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Interpretation Response #03-0063 ([D&G Consulting, Inc.] [Mr. Glen K. Wanczyk])

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

Interpretation Response Details

Response Publish Date:

Company Name: D&G Consulting, Inc.

Individual Name: Mr. Glen K. Wanczyk

Location State: UT Country: US

View the Interpretation Document

Response text:

Aug 18, 2003


Mr. Glen K. Wanczyk                Ref. No. 03-0063
Hazardous Materials Consultant
D&G Consulting, Inc.
3708 South Monarch Drive
Bountiful, Utah 84010

Dear Mr. Wanczyk:

This responds to your letter regarding modifications made to an air bag inflator manufactured under the terms of a DOT exemption, under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171¬180). Specifically, _you inquire whether your customer may replace the thrust neutral shipping cap with one that is appropriate for the application of the inflator and reoffer it for transportation without review, testing and certification by an independent inspector.

The answer is no. As specified in the exemption, no modification may be made to the production safety system which would affect the performance of the safety system or its compliance with the requirements of the exemption until such modifications have been reviewed, tested and certified by an independent inspector.

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



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

Regulation Sections

Section Subject
178.65 Specification 39 non-reusable (non-refillable) cylinders