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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 #02-0080 ([Allied Universal Corp.] [Robin J. Eddy Bolte])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Allied Universal Corp.

Individual Name: Robin J. Eddy Bolte

Location State: FL Country: US

View the Interpretation Document

Response text:

July 10, 2003

Ms. Robin J. Eddy Bolte                                                       Ref. No. 02-0080
Safety and Regulatory Compliance Manager
Allied Universal Corp.
3901 N.W. 115th Avenue
Miami, FL 33178

Dear Ms. Bolte:

This is in response to your letter and subsequent telephone conversation with Sandra Webb of my staff requesting clarification of the requirements for marking the tare weight on a cylinder under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you state that your
company is trying to determine the proper procedure for handling DOT Specification 3A and 3AA cylinders that show distinct loss in weight, between five (5) and nine (9) percent of the original stamped weight. I regret the delay in responding to your letter and hope it has not caused you any inconvenience.

The requirement previously contained in § 173.34(c) was recently moved to §173.301(b) in a final published on August 8, 2002, under RSPA Docket HM-220D; 67 FR 51652. Your specific questions are paraphrased and answered below.

Q1: If the cylinder passes inspection and requalification, may our hydrostatic testers or third party
hydrostatic testing service mark the new tare weight to the right of the original tare weigh on the the cylinder?

A1: The answer is yes. Additional information may be marked on the cylinder provided it do not
affect the required markings prescribed in § 178.35(1) and the applicable specification as
specified in § 173.301(b). However, we recommend that you stamp one diagonal line through the obselete, original tare weight(s), if present, so that it is still legible for future reference.

Q2: Is it true that a cylinder with a five to nine percent tare weight lost passing inspection and hydrostatic testing may only be used for one year from the date of that testing, or may it
until additional inspection and hydrostatic testing is warranted or it fails the ten percent.

A2: With the exception of DOT Specification 3HT cylinders (see § 173.302a(a)(2) as specified under Docket HM-220D (67 FR 51626; 51646; August 8,2002)) or cylinders manufactured under exemption, DOT cylinders do not have a specified service life. Therefore, if the cylinder conforms to the applicable requirements specified in Part 173 and Part 180 of the HMR, it may be used in the transportation of hazardous materials.

I trust this satisfies your request. Please contact us again if we can be of further assistance.

Sincerely,
Susan Gorsky
Senior Transportation Regulations Specialist
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
173.302a Additional requirements for shipment of nonliquefied (permanent) compressed gases in specification cylinders
178.35 General requirements for specification cylinders