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Interpretation Response #10-0006 ([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:

August 8, 2010






Mr. Tom Sauta

Hydro-Test Products, Inc.

85 Hudson Road

Stow, MA 01775


Ref. No. 10-0006


Dear Mr. Sauta:


This is in reference to your request for a clarification of a requirement appearing in 49 CFR 180.205(g)(6) that states training materials (e.g., CGA publication C-1.1) may be used for training persons who requalify cylinders using the volumetric expansion test methods. Specifically, you ask whether the sole use of the referenced publication would satisfy the training requirements in § 172.702. We apologize for the delay in responding and any inconvenience it may have caused.


The answer to your question is no. As you are aware, we specifically stated in the preamble of the HM-244A final rule that CGA C 1.1 could be used as guidance material to assist cylinder requalifiers in setting up their training procedures and was not to be considered as a stand-alone tool for training persons on how to perform requalification of cylinders using the volumetric expansion test method. In the final rule, we also stated we were removing the entries in §§ 171.7(b) and 180.205(g)(6) that refer to the publication. However, due to an oversight, the amendatory language was inadvertently omitted. These regulatory entries are scheduled for removal in an upcoming (HM-244C) final rule.


I hope this information is helpful. Please contact this office should you have additional questions.




T. Glenn Foster

Acting Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards



Regulation Sections

Section Subject
172.702 Applicability and responsibility for training and testing