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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 #12-0091 ([Chief Daniel H. Graves] [St. Pete Beach Fire Department])

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

Interpretation Response Details

Response Publish Date:

Company Name: Chief Daniel H. Graves

Individual Name: St. Pete Beach Fire Department

Location State: FL Country: US

View the Interpretation Document

Response text:

June 25, 2012



Daniel H. Graves
Fire Chief
St. Pete Beach Fire Department
7301 Gulf Boulevard
St. Pete Beach, FL 33706

Ref. No.: 12-0091

Dear Chief Graves:

This responds to your March 14, 2012 letter regarding the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they pertain to carbon fiber wrapped cylinders marked with Department of Transportation Exemption (DOT-E) 10915 (renamed special permit (SP) 10915). Cylinders manufactured under this special permit are limited to a fifteen (15) year service life.

Composite cylinders older than their authorized service life may have reduced strength without any visual indication of damage. At this time, there is no effective non-destructive method of detecting the degree of strength loss for a composite cylinder. We are aware of, and concerned about, the financial burden associated with limiting the service life of composite cylinders, but PHMSA must weigh this burden against the safety risk of a cylinder failure to firefighters and other users.
A service life extension approval may only be accommodated by modification of the special permit authorizing cylinder construction. Accordingly, no service life extension is authorized for cylinders manufactured in accordance with DOT-SP 10915. Therefore, once a cylinder marked DOT-E 10915 or DOT-SP 10915 has reached the end of its authorized service life, it must be condemned in accordance with § 180.205.

I hope this information is helpful. If you have further questions, please contact this office.



Robert Benedict
Chief, Standards Development
Standards and Rulemaking Division


Regulation Sections

Section Subject
180.205 General requirements for requalification of specification cylinders