Interpretation Response #00-0364 ([Barlen and Associates, Inc.] [Mr. William Barlen])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Barlen and Associates, Inc.
Individual Name: Mr. William Barlen
Location State: CT Country: US
View the Interpretation Document
Response text:
April 18, 2002
Mr. William Barlen Reference. No. 00-0364
Barlen and Associates, Inc.
90 Dorset Lance
Madison, CT 065443-8107
Dear Mr. Barlen:
This is in reference to your inquiry concerning the soldering or brazing of an outlet connection onto the valve of a DOT 4L cylinder under the Hazardous Materials Regulations (49 CFR Parts 171-180). Your inquiry also is in further reference and clarification to our May 24, 1999 response to Mr. Mike Lopez, Safety and Compliance Associate, Inc. I apologize for the delay in responding and regret any inconvenience it may have caused.
Specifically, you inquired whether the work can be done by a "qualified person" who is not an authorized facility as specified in § 173.34(i). The work involves permanently attaching, by soldering or brazing, the outlet connection onto the cylinder valve. Outlet connections are designed for a specific gas or group of gases. They are used to prevent a person from making connections that could, for example, result in the mixing of non-compatible gases or unloading the cylinder's contents into unintended connections, such as in medical gases applications.
After reviewing the supplemental information you submitted and based on the location of the connections, as we have illustrated on the enclosed sketch, it is the opinion of this office that the work may be performed by a qualified person who is knowledgeable of the proper soldering or brazing procedures. The person need not be registered under § 173.34(i).
If I can be of further assistance, please feel fee to contact this office.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
Enclosure
cc: Mr. Mike Lopez
173.34