Interpretation Response #00-0309 ([Vallen Technical Services] [Mr. Bill McDonald])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Vallen Technical Services
Individual Name: Mr. Bill McDonald
Location State: CA Country: US
View the Interpretation Document
Response text:
March 15, 2001
Mr. Bill McDonald Ref. No. 00-0309
Vallen Technical Services
909 William Drive
San Lorenzo, CA 94580
Dear Mr. McDonald:
This is in response to your letter requesting clarification under the Hazardous Materials Regulations (HMR;49 CFR Parts 171-180) pertaining to the pressure retest of DOT specification cylinders. Specifically, § 173.34(e)(4)(v)states: “In the case of a malfunction of the test equipment, the test may be repeated at a pressure increased by 10 percent or 100 psi, whichever is less.” It is your understanding that only one repeat test is permitted.
Your understanding of this requirement is correct. Section 173.34 (e)(4)(v) permits only one repeat test in the case of a malfunction of the test equipment.
With regards to your reference to the Compressed Gas Association (CGA) pamphlet C-1, currently the HMR does not incorporate the pamphlet by reference. However, we proposed in a notice of proposed rulemaking to reference certain pressure test procedures contained in the CGA pamphlet. (Docket No. HM-98-3684 (HM-220); October 30, 1998).
I hope this information is helpful. Please contact this office if you need additional assistance.
Sincerely,
Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.34