Interpretation Response #17-0056
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: FIBA Technologies, Inc
Individual Name: Chris Adams
Location State: MA Country: US
View the Interpretation Document
Response text:
September 26, 2017
Chris Adams
Manager, Regulatory Affairs
FIBA Technologies, Inc.
53 Ayer Road
Littleton, MA 01406
Reference No. 17-0056
Dear Mr. Adams:
This letter is in response to your May 25, 2017, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the repair of seamless DOT 3-series specification cylinders. You describe a scenario in which a DOT 3AAX specification cylinder was not equipped with external neck threads at the time of manufacture. You ask if the cylinder may be threaded with external threads and be considered a “re-threaded” repair under the provisions of § 180.212(b)(2), and therefore not require prior approval.
The answer is no. The provisions of § 180.212(b)(2) apply only to cylinders already machined with threads. If a person wishes to machine external threads on a cylinder originally manufactured without external threads, the work must be done in accordance with § 180.212(a), which requires an approval under Part 107, Subpart H.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
180.212(b)(2), 180.212(a)