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Interpretation Response #05-0270 ([Fire Protection Certification] [Mr. Edward O'Brien])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Fire Protection Certification

Individual Name: Mr. Edward O'Brien

Location State: MD Country: US

View the Interpretation Document

Response text:

Jan 5, 2006

 

Mr. Edward O"Brien                      Reference No. 05-0270

President

Fire Protection Certification

8719 Pete Wiles Road

Middletown, MD 21769

Dear Mr. O"Brien:

This is in response to your October 12, 2005 letter requesting clarification of the record retention requirements for cylinder requalifiers under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask which number a requalifier should maintain in his records as the serial number when recording the performance of a 1 2-year hydrostatic test on a DOT 4B cylinder used as a fire extinguisher. You indicate that two numbers are marked on the cylinder - a batch number that applies to an entire lot of cylinders is stamped on the shell, and a serial number is displayed on the manufacturer"s label. The cylinder was manufactured by Amerex Corporation.

Section 178.35(f) requires each specification cylinder to be marked with a serial number. For the purpose of cylinder identification, § 180.2 15(b)(2) requires the person performing cylinder requalification to record and retain the serial number of the cylinder that was tested.

In the situation you describe, it is likely that the cylinder was manufactured by Amerex Corporation under DOT exemption DOT-E 9837. The exemption authorizes Amerex Corporation to stamp the lot number instead of the serial number on DOT 4B cylinders. The lot must consist of less than 500 cylinders and each cylinder must have a volumetric capacity not exceeding 170 cubic inches and a service pressure not exceeding 200 psig. Assuming that your cylinder meets DOT-E 9837, your records should display the lot number that is permanently stamped in the cylinder. The serial number may be entered as additional information to clearly identify the cylinder.

I hope this information is helpful. Please contact us if you require additional assistance.

Sincerely,

 

John A. Gale

Chief, Regulations Development

Office of Hazardous Materials Standards

180.215(b)(2)

Regulation Sections