Interpretation Response #13-0190 ([T-Aerospace, LLC] [Mr. Patrick Miller])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: T-Aerospace, LLC
Individual Name: Mr. Patrick Miller
Location State: TN Country: US
View the Interpretation Document
Response text:
January 13, 2014
Mr. Patrick Miller
Chief Inspector
T-Aerospace, LLC
4048 Senator Street
Memphis, TN 38118
Reference No. 13-0190
Dear Mr. Miller:
This is in response to your September 19, 2013 e-mail asking for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) pertaining to chemical fire extinguishers. In your e-mail, you state these fire extinguishers weigh 13 pounds (5.90 kg) each, contain liquefied bromochlorodifluoromethane gas (Halon 1211), and are composed of non-specification cylinders constructed in conformance with United Laboratories (UL) Standard 299 (Dry chemical fire extinguishers). We apologize for the delay in responding and any inconvenience this may have caused.
As an attachment to your e-mail, you included two pictures of the Amerex Model B371 fire extinguisher: one of the specification plate, the second, of the instructions. These pictures indicate that the cylinders are Classification 2-1:40-B:C, Size II, cylinders pressure-tested to 585 psi (4035 kPa). Further, the specification plate also states that the fire extinguisher conforms to two test standards: American National Standards Institute, Inc. (ANSI)/UL 711 (Rating and fire testing of fire extinguishers), and ANSI/UL 1093 (Halogenated agent fire extinguishers). You ask if your company needs a requalifier identification number (RIN) to service and re-certify dry chemical fire extinguishers manufactured by the Ansul and Amerex Corporations under the HMR.
The answer to your question is no. The HMR require those persons who requalify (i.e., inspect, test, or certify), rebuild, or repair a Department of Transportation (DOT) specification cylinder or United Nations (UN) standard pressure receptacle to be approved to perform these tasks through receipt of a RIN. The Pipeline and Hazardous Materials Safety Administration’s (PHMSA’s) Associate Administrator for Hazardous Materials Safety issues RINs to qualified persons in conformance with §§ 107.801, 180.201, and 180.203 of
the HMR. The HMR do not require facilities that test non-specification fire extinguishers to have a PHMSA-issued RIN. Nevertheless, non-specification fire extinguishers are only authorized under the HMR if they meet all conditions and testing requirements prescribed in § 173.309(c).
I hope this satisfies your request. Please contact us if you need further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
173.309
Regulation Sections
| Section | Subject |
|---|---|
| 173.309 | Fire extinguishers |