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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 #07-0226 ([Mr. Dave Romanin])

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name: Mr. Dave Romanin

Location State: WI Country: US

View the Interpretation Document

Response text:

January 15, 2008

Mr. Dave Romanin

115 Potomac Place

Oregon, WI 53575

Ref. No. 07-0226

Dear Mr. Romanin:

This is in response to your request for clarification of the requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) pertaining to the verification of ownership of a packaging. Specifically, you ask whether the HMR include requirements related to establishing ownership of a cylinder.

Enclosed is a letter of interpretation (Ref. No. 01-0074) issued by this office that addresses the issue of ownership of a packaging. As stated in the letter, a permission slip from a person representing himself as the owner of the packaging is sufficient proof of ownership, provided the person who is testing and filling the packaging does not have knowledge or reason to believe otherwise.

You may want to write a letter of authorization or obtain a transfer of ownership letter from the seller and present it to the company you wish to test and fill your cylinder. However, if the person filling and testing the cylinder is not satisfied, that person may refuse to provide the service.

I hope this 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



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