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Interpretation Response #00-0046 ([Taylor-Wharton] [Mr. Glenn Curtis])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Taylor-Wharton

Individual Name: Mr. Glenn Curtis

Location State: AL Country: US

View the Interpretation Document

Response text:

March 24, 2000


Mr. Glenn Curtis                              Ref.  No: 00-0046
4075 Hamilton Blvd.
Theodore, AL 36582

Dear Mr. Curtis:

This is in response to your February 7, 2000, letter requesting clarification of the term "lot" as it pertains to DOT specification 4L welded cylinders under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Your questions are paraphrased and answered as follows:

Q.       We manufacture different cylinder models that are identical in all respects, except for a 7%-8% volumetric capacity due to a difference in shell length.  May the two models be considered a "lot" provided their combined quantity doesn't exceed 200?

A.       No. A "lot" is considered to be cylinders of the same size that are successively produced in the same shift (see § 178.65(f)). Although § 178.65 pertains to DOT Specification 39 cylinders, "lot" has the same meaning throughout the HMR.  This will be clarified in a future rulemaking action.

Q.       Due to a delay we interrupt manufacturing of a lot of cylinders.  At some later time we resume production using the same heats of materials, designs, equipment, and process.  Are all cylinders manufactured both before and after the interruption considered as one "lot" in relation to the testing requirements of § 178.57(l)(1)(2) or (3)?

A. No, for the same reasons.

I hope this information is helpful.



Delmer F.  Billings
Chief, Standards Development
Office of Hazardous Materials Standards



Regulation Sections

Section Subject
178.57 Specification 4L welded insulated cylinders