Interpretation Response #23-0031
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Essex Industries, Inc.
Individual Name: Ario Estrada
Location State: MO Country: US
View the Interpretation Document
Response text:
June 7, 2023
Ario Estrada
Senior Quality Manager
Essex Industries, Inc.
8007 Chivvis Drive
St. Louis, MO 63123-2395
Reference No. 23-0031
Dear Mr. Estrada:
This letter is in response to your March 20, 2023, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to general requirements for DOT specification cylinders. In your email, you state that your company manufacturers DOT 4L cylinders with a water capacity of 1,220 cubic inches at a facility in the United States. In reference to the inspection and analyses requirements of § 178.35(b)(2), you ask whether your company is able to use a competent inspector of the manufacturer or must instead use an independent inspection agency approved in writing by the Associate Administrator. Specifically, you seek confirmation of your understanding that the water capacity threshold limit of 1,100 cubic inches for use of a competent inspector of the manufacturer for domestic manufacturing applies only to DOT 4D cylinders and not to the other cylinders listed including DOT 4L cylinders.
Your understanding is correct, the 1,100 cubic-inch limit only applies to DOT 4D cylinders. A domestic manufacturer of DOT 4L cylinders may use a "competent inspector of the manufacturer" for performance of inspections and verification of the cylinders. Specifically, your 1,220 cubic inch DOT 4L cylinders may be inspected by a competent inspector of the manufacturer.
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
178.35(b)(2)
Regulation Sections
| Section | Subject |
|---|---|
| 178.35 | General requirements for specification cylinders |