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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 #11-0058 ([Airspeed Press] [Mr. Steve Lindblom])

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

Interpretation Response Details

Response Publish Date:

Company Name: Airspeed Press

Individual Name: Mr. Steve Lindblom

Location State: NH Country: US

View the Interpretation Document

Response text:

April 13, 2011

 

 

 

Mr. Steve Lindblom

Airspeed Press

79 Old Denny Hill Rd

Warner NH 03278

Reference No.: 11-0058

Dear Mr. Lindblom:

This responds to your email regarding the requalification marking requirements for Department of Transportation (DOT) specification cylinders under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows:

Q1. If a dive shop has stamped markings not required by the HMR on the crown of a specification cylinder (i.e. cylinder owner"s name), would the cylinder be required to be condemned?

A1. The answer is no. In accordance with § 173.301(b), required markings on a specification cylinder must be legible and must meet the applicable requirements of subpart C of part 180 of the HMR. Additional information may be marked on the cylinder provided it does not affect the required markings prescribed in the applicable cylinder specification. Non-DOT markings (e.g., company name, address) are authorized provided they are made in low stress areas other than the side wall and are not of a size and depth that will create harmful stress concentrations. The presence of stamped markings not required by the HMR on the crown of a specification cylinder would not require condemnation unless the cylinder also meets the condemnation requirements for cylinders found in

§ 180.205(i).

Q2. If an authorized cylinder requalifier stamps a cylinder with an unauthorized marking or a marking not required by the HMR (i.e., a "+" after the hydrostatic test date on a Special Permit cylinder, or the words "No Plus" after the hydrostatic test marking on a 3AA tank that had failed the EE 10% overfill test), would the cylinders be required to be condemned? If the cylinder is not required to be condemned, would the improper markings need to be obliterated?

A2. In accordance with § 180.205(b), no person may mark a cylinder with a Retester Identification Number and a requalification date or otherwise represent that a DOT specification or special permit cylinder has been requalified unless all applicable requirements of this subpart have been met. The "+" marking on a cylinder indicates that a cylinder complies with § 173.302a(b) and is permitted to be filled to a pressure 10 percent in excess of its marked service pressure. Therefore, marking "+" on a specification cylinder not meeting the requirements in § 173.302a(b) would be prohibited. In addition, in accordance with the condemnation requirements for cylinders found in § 180.205(i), this cylinder is not required to be condemned. However, the cylinder would not be permitted to be offered for transportation until the incorrect markings are obliterated or removed.

Further, as stated in A1, there is no prohibition against additional markings on a specification cylinder provided those markings do not conflict with the requirements in the HMR. Therefore, marking a cylinder with the words "No Plus" is not prohibited by the HMR. However, it is strongly discouraged because this marking may diminish the effectiveness of the required markings. The presence of the marking "No Plus" on a cylinder would not require condemnation unless the cylinder also meets the condemnation requirements for cylinders found in § 180.205(i).



Q3. If a specification cylinder meets all the requirements in § 173.302a(b) at the time of requalification but the requalifier fails to mark the cylinder with the "+" at the time of requalification, is it permissible to return the cylinder to the requalifier at a later date and mark the "+" on the cylinder based on the information in the requalifier"s logbook?

A3. Although it is the intent of the HMR to mark the "+" on the cylinder at the time of requalification, provided the cylinder has not been re-filled since the time of last requalification and all the requirements of § 173.302a(b) were met at the time of the last requalification test, the marking could be applied at a later date.

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

Sincerely,

T. Glenn Foster

Chief, Regulatory Review and Reinvention Branch

Standards and Rulemaking Division

173.301, 180.205(b), 173.302a(b)

Regulation Sections

Section Subject
173.301 General requirements for shipment of compressed gases and other hazardous materials in cylinders, UN pressure receptacles and spherical pressure vessels
180.205 General requirements for requalification of specification cylinders