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Interpretation Response #06-0276 ([Thunderbird Cylinder, Inc.] [Mr. Fred A. Nachman])

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

Interpretation Response Details

Response Publish Date:

Company Name: Thunderbird Cylinder, Inc.

Individual Name: Mr. Fred A. Nachman

Location State: AZ Country: US

View the Interpretation Document

Response text:

Nov 14, 2007

Mr. Fred A. Nachman                                 Ref. No.: 06-0276

Thunderbird Cylinder, Inc.

4209 E. University Drive

Phoenix, AZ 85034-7315

Dear Mr. Nachman:

This is in response to your request for a clarification of the cylinder requalification requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows:

Q1. Is a leakproofness test required under § 180.209(g)? If yes, how is the test performed?

A1. Yes. Section 180.209(g) specifies that the external visual inspection must be performed on the named cylinders in accordance with either Compressed Gas Association (CGA) C-6 or CGA 6.3, as applicable. CGA C-6 requires the use of soap or other suitable solution to check for leaks. CGA C-6.3 is silent concerning how to detect leaks. Based on the provisions in CGA C 6, a gas sniffer may be used in addition to coating the cylinder with soap or other solution, but not in place of these methods.

Q2. Under the non-bulk packaging reuse requirements in § 173.28, paragraph (b)(2)(i) requires packagings subject to the leakproofness test in § 178.604 to be retested without failure. Does this provision apply to cylinders?

A2. No. Section 178.600 specifies that the testing requirements in Part 178, Subpart M (§§ 178.600 through 178.609) apply to the performance oriented packagings identified in Part 178, Subpart L. Cylinder requirements are specified in Part 178, Subpart C and, therefore, are not subject to the leakproofness testing requirements in § 178.604.

Q3. Do the HMR require all DOT specification cylinders to be marked with a tare weight?

A3. No. Unless otherwise specified in the HMR, DOT specification cylinders are not required to be marked with the tare weight.

Q4. When should the cylinder requalifer verify the tare weight on a DOT specification cylinder?

A4. Currently, the HMR require verification of the tare of DOT 4-series and 8-series cylinders, under certain conditions. See § 180.209(c) and (i) respectively.

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.



Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials, Standards

File: 173.28, 180.209

SC: Cylinder Testing

Regulation Sections

Section Subject
173.28 Reuse, reconditioning and remanufacture of packagings
180.209 Requirements for requalification of specification cylinders