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Interpretation Response #05-0287 ([Airgas, Inc.] [Mr. John Anderson])

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

Interpretation Response Details

Response Publish Date:

Company Name: Airgas, Inc.

Individual Name: Mr. John Anderson

Location State: WY Country: US

View the Interpretation Document

Response text:

Feb 3, 2006


Mr. John Anderson                       Reference No. 05-0287
Director of DOT Operations
Airgas, Inc.
P0 Box 20067
Cheyenne, WY 82003

Dear Mr. Anderson:

This is in response to your letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding verification of cylinder testing equipment to within ±1.0% of the calibrated cylinder’s pressure and corresponding expansion values. Specifically, you ask if § 1 80.205(g)(4) requires a retester to demonstrate calibration for more than one test jacket if multiple test jackets are used to test cylinders that day.

In accordance with § 1 80.205(g)(4), the test equipment must be verified to be accurate within ±1.0% of the calibrated cylinder’s pressure and corresponding expansion values. The retester achieves verification by demonstrating calibration of the test equipment used to retest cylinders that day. An authorized inspector may request a demonstration of any or all test equipment used to test cylinders. Any configuration of test jacket and test heads used to retest cylinders that day is subject to demonstration at the inspector’s request. Therefore, even if you demonstrate calibration with one test jacket, at the discretion of the authorized inspector, you may be required to demonstrate that additional testing equipment used to test
cylinders that day is properly calibrated.

I hope this information is helpful. Please contact us if you require additional assistance.



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

180.205 (g)(5)

Regulation Sections

Section Subject
180.205 General requirements for requalification of specification cylinders