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Interpretation Response #02-0295 ([Structural Composites Industries (SCI)] [Robert Beck])

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

Interpretation Response Details

Response Publish Date:

Company Name: Structural Composites Industries (SCI)

Individual Name: Robert Beck

Location State: CA Country: US

View the Interpretation Document

Response text:

Apr 3, 2003

Mr. Robert Beck                 Reference No. 02-0295
Director of Quality and Technical Services
Structural Composites Industries (SCI)
325 Enterprise Place
Pomona, CA 91768

Dear Mr. Beck:

This is in response to your November 13, 2002, letter requesting clarification of the marking requirements of cylinders manufactured to the Carbon-Fiber Reinforced Aluminum Lined Cylinders (DOT-CFFC) standard.  You stated that most carbon composite cylinders manufactured by SCI have an outside layer of a resin-based material (FlowCoat) added to the cylinder.  Specifically, you asked if it is permissible to place the cylinder label containing the manufacturing standard information under this FlowCoat.

The answer is no.  The marking requirements in DOT-CFFC Standard, Section CFFC-14, state that cylinders made in conformance with this standard and the applicable DOT exemption must be permanently marked (other than stamping) in the composite overwrap on the sidewall.  Therefore, your proposed label application does not meet the requirements of the DOT-CFFC standard.

You may submit a request to modify the terms of the applicable exemption by providing supporting information to demonstrate that your proposed modification will achieve a level of safety at least equal to that established by the current standard and current exemption.

If we can be of further assistance, please contact us.


Delmer F. Billings
Chief, Regulations Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
178.35 General requirements for specification cylinders