Interpretation Response #11-0131 ([Flightpath Services, Inc.] [Mr. Douglas Svoboda])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Flightpath Services, Inc.
Individual Name: Mr. Douglas Svoboda
Location State: NJ Country: US
View the Interpretation Document
Response text:
September 1, 2011
Mr. Douglas Svoboda
Flightpath Services, Inc.
500 Hollister Road
Teterboro, NJ 07801
Ref. No. 11-0131
Dear Mr. Svoboda:
This responds to your letter requesting clarification of the cylinder requalification provisions under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether all cylinders must be requalified before refilling or just those cylinders where requalification is due or past due. Additionally, you ask if requalification is required if a cylinder installed in an aircraft rapidly discharges (e.g., emergency inflation cylinder on a life raft) before it can be returned to service.
In accordance with § 180.205(c) of the HMR, a cylinder may be requalified at any time before or during the month and year the requalification is due. A cylinder filled before the requalification becomes due may remain in service until it is emptied. A cylinder with a specified service life or past its requalification date may not be refilled and offered for transportation after its authorized service life has expired or, it is requalified, respectively.
For a cylinder installed in an aircraft that rapidly discharges, requalification is required if the conditions specified in § 180.205(d) are met. Specifically, a cylinder must be tested and inspected, without regard to any other periodic requalification requirements, prior to further use if: (1) The cylinder shows evidence of dents, corrosion, cracked or abraded areas, leakage, thermal damage, or any other condition that might render it unsafe for use in transportation; (2) The cylinder has been in an accident and has been damaged to an extent that may adversely affect its lading retention capability; (3) The cylinder shows evidence of or is known to have been over-heated; or (4) The Associate Administrator determines that the cylinder may be in an unsafe condition.
I trust 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
180.205