Interpretation Response #07-0139 ([Strike First Corporation] [Ms. Angie Williams])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Strike First Corporation
Individual Name: Ms. Angie Williams
Location State: MA Country: US
View the Interpretation Document
Response text:
Nov 19, 2007
Ms. Angie Williams Ref. No.: 07-0139
Vice-President
Strike First Corporation
85 Hudson Road
Stow, Massachusetts 01775
Dear Ms. Williams:
This is in response to your June 28, 2007 letter and subsequent e-mail correspondence from your Chief Operations Officer regarding the fire extinguisher requirements in § 173.309(a) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
You reference our May 8, 2007 response (Ref. # 07-0070) to Edward O'Brien, of Fire Protection Certification, in which we stated your company's fire extinguisher submitted to us for review does not conform to the provisions in § 173.309(a) and, when charged, may not be offered for transportation in commerce. We also stated the non-DOT specification fire extinguisher does not display the marking "MEETS DOT REQUIREMENTS" which is a certification that the fire extinguisher was manufactured in full conformance with the prescribed requirements.
In your letter you acknowledged that your company's fire extinguishers did not contain the certification marking. However, you stated that you are providing a label containing the certification marking to your clients for application to the fire extinguishers. Further, we were informed by Mr. Randal Joyner, Chief Operations Officer with your company, that the fire extinguishers will be full compliance with all requirements in § 173.309(a) upon applying the certification marking. Based on this additional information, we agree that your company's fire extinguishers would be in full compliance with § 173.309(a) after affixing the "MEETS DOT REQUIREMENTS" marking and, therefore, may be offered for transportation in commerce.
I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
cc: Mr. Edward O'Brien
173.309
Regulation Sections
| Section | Subject |
|---|---|
| 173.309 | Fire extinguishers |