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Interpretation Response #08-0082 ([Hydro-Test Products, Inc.] [Mr. Tom Sauta])

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

Interpretation Response Details

Response Publish Date:

Company Name: Hydro-Test Products, Inc.

Individual Name: Mr. Tom Sauta

Location State: MA Country: US

View the Interpretation Document

Response text:

May 13, 2008

Mr. Tom Sauta

Hydro-Test Products, Inc.

85 Hudson Road

Stow, MA 01775

Ref. No.: 08-0082

Dear Mr. Sauta:

This is in response to your March 14, 2008 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding cylinder requalification. Your questions are paraphrased and answered below.

Q1: Do the HMR allow for a cylinder requalifier to have and use the most current edition of a referenced CGA publication when the referenced CGA publication in § 171.7 is an older edition?

A1. Yes. Sections 107.805(f) and 180.215(a)(6) specify that each cylinder requalifier must be trained and have "the information contained in each applicable CGA or ASTM standard incorporated by reference in § 171.7 of this subchapter applicable to the requalifier"s activities." Therefore, the requalifier does not need the actual CGA publication referenced as long as the requalifier has a document that contains the same information as the referenced CGA publication, which may include an updated version.

Q2: Is a requalifier required to have the latest edition of a required CGA publication if it is not the same as the cited edition?

A2. No. The requalifier is required to have the information contained in the referenced CGA publication as stated in A1 above.

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

171.1, 107.805(f), 180.215(a)(6)

Regulation Sections

Section Subject
171.7 Reference material