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Interpretation Response #13-0146 ([FIBA Technologies] [Mr. Christopher Adams])

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

Interpretation Response Details

Response Publish Date:

Company Name: FIBA Technologies

Individual Name: Mr. Christopher Adams

Location State: MA Country: US

View the Interpretation Document

Response text:

January 16, 2014

Mr. Christopher Adams
Manager, Regulatory Affairs
FIBA Technologies
P.O. Box 360
1535 Grafton Road
Millbury, MA 01527

Ref. No.: 13-0146

Dear Mr. Adams:

This is in response to your July 9, 2013 petition for rulemaking and your telephone conversation with a member of my staff discussing a change to the requalification requirements for UN pressure receptacles in accordance with the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you note that § 180.207(d)(1) requires each seamless steel UN pressure receptacle (defined as UN cylinders and UN tubes) to be requalified in accordance with ISO 6406, however ISO 6406 addresses only UN cylinders.  

The HMR currently authorize the use of ISO 6406 to requalify UN refillable seamless steel cylinders and UN refillable seamless steel tubes.  As noted in your letter, while ISO 6406 does not specifically address requalification of UN tubes, all of the elements associated with the periodic requalification of seamless steel UN tubes are addressed and would allow a proper requalification of a UN tube.  We are aware that the current ISO 6406 has a limitation of 150 liters, which is substantially less than the maximum volume of a UN refillable seamless steel tube (3,000 liters). PHMSA participates in the ISO/TC58/SC4 working group considering revisions to that standard.  Once that revision is complete, we may consider adopting the revised standard.  

Until we adopt a revised standard that specifically addresses the requalification of UN refillable seamless steel tubes the currently adopted ISO 6406 may be used to requalify UN refillable seamless steel tubes (with a  capacity greater than 150 liters) as permitted by § 180.207.

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


Duane Pfund
International Standards Coordinator
Standards and Rulemaking Division


Regulation Sections

Section Subject
180.207 Requirements for requalification of UN pressure receptacles