Interpretation Response #24-0033R
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Moog, Inc.
Individual Name: Sam Browning
View the Interpretation Document
Response text:
July 22, 2025
Sam Browning
Moog, Inc.
Ashchurch Parkway
Tewkesbury
Gloucestershire
GL20 8TU
United Kingdom
Reference No. 24-0033R
Dear Mr. Browning:
This letter is updated and revised in response to your original April 2 email based on your follow-up September 4, 2024 email, and your subsequent conversation with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to cylinder condemnation. Specifically, you have questions about the process for condemning a cylinder consistent with the requirement outlined in § 180.205(j)(1)(x) when the owner of the cylinder knows that its service life has expired.
We have paraphrased and answered your questions as follows:
Q1. Must a person (i.e., a cylinder owner) have any part of a "requalification"—as defined in § 180.203—performed when the cylinder owner knows that the authorized service life of a cylinder such that it is now subject to condemnation consistent with § 180.205(j)(1)(x)?
A1. No. In this instance, when a cylinder owner knows a cylinder is not suitable for continued service because it has reached the end of its service life it does not need to be subjected to requalification provisions. The term "requalification"—as defined in § 180.203—means the completion of a visual inspection and/or the test(s) required to be performed on a cylinder to determine its suitability for continued service.
Q2. In the instance of a cylinder owner knowing a cylinder is not suitable for continued service because it has reached the end of its service life and the owner uses the services of a cylinder requalifier to condemn the cylinder in accordance with § 180.205(j), must a requalifier complete any part of recordkeeping found in §§ 180.215(b) introductory text or 180.215(b)(2), respectively?
A2. No. A cylinder known to have an expired service life does not need to undergo formal requalification including maintenance of a record because the owner has already determined the cylinder is no longer suitable for continued service past its authorized service life. The requalifier needs only to adhere to the requirements found in § 180.205(j)(2).
Q3. When is a requalification record of condemnation of a cylinder necessary for a cylinder past its specified service life?
A3. A record of condemnation is necessary if during performing a requalification, it is determined by the requalifier that a cylinder’s authorized service life has expired.
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
§ 180.203, § 180.205(j), § 180.205(j)(1)(x), § 180.205(j)(2), § 180.215(b), § 180.215(b)(2)