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Interpretation Response #11-0272 ([Safetech] [Mr. Robert Holley])

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

Interpretation Response Details

Response Publish Date:

Company Name: Safetech

Individual Name: Mr. Robert Holley

Location State: TX Country: US

View the Interpretation Document

Response text:

March 30, 2012



Mr. Robert Holley
1230 Wilson Court
Humble, TX 77396


Ref. No. 11-0272


Dear Mr. Holley:

This responds to your October 28, 2011 request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding recordkeeping requirements applicable to a person who requalifies, repairs, or rebuilds cylinders.  Your questions are paraphrased and answered as follows:

Q1.  Is it acceptable to have the latest editions of the required Compressed Gas Association (CGA) publications in place of the editions incorporated by reference in § 171.7?

A1.  The answer is yes, if it contains the same applicable information that is in the incorporated edition.  Section 180.215(a)(6) requires a person who requalifies, repairs, or rebuilds cylinders to maintain the "information contained in each applicable CGA or [American Society for Testing and Materials] (ASTM) standard incorporated by reference in § 171.7 applicable to the requalifier"s activities."  A more recent CGA publication may be used to satisfy this requirement provided the more recent edition contains the same relevant information that is contained in the edition incorporated by reference in § 171.7.

Q2.  Should independent inspectors and enforcement inspectors be allowed to demand or suggest that the facility have the latest edition of the required CGA publication(s) if they are not the same as the cited edition?

A2.  The answer is no.  Unless otherwise specified in a special permit issued by the Pipeline and Hazardous Materials Safety Administration (PHMSA), the HMR only require a cylinder requalifer to have the information contained in the applicable CGA publications incorporated by reference in § 171.7.

I hope this answers your inquiry.  If you need additional assistance, please contact this office at (202) 366-8553.


Ben Supko
Acting Chief, Standards Development
Standards and Rulemaking Division

171.7, 180. 215(a)(6)

Regulation Sections

Section Subject
171.7 Reference material
180.215 Reporting and record retention requirements