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Interpretation Response #07-0170 ([American Cap Co. L.L.C] [Mr. Kerry Hricsina])

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

Interpretation Response Details

Response Publish Date:

Company Name: American Cap Co. L.L.C

Individual Name: Mr. Kerry Hricsina

Location State: PA Country: US

View the Interpretation Document

Response text:

Mr. Kerry Hricsina                                               Ref. No.: 07-0170

Director of Engineering and Product Development

American Cap Co. L.L.C

15 Church Street

Wheatland, PA 16161

Dear Mr. Hricsina:

This responds to your August 22, 2007 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) requirements applicable to cylinder valve caps and guards. Your questions are paraphrased and answered below.

Q1. Section 173.301(h)(3) specifies that each cylinder manufactured after October 1, 2007 must have a valve assembly that is of sufficient strength or protected such that no leakage occurs when a cylinder with the valve installed is dropped 1.8 m (6 ft.) or more onto a non-yielding surface, such as concrete or steel, impacting the valve assembly or protection device at an orientation most likely to cause damage. Do the HMR allow for valve caps meeting this requirement to be marked "DOT CFR 49" to specify that they are in compliance with § 173.301(h)?

A1: Yes. Although the HMR do not require such a mark to be placed on valve caps that comply with § 173.301(h), such a marking would not be considered a prohibited mark.

Q2: Is there any requirement in the HMR for either a cylinder protection valve cap or valve guard to meet the testing requirements in the Compressed Gas Association publication, CGA V-9?

A2: No. However, we proposed to incorporate CGA V-9 into the HMR in a notice of proposed rulemaking published April 17, 2007 (72 FR 18446).


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