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Interpretation Response #12-0242


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

Interpretation Response Details

Response Publish Date: 01-03-2013
Company Name: NK CO., LTD    Individual Name: Mr. Hyun-Joon Ji
Country: KR

View the Interpretation Document


Response text:

January 22, 2013

Mr. Hyun-Joon Ji
Assistant Manager
Quality Inspection Team
NK CO., LTD
497, Sinpyeong-dong, Saha-gu,
Busan 604-030, Korea 

Ref. No.: 12-0242

Dear Mr. Ji:

This is in response to your October 24, 2012 email concerning the requirements for cylinders in accordance with the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically you request confirmation of your understanding of the appropriate lot size for conducting the physical tests on DOT 3AA and DOT 3AAX cylinders.  In your letter you describe a scenario in which cylinders are subjected to heat treatment two at a time in a continuous furnace using a conveyor.  Specifically you ask if cylinders continuously fed into the heat treatment furnace may be considered the same lot for the purposes of conducting the physical tests in accordance with § 178.37.

Provided each of the cylinders were processed through the same equipment under the same conditions of time and temperature those cylinders may be considered the same lot for the purposes of testing in accordance with § 178.37.

I hope this information is helpful.  If you have further questions, please do not hesitate to contact this office.

Sincerely,

Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division

178.37


Regulation Sections

Section Subject
§ 178.37 Specification 3AA and 3AAX seamless steel cylinders