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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 #09-0236 ([Department of State INL/A] [Mr. James A. Sherman])

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

Interpretation Response Details

Response Publish Date:

Company Name: Department of State INL/A

Individual Name: Mr. James A. Sherman

Location State: FL Country: US

View the Interpretation Document

Response text:

March 28, 2011




Mr. James A. Sherman

Maintenance Production

Control Specialist

Department of State INL/A

1038 S. Patrick Dr. HGR 985

Patrick AFB, FL 32955

Ref. No. 09-0236

Dear Mr. Sherman:

This responds to your e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the requalification requirements for DOT specification 3A and 3AA cylinders as specified in § 180.209. We apologize for the delay in responding and any inconvenience it may have caused. Your questions are paraphrased and answered as follows:

Q1. Under § 180.209(b), if a cylinder is removed from a cluster, bank, group, rack, or vehicle for inspection and is not returned to that particular form of exclusive service, what must occur?

A1. As specified in § 180.209(b)(3), the cylinder must be requalified five years from the marked test date or prior to the first filling with a compressed gas if the required five-year requalification period has passed. Additionally, the "star" indicating exclusive service following the most recent test date must be obliterated.

Q2. If a cylinder is no longer in service as part of a cluster, bank, group, rack or vehicle and its inspection (requalification) becomes due, how long may the cylinder be used before it must be inspected (requalified)?

A2. As specified in § 180.205(c), no cylinder may be filled with a hazardous material and offered for transportation in commerce unless that cylinder has been successfully requalified and marked in accordance with the HMR. A cylinder filled before the requalification becomes due may remain in service until it is emptied. A cylinder with a specified service life may not be refilled and offered for transportation after its authorized service life has expired. This requirement is applicable regardless of whether the cylinder is part of a cluster, bank, group, rack, vehicle, or otherwise.

Q3. Please define "cluster, bank, group, rack or vehicle" as it is used in the HMR.

A3. The term "cluster, bank, group, rack or vehicle" is not currently defined in the HMR. As used in

§ 180.209(b), it represents a generalization of a type of service where one or more cylinders are secured and transported in or on a vehicle in a cluster, bank, group or rack specifically designed for such transportation. See § 177.840(a).

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


T. Glenn Foster

Chief, Regulatory Review and Reinvention Branch

Standards and Rulemaking Division

180.209(b), 180.205(c), 177.804(a)

Regulation Sections

Section Subject
177.840 Class 2 (gases) materials
180.205 General requirements for requalification of specification cylinders
180.209 Requirements for requalification of specification cylinders