Interpretation Response #01-0128 ([Aidant Cylinder Maintenance Co.] [Mr. Fred Bali])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Aidant Cylinder Maintenance Co.
Individual Name: Mr. Fred Bali
Country: US
View the Interpretation Document
Response text:
AUG 20, 2001
Mr. Fred Bali Ref. No. 01-0128
Aidant Cylinder Maintenance Co.
15836 North 77th St.
Scottsdale, AZ 85260
Dear Mr. Bali:
This is in response to your letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) concerning requalification requirements for acetylene cylinders. You state that you perform acetylene cylinder requalifications for a customer who asks that you not perform the examination and replacement of defective fuse plugs. You state that the customer wants to perform this portion of the requalification and you ask whether this is prohibited under the 49 CFR. You also ask whether "extruded metal" in paragraph 5.4.8 of the Compressed Gas Association's (CGA) pamphlet C-13 allows for any amount of extrusion without the cylinder being considered defective.
Section 173.34(e) (18) (ii) specifies that an aceytlene cylinder requalification may be performed only by a person holding a valid RIN (retester identification number). The person holding the RIN that is marked on the acetylene cylinder is the person certifying that the cylinder has been fully requalified in accordance with the requirements in § 173.34 and CGA pamphlet C-13. Therefore, if you do not perform the examination and replacement of defective fuse plugs, you may not mark your RIN number on the cylinder.
With regard to whether the examination for extruded metal in accordance with the CGA pamphlet C-13 allows for any amount of extrusion without being considered defective, the answer is no.
I hope this information is helpful. Please contact this office if we may be of further assistance.
Sincerely,
Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.34