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Interpretation Response #06-0133 ([Global Fire and Safety, Inc.] [Mr. Bill McDonald ])

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

Interpretation Response Details

Response Publish Date:

Company Name: Global Fire and Safety, Inc.

Individual Name: Mr. Bill McDonald 

Location State: CA Country: US

View the Interpretation Document

Response text:

Jun 30, 2006


Mr. Bill McDonald                Reference No. 06-0133
Global Fire and Safety, Inc.
2601 Adeline Suite 150
Oakland, CA 94607

Dear Mr. McDonald:

This is in response to your June 6, 2006 letter requesting clarification regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171.180) to your exemption cylinder. In your scenario, you have an exemption cylinder marked DOT E-8795. This exemption authorizes the manufacture, mark, sale and use of certain non-DOT specification cylinders conforming to the DOT 4B240ET specification with certain exceptions. Specifically, you ask if your exemption cylinder may be requalified in accordance with § 180.209(g), which allows for external visual inspections of cylinders used exclusively for certain named gases.

The answer is yes. Upon review by the Office of Hazardous Materials Special Permits and Approvals, it has been determined that the cylinder specified in your request may be requalified in accordance with § 180.209(g).

I hope this information is helpful.



Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards

180.209 (g)

Regulation Sections

Section Subject
180.209 Requirements for requalification of specification cylinders