Interpretation Response #01-0048 ([BOC Gases] [Mr. John M. Thompson])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: BOC Gases
Individual Name: Mr. John M. Thompson
Location State: NJ Country: US
View the Interpretation Document
Response text:
JUN 25, 2001
Mr. John M. Thompson Reference No. 01-0048
BOC Gases
600 Union Landing Road
Riverton, New Jersey 08077
Dear Mr. Thompson:
This is in response to your February 14, 2001 letter, requesting clarification on the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they pertain to the charging of foreignmade cylinders for export. Specifically, you asked whether a pressure relief device (PRD) is required on a foreign-made cylinder charge for export as provided by § 173.3010).
The answer is yes, if the use of a PRD is required by § 173.34(d) or the specific packaging provision. As provided by § 173.3010), a foreign-made non-DOT specification cylinder may be charged and shipped for export only, if it meets the applicable requirements in the HMR. Section 173.34(d) states that "No person may offer a cylinder charged with a compressed gas for transportation in commerce unless the cylinder is equipped with one or more pressure relief devices" and lists certain exceptions. Additionally, under § 173.3010)(1), the cylinder must be retested in accordance with § 173 .34( e), which prescribes a periodic retest at the pressure marked on the cylinder, but not less than 5/3 of the marked service or working pressure. The retest interval for a foreign cylinder is once every five years.
I hope this information is helpful. Should you have further questions, please contact us.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.301(j)