Interpretation Response #06-0093 ([Mr. Bill Korzeniowski ])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name:
Individual Name: Mr. Bill Korzeniowski
Location State: IL Country: US
View the Interpretation Document
Response text:
Jun 5, l2006
Mr. Bill Korzeniowski Reference No. 06-0093
Air Liquide
318 Hampshire Lane
Crystal Lake, IL 60014
Dear Mr. Korzeniowski:
This is in response to your April 6, 2006 letter requesting clarification regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to marking of cylinders. Your scenario is based on the marking of a cylinder with a star under the provisions in § 180.209(b) when the star is used to indicate the cylinder has a requalification period of ten years instead of five. Your questions are paraphrased and answered below.
Q1. Is the owner of a cylinder authorized to stamp a star on the cylinder, or is it only allowed to be done by the testing agency?
Al. The cylinder owner may mark a star on the cylinder if it complies with the provisions in § 180.209(b), and the consent of the testing agency that performed the most recent test is obtained.
Q2. May an owner of a cylinder stamp a star on a cylinder that has been in service
and there is supporting documentation that the cylinder has met all the criteria of
§ 180.209(b)(1)?
A2. The answer is yes, if the cylinder has not been in service over five years. Also, see Al.
I hope this information is helpful.
Sincerely,
Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards
180.219 (b)(1)