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Interpretation Response #05-0239 ([CTC Certified Training Co] [Mr. Darrell K. Garton])

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

Interpretation Response Details

Response Publish Date:

Company Name: CTC Certified Training Co

Individual Name: Mr. Darrell K. Garton

Location State: CO Country: US

View the Interpretation Document

Response text:

May 24, 2006

 

Mr. Darrell K. Garton                         Reference No. 05-0239
CTC Certified Training Co.
62537 N. Star Dr.
Montrose,CO 81401

Dear Mr. Garton:

This responds to your letter requesting reconsideration of a previous interpretation (Ref. No. 03-0164) sent to you regarding whether the proof pressure test prescribed in § 180.209(e) may be performed on certain DOT-4 series cylinders used for refrigerant gas recovery.

Because of the possibility that these cylinders are subject to unknown contamination during the recovery process, you disagree with us that the proof pressure test, authorized as an alternative, is acceptable to be performed on DOT-4 series cylinders used as refrigerant gas recovery cylinders.

Although industry practice appears to take the position that all refrigerant gas recovery systems are contaminated, we believe it is the shipper’s responsibility to determine ii a refrigerant gas cylinder is “commercially free from corroding components”, and thus can take advantage of the alternative testing authorized in § 180.209(e). There is nothing in the HMR prohibiting such testing, and there is no exception in the HMR to this practice under the circumstances you described.

If you wish to add, amend or delete a regulation, you may petition for rulemaking under the requirements in § 106.95 and 106.100.

I hope this information is helpful. If we can be of further assistance, please contact us.

Sincerely,

 

John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards

180.209(e)

Regulation Sections

Section Subject
180.209 Requirements for requalification of specification cylinders