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Interpretation Response #07-0117 ([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:

Jun 27, 2007


Ms. Amy Morgan Bruecks                 Reference No. 07-0117
City Carbonic Sales & Service, Inc.
406 S.W. 4 St.
Oklahoma City, OK 73109

Dear Ms. Bruecks:

This is in further reference to my May 17 response (ref. no. 07-0082) 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.

As I stated, the answer is no. Any aluminum alloy cylinder may be eddy current tested and marked with the VE marking regardless of whether the test is required for the particular cylinder. For aluminum cylinders made of other than alloy 6351-T6 for which the eddy current test and marking are not required, performance of this additional test exceeds the HMR requirements and is acceptable.

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



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

180.209, 180.213

Regulation Sections

Section Subject
180.209 Requirements for requalification of specification cylinders
180.213 Requalification markings