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Interpretation Response #02-0271 ([Fire Protection Consultants, LTD] [Edward O'Brien])

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

Interpretation Response Details

Response Publish Date:

Company Name: Fire Protection Consultants, LTD

Individual Name: Edward O'Brien

Location State: MD Country: US

View the Interpretation Document

Response text:

Nov 27, 2002

Mr. Edward O'Brien                 Reference No. 02-0271
Fire Protection Consultants, LTD
8719 Pete Wiles Road
Middletown, MD 21769

Dear Mr. O'Brien:

This is in response to your October 14, 2002 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you request a variation from the requalification markings displayed on pressure-sensitive labels for cylinders used as fire extinguishers.  In your letter you provided a copy of a pressure sensitive label for our review.

As provided in recently adopted 180.213(c), the HMR permit the application of pressuresensitive labels bearing the requalification information on DOT specification cylinders used as fire extinguishers.  However, as pointed out in your letter, the marking configuration on the labels are not consistent with the HMR but conform to the requirements referenced in NFPA 10, Standard for Portable Fire Extinguishers, which is adopted by many State and local agencies.

The requalification marking on pressure-sensitive labels for cylinders used as fire extinguishers must be marked in the manner illustrated in § 180.213(d). However, upon written request, a variation from the marking requirement may be approved by the Associate Adminitrator as provided in § 180.213(d)(1). A request for a variation may be submitted to the Office of Hazardous Materials Exemptions and Approvals (DHM-30), Research and Special Programs Administration, U.S. Department of Transportation, 400 7th Street SW., Washington DC, 20590-0001.


Hattie Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
180.213 Requalification markings