Interpretation Response #05-0270 ([Fire Protection Certification] [Mr. Edward O'Brien])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Fire Protection Certification
Individual Name: Mr. Edward O'Brien
Location State: MD Country: US
View the Interpretation Document
Response text:
Jan 5, 2006
Mr. Edward O"Brien Reference No. 05-0270
President
Fire Protection Certification
8719 Pete Wiles Road
Middletown, MD 21769
Dear Mr. O"Brien:
This is in response to your October 12, 2005 letter requesting clarification of the record retention requirements for cylinder requalifiers under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask which number a requalifier should maintain in his records as the serial number when recording the performance of a 1 2-year hydrostatic test on a DOT 4B cylinder used as a fire extinguisher. You indicate that two numbers are marked on the cylinder - a batch number that applies to an entire lot of cylinders is stamped on the shell, and a serial number is displayed on the manufacturer"s label. The cylinder was manufactured by Amerex Corporation.
Section 178.35(f) requires each specification cylinder to be marked with a serial number. For the purpose of cylinder identification, § 180.2 15(b)(2) requires the person performing cylinder requalification to record and retain the serial number of the cylinder that was tested.
In the situation you describe, it is likely that the cylinder was manufactured by Amerex Corporation under DOT exemption DOT-E 9837. The exemption authorizes Amerex Corporation to stamp the lot number instead of the serial number on DOT 4B cylinders. The lot must consist of less than 500 cylinders and each cylinder must have a volumetric capacity not exceeding 170 cubic inches and a service pressure not exceeding 200 psig. Assuming that your cylinder meets DOT-E 9837, your records should display the lot number that is permanently stamped in the cylinder. The serial number may be entered as additional information to clearly identify the cylinder.
I hope this information is helpful. Please contact us if you require additional assistance.
Sincerely,
John A. Gale
Chief, Regulations Development
Office of Hazardous Materials Standards
180.215(b)(2)
Regulation Sections
| Section | Subject |
|---|---|
| 180.215 | Reporting and record retention requirements |