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Interpretation Response #00-0103 ([Safety & Compliance Associates, Inc.] [Mr. Mike Lopez])

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

Interpretation Response Details

Response Publish Date:

Company Name: Safety & Compliance Associates, Inc.

Individual Name: Mr. Mike Lopez

Location State: AL Country: US

View the Interpretation Document

Response text:

October 23, 2000


Mr. Mike Lopez                Ref. No. 00-0103
Safety & Compliance Associates, Inc.
P.O. Box 48
Trussville, AL 35173

Dear Mr. Lopez:

This is in response to your request concerning the charging of foreign-made cylinders for export under the Hazardous Materials Regulations (HMR; 49 CFR 171-180).

Your questions are paraphrased and answered below:

Ql.  In reference to your May 23, 1992 response to Ms. Janice Romstad, Du Pont Materials, Logistics and Services, please clarify whether a foreign-made, non ­DOT specification cylinder may be filled and shipped for export provided it has been retested within the prescribed retest period according to the standards of the country of manufacture and it will be filled and shipped prior to its retest due date.

Al. Enclosed is our December 7, 1993 correction letter that we sent to Ms. Romstad.  Also in the enclosed notice of proposed rule making, we proposed to permit a foreign-made, non-DOT specification cylinder to be requalified as authorized by the Associate Administrator for Hazardous Materials Safety.

Q2. Must foreign-made, non-DOT specification cylinders be retested prior to each instance of refilling for shipment, regardless of frequency?

A2. No. A foreign-made, non-DOT specification cylinder is required to be retested every 5 years in accordance with the marked service pressure on the cylinder, but not less than 5/3 of any service or working pressure marking.  See &SE173.34(c) table.

Q3. If this does not remain your current policy, must shippers retest a foreign-made, non-DOT specification cylinder prior to each instance of refilling for shipment, regardless of frequency?

A3. Refer to A2.

Q4. May a retest facility place an identifying mark, other than its RIN number, on the shoulder of a foreign-made, non-DOT specification cylinder, in accordance with §173.34(c)(1)?

A4. Yes.

I hope this information is helpful.


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


Regulation Sections

Section Subject
173.301 General requirements for shipment of compressed gases and other hazardous materials in cylinders, UN pressure receptacles and spherical pressure vessels