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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #00-0066 ([Allied Universal Corp.] [Ms. Robin J. Eddy])

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

Interpretation Response Details

Response Publish Date:

Company Name: Allied Universal Corp.

Individual Name: Ms. Robin J. Eddy

Location State: FL Country: US

View the Interpretation Document

Response text:

March 17, 2000

Ms. Robin J. Eddy                Ref. No. 00-0066
Safety and Regulatory Compliance Manager
Allied Universal Corp.
8350 N.W. 93 Street
Miami, Florida 33166-2098

Dear Ms. Eddy:

This is in response to your letter of February 24, 1999, requesting clarification of the retest and marking requirements for DOT specification 106A50OX multi-unit tank car tanks under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Your questions are paraphrased and answered as follows:

(Ql) Must a testing facility possess a valid retester identification number (RIN) to perform retesting under § 180.519?

(Al) No. RIN numbers are only assigned to authorized cylinder requalifiers.

(Q2)     Is a retester prohibited from stamping his RIN number on a multi-unit tank car tank that successfully completes the required pressure test?

(A2)     No, the HMR do not prohibit the placement of a RIN number on a tank car, nor is it required.

(Q3)     Multi-unit tank car tanks are required to be marked with the month and year of test, plainly and permanently stamped into the metal of one head or chime of each tank with successful test results.  Based on a tank pressure retest interval of five years, if a tank is marked with the month and year 1/96, when is the retest due?

(M)      As specified in § 180.519(a), a retest may be made at any time during the calender year the retest falls due.  Therefore, in your scenario, the retest may be conducted by December 31, 2001.


I trust this satisfies your inquiry.  Please contact us if we can be of further assistance.

Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.31 Use of tank cars