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Interpretation Response #09-0002 ([RFD Beaufort Ltd.] [FAO Tommy Scott])

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

Interpretation Response Details

Response Publish Date:

Company Name: RFD Beaufort Ltd.

Individual Name: FAO Tommy Scott

Country: UK

View the Interpretation Document

Response text:

February 10, 2009

FAO Tommy Scott

RFD Beaufort Limited




BT17 9AF

United Kingdom

Ref. No.: 09-0002

Dear Mr. Scott:

This responds to your electronic mail requesting clarification of the Hazardous Material Regulations (HMR; 49 CFR Parts 171-180) pertaining to the approval and marking of UN pressure receptacles. Specifically you request information on the process required to obtain approval to manufacture UN pressure receptacles for transport in the United States and ask if a single UN pressure receptacle may be marked "USA" as a country of approval and bear the Transportable Pressure Equipment Directive (TPED) marks required by the European Union.

On June 12, 2006, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published a final rule entitled "Hazardous Materials: Requirements for UN Cylinders" (71 FR 33858). In this final rule, we amended the Hazardous Materials Regulations to adopt standards for the design, construction, maintenance, and use of pressure receptacles based on standards contained in the United Nations Recommendations on the Transport of Dangerous Goods.

The requirements to obtain a design-type approval to manufacture UN pressure receptacles acceptable for transportation in the United States are contained in § 178.70 and entail the following general procedures:

1. Obtain an initial design-type approval from the Associate Administrator for Hazardous Materials Safety (Associate Administrator).

2. Arrange for a pre-audit of the manufacturing facilities by an Independent Inspection Agency (IIA) approved by the Associate Administrator.

3. PHMSA will then conduct an on sight production audit in the presence of the IIA where the applicant would be required to produce pressure receptacles to the appropriate technical standard.

4. Provided the manufacturing process and the pressure receptacles are found to conform to all applicable requirements, the Associate Administrator will issue the applicant a design-type approval.

A single UN pressure receptacle may bear approval markings from multiple competent authorities. However, a UN pressure receptacle acceptable for transport to, from, or within the United States must be marked with "USA" as a country of approval in conformance with §§ 178.69 and 178.70.

Additional information concerning procedures and application requirements for approval of pressure receptacle (cylinder) manufacturers may be viewed on the PHMSA website at

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

178.70, 178.69

Regulation Sections

Section Subject
178.70 Approval of UN pressure receptacles