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Interpretation Response #09-0222 ([FIBA Technologies, Inc.] [Mr. Christopher R. Adams])

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

Interpretation Response Details

Response Publish Date:

Company Name: FIBA Technologies, Inc.

Individual Name: Mr. Christopher R. Adams

Location State: MA Country: US

View the Interpretation Document

Response text:

October 27, 2009





Mr. Christopher R. Adams

Manager, Regulatory Affairs

FIBA Technologies, Inc.

1535 Grafton Road

Millbury, MA 01527

Ref. No. 09-0222

Dear Mr. Adams:

This responds to your e-mail requesting more information about a recently published final rule under Docket PHMSA-2006-25910 (HM-218E; April 9, 2009) that revised the mounting integrity criteria in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) for cylinders mounted on motor vehicles or in frames. You also acknowledge the May 11, 2009 effective date of amendments to the HMR in the final rule and ask if they are applicable to cylinders mounted prior to that date.

The answer is no. Cylinders mounted prior to May 11, 2009 must conform to the criteria specified in § 173.301(i) of the HMR in effect on October 1, 2008. Cylinders mounted on or after May 11, 2009 must conform to the Compressed Gas Association"s technical bulletin TB-25, adopted under the final rule as matter incorporated by reference in § 171.7 of the HMR. Although we intend to monitor very closely any incident trend involving cylinders mounted prior to the effective date of the final rule, it is our understanding there was already widespread use of CGA TB-25, an industry consensus standard in place since 2005 (and revised in 2008) that was specifically implemented to enhance the safe transportation of such cylinders mounted in frames.

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

173.301(i), 171.7

Regulation Sections

Section Subject
171.7 Reference material
173.301 General requirements for shipment of compressed gases and other hazardous materials in cylinders, UN pressure receptacles and spherical pressure vessels