlet CGA C-1.
I hope this information is helpful. If you have any more questions, please do not hesitate to contact this office.
Sincerely,
Robert Benedict
Chief, Standards Development
Standards and Rulemaking Division
180.215(b)
Regulation Sections
| Section | Subject |
|---|---|
| 180.215 | Reporting and record retention requirements |