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Interpretation Response #07-0082 ([City Carbonic Sales & Service, Inc.] [Ms. Amy Morgan Bruecks])

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

Interpretation Response Details

Response Publish Date:

Company Name: City Carbonic Sales & Service, Inc.

Individual Name: Ms. Amy Morgan Bruecks

Location State: OK Country: US

View the Interpretation Document

Response text:

May 17, 2007


Ms. Amy Morgan Bruecks                 Reference No. 07-0082
City Carbonic Sales & Service, Inc.
406 S.W. 4th St.
Oklahoma City, OK 73109

Dear Ms. Bruecks:

This is in response to your letter requesting clarification of the requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to cylinders manufactured of 6351-T6 aluminum alloy and used in self-contained underwater breathing apparatus (SCUBA), self-contained breathing apparatus (SCBA), or oxygen service. Specifically, you ask whether only these specific cylinders may be eddy current tested and marked with the VE marking as required by § 180.209 and 180.213, respectively.

The answer is no. Any cylinder may be eddy current tested and marked with the VE marking regardless of whether the test is required for the particular cylinder. For those cylinders for which the eddy current test and marking are not required. the test exceeds the HMR requirements and is not prohibited.

I hope this information is helpful. Please contact this office if you have additional questions.



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


Regulation Sections

Section Subject
180.209 Requirements for requalification of specification cylinders