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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

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.



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