Interpretation Response #02-0023 ([Texas Commission on Fire Protection] [JonathanWeidemann])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Texas Commission on Fire Protection
Individual Name: JonathanWeidemann
Location State: TX Country: US
View the Interpretation Document
Response text:
July 1, 2002
Mr. Jonathan Weidemann Reference No. 02-0023
Texas Commission on Fire Protection
Post Office Box 2286
Austin, Texas 78768-2286
Dear Mr. Weidemann:
This is in response to your letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) pertaining to the qualification and maintenance of Self-Contained Breathing Apparatus (SCBA) composite cylinders. Your questions are paraphrased and answered as follows:
Q. As required by the HMR, SCBA cylinders must be marked a specific way. Are there any exceptions to the way SCBA cylinders are marked, and if so what are the exceptions?
A. Your understanding is not correct that cylinders are marked in accordance with the HMR. SCBA composite cylinders are nonspecification cylinders manufactured under exemptions issued by the Associate Administrator for Hazardous Materials Safety (AAHMS)or special permits granted by Transport Canada. An exemption,' as defined in § 171.8, is a document that authorizes a person to perform a function that is not otherwise authorized under the HMR. Therefore, the requirements pertaining to the qualification, maintenance, and use of SCBA cylinders are found in the applicable exemption. In addition, exemptions may vary according to the cylinder model or design, therefore each exemption should be reviewed in its entirety. You may obtain copies of the exemptions at the following website: http://hazmat.dot.gov/exemptions_index.htm. You may also contact the Office of Hazardous Materials Exemptions and Approvals by telephone (202) 366-4535 to obtain copies.
Q. Where can we find identification numbers for those facilities that perform hydrostatic testing and if the number is valid?
A. Under the retest authorization requirements in § 173.34(e)(2), any person who performs a hydrostatic test or a modified hydrostatic test is required to be approved and hold
a current retesters identification number issued by RSPA and operate in compliance with the terms of the retester identification number issuance letter. Unless otherwise provided in the issuance letter, an approval expires five years from the date of issuance. A list of authorized retesters of cylinders is available on the Internet at the following website: http://hazmat.dot.gov/files/approvals/hydro/hydro_retesters.htm
The retester identification number, the name and address, the classes of cylinders authorized for retest, the date of the most recent authorization and current status of the retester is provided. You may also contact the Office of Hazardous Material Safety Office of Exemptions and Approvals at 202-366-4512 to assist you in determining the retesterrs current status and recent authorization.
Q. How can we know if hydrostatic inspection and test facilities are certified and if their certification is current. We would also like to know if the individual that is performing the inspection is currently certified.
A. The AAHMS issues retester identification numbers to facilities not individuals as evidence of approval to requalify DOT specification and exemption cylinders. As provided in § 173.34(e)(2), a retester approval is based on the retester"s application, the inspection report and recommendation submitted by an independent inspection agency. A retester identification number is in effect for a maximum of five (5) years, at which time the approval holder must apply for renewal.
I trust this satisfies your inquiry. Please contact us if we can be of more assistance.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
173.34