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Interpretation Response #05-0087 ([G & C Kinney, Inc.] [Mr. Glen L. Kinney])

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

Interpretation Response Details

Response Publish Date:

Company Name: G & C Kinney, Inc.

Individual Name: Mr. Glen L. Kinney

Location State: VA Country: US

View the Interpretation Document

Response text:

May 10, 2005


Mr. Glen L. Kinney                     Reference No. 05-0087
G & C Kinney, Inc.
306 Cutler Cove
Stafford. VA 22554

Dear Mr. Kinney:

This responds to your telephone conversation with Mr. Ryan Posten, Exemptions Program Officer, Office of Hazardous Materials Exemptions and Approvals, requesting clarification of the requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) concerning calibration verification of equipment used for volumetric expansion tests for DOT specification cylinders. Specifically, you ask whether the maximum pressure at which the verification test is being conducted (for example, 3,000 pounds) must be maintained at the final pressure for 30 seconds or whether the pressure may be allowed to drop between 2 psi and 10 psi.

Overall, for any pressure test (calibration or production retest), the 30-second hold time begins only when the cylinder has completed its expansion. If the cylinder pressure drops by any measurable amount (such as 2 psi) during the recorded 30-second hold time, the hold time must be restarted or the test would be considered invalid.

I hope this information is helpful. If you need additional information, please do not hesitate to contact this office.



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


Regulation Sections

Section Subject
180.205 General requirements for requalification of specification cylinders