Interpretation Response #21-0084
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Koorsen Fire & Security
Individual Name: Brick Keltner
Location State: IN Country: US
View the Interpretation Document
Response text:
September 23, 2021
Mr. Brick Keltner
Corporate Trainer Shop
Koorsen Fire & Security
2820 N. Webster
Indianapolis, IN 46219
Reference No. 21-0084
Dear Mr. Keltner:
This letter is in response to your August 4, 2021, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to fire suppression systems classified as fire extinguishers. Specifically, you reference the final rule published on December 28, 2020, titled "Hazardous Materials: Miscellaneous Amendments Pertaining to DOT-Specification Cylinders" [HM-234; 85 FR 85380].
We have paraphrased and answered your questions as follows:
Q1. You ask whether cylinders that are classified as fire extinguishers when installed in fire suppression systems must be requalified exclusively in accordance with § 180.209(j).
A1. The answer is no. A cylinder that meets that definition of a fire extinguisher—as defined in the introductory text to § 173.309—may follow the requalification periods in § 180.209(j) for fire extinguishers. Alternatively, the cylinder may be requalified in accordance with any of the other eligible requalification periods that the cylinder meets in § 180.209.
Q2. You ask what the effective date is for the HM-234 final rule.
A2. The HM-234 final rule became effective on January 27, 2021. However, compliance with the amendments adopted in the HM-234 final rule is required beginning December 28, 2021.
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
173.309, 180.209, 180.209(j)