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Interpretation Response #05-0179 ([Taylor-Wharton] [Mr. Les Musselman, P.E.])

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

Interpretation Response Details

Response Publish Date:

Company Name: Taylor-Wharton

Individual Name: Mr. Les Musselman, P.E.

Location State: PA Country: US

View the Interpretation Document

Response text:

Oct 13, 2005

Mr. Les Musselman, P.E.                     Reference No. 05-0 179
Manager of Product Technology
P. 0. Box 2365
Harrisburg, PA 17105-2385

Dear Mr. Musselman:

This responds to your letter requesting clarification of the requirements for visual inspection of steel cylinders under § 180.205(f) of the Hazardous Materials Regulations (49 CFR Parts 171-180). Specifically, you ask what level of paint constitutes “inhibiting visual inspections.”

Section 180.205(f) requires the visual inspection of a steel cylinder to be performed in accordance with CGA Pamphlet C-6. The HMR and CGA Pamphlet C-6 are silent on the level of paint that would inhibit visual inspection of a cylinder. It is our opinion that excessively caked paint or evidence of exfoliation, such as peeling, blistering or scaling paint, warrants the removal of the paint in the affected area to detect abnormalities that indicate a potential or actual weakness that could make the cylinder unsafe for transportation.

I hope this satisfies your inquiry.



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