Interpretation Response #11-0270 ([Ferrellgas LP] [Mr. Jerry Swank])

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

Interpretation Response Details

Response Publish Date: 01/26/2012

Company Name: Ferrellgas LP

Individual Name: Mr. Jerry Swank

Location State: MO Country: US

View the Interpretation Document

Response text:

January 26, 2012

Mr. Jerry Swank
Ferrellgas LP
One Liberty Plaza MD# 5
Liberty, MO 64068

Reference No.: 11-0270

Dear Mr. Swank:

This responds to your letter requesting clarification of Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the recordkeeping requirements for Department of Transportation (DOT) specification cylinders that have been visually inspected and requalified. Specifically, you ask whether the actual cylinder dimensions are required to be included on the requalification record specified in § 180.215, when a visual inspection and requalification are performed on DOT specification steel cylinders and low pressure aluminum cylinders.
The answer is yes. The actual cylinder dimensions are required to be included on the requalification record specified in § 180.215. The requirements for reporting and record retention of cylinders, including DOT specification steel cylinders and low pressure aluminum cylinders, are specified in § 180.215. In accordance with § 180.215(b)(2), the date of requalification; serial number; DOT specification or special permit number; marked pressure; actual dimensions; manufacturer's name or symbol; owner's name or symbol, if present; result of visual inspection; actual test pressure; total, elastic and permanent expansions; percent permanent expansion; disposition, with reason for any repeated test, rejection or condemnation; and legible identification of test operator must be included on the requalification record.

You also state in your incoming letter that based on the requirements of the Compressed Gas Association (CGA) Pamphlet C"6 or C"6.3 and § 180.209(g), it is your opinion that the actual dimensions of the cylinder are not required on the requalification record. As noted in your letter, the external visual inspection of a DOT specification cylinder must be completed in accordance with the CGA Pamphlet C"6 or C"6.3, as applicable. However the specific reporting and record retention requirements must be recorded and maintained in accordance with § 180.215. Further, in your letter, you state that § 180.209(g) lists specific information that visual inspection records must include and that this list makes no mention of actual cylinder dimensions. You are correct that this list does not include actual cylinder dimensions. However, this list is not all encompassing and § 180.209(g) further states that records "must be recorded and maintained in accordance with § 180.215."

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

180.215, 180.209(g)

Regulation Sections