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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #07-0118 ([Northwest Airlines Inc.] [Mr. David A. Tikaisky])

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

Interpretation Response Details

Response Publish Date:

Company Name: Northwest Airlines Inc.

Individual Name: Mr. David A. Tikaisky

Location State: MN Country: US

View the Interpretation Document

Response text:

Jul 16, 2007

Mr. David A. Tikaisky                 Reference No. 07-0118


DG Programs System Stores

Northwest Airlines Inc.

2700 Lone Oak Parkway

Eagan, MN 55121

Dear Mr. Tikalsky:

This is in response to your June 18, 2007 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to special permit cylinders. Your scenario is based on DOT- SP 12955 that specifies "No cylinder is authorized 15 years after the date of manufacture marked on the cylinder." Specifically, you ask if a DOT-SP 12955 cylinder may be transported after its service life has expired in accordance with § 173.301 (a)(7).

The answer is yes. DOT-SP 12955 does not prohibit the use of § 173.301(a)(7). Section 173.301(a)(7) allows a cylinder to be offered for transportation in commerce after its authorized service life has expired if the cylinder was filled prior to the expiration of its authorized service life, and it is transported for reprocessing or disposal of the cylinder's contents. Once the cylinder has been emptied, it must be condemned in accordance with

§ 180.205.

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


Regulation Sections

Section Subject
173.301 General requirements for shipment of compressed gases and other hazardous materials in cylinders, UN pressure receptacles and spherical pressure vessels