Interpretation Response #00-0071 ([Law Offices of Fisher & Douglas] [Ms. Rebecca A. Smith])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Law Offices of Fisher & Douglas
Individual Name: Ms. Rebecca A. Smith
Location State: OH Country: US
View the Interpretation Document
Response text:
September 15, 2000
Ms. Rebecca A. Smith Ref No: 00-0071
Legal Administrator
Law Offices of Fisher & Douglas
122 East Main Street
Columbus, Ohio 43215-5208
Dear Ms. Smith:
This is in response to your letter of March 1, 2000, requesting clarification on the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they pertain to DOT specification cylinders which are never transported in commerce. Specifically you ask whether these specification cylinders must be inspected or tested prior to refilling.
As specified in §171.1, the HMR govern the safe transportation of hazardous materials in intrastate, interstate, and foreign commerce. Therefore, a DOT specification cylinder used on a paint ball battlefield, which are emptied and refilled on the premises, and never transported off of the battlefield, is not subject to the HMR.
For your information, although not required by the HMR, we recommend testing of any cylinder beyond its retest date prior to refilling the cylinder.
I hope this information is helpful.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
173.34