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Interpretation Response #07-0204 ([E.I. DuPont de Nemours & Co.] [Mr. Kevin M. Greene])

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

Interpretation Response Details

Response Publish Date:

Company Name: E.I. DuPont de Nemours & Co.

Individual Name: Mr. Kevin M. Greene

Location State: AL Country: US

View the Interpretation Document

Response text:

January 8, 2008

Mr. Kevin M. Greene

Hazardous Materials Distribution Consultant

E.I. DuPont de Nemours & Co.

12650 Highway 43 North

Axis, Alabama 36505

Ref. No.: 07-0204

Dear Mr. Greene:

This is in response to your request for a clarification of the packaging notification requirements in Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the packaging notification requirements in § 178.2(c)(1)(i) apply to cylinders.

The answer is no. Section 178.2(c)(1)(i) requires written notification to each person to whom a packaging is transferred of all Part 178 requirements not met at the time of transfer. A cylinder manufactured under Part 178, Subpart C must be in full conformance with all specification requirements at the time of transfer. The cylinder manufacturer certifies that these requirements have been met by marking the applicable DOT specification marking on the cylinder, eg. DOT-3A, DOT-4BW. Additionally, the cylinder inspector is responsible for ensuring each cylinder made is in full conformance with all specification requirements. See § 178.35(c) of the HMR.

In addition, you refer to a December 1, 2005 interpretation letter (Ref. No.: 05-0209) from this office in which we specify that paragraph (c) should include a reference to § 178.338-19 and that current reference to § 178.345-10 should be replaced with § 178.345-15. You ask when we plan to implement these corrections. We are currently considering revisions to the cargo tank specifications and plan to include these corrections in that rulemaking.

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

178.2, 178.35, 178.345-15

Regulation Sections

Section Subject
178.345-15 Certification
178.35 General requirements for specification cylinders