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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 #13-0224 ([Linde North America, Inc.] [Mr. Guy Dalton])

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

Interpretation Response Details

Response Publish Date:

Company Name: Linde North America, Inc.

Individual Name: Mr. Guy Dalton

Location State: OH Country: US

View the Interpretation Document

Response text:

January 28, 2014

Mr. Guy Dalton
Fleet Compliance and Safety Manager
Linde North America, Inc.
130 Briar Hill
Painesville, OH 44077

Reference No.: 13-0224

Dear Mr. Dalton:

This is in response to your November 15, 2013 letter and conversation with a member of my staff requesting clarification of the requirements for the use and requalification of Transport Canada (TC) specification cylinders under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Your questions are paraphrased and answered as follows.

Q1. May a cylinder stamped “DOT” and “TC” and requalified by a Transport Canada retest facility within the last 5 years be filled and transported in the United States?

A1. A United States-based facility is permitted to fill and transport a cylinder marked as meeting a TC specification provided the cylinder conforms to and is also marked with a corresponding DOT specification.  However, the cylinder must be requalified and marked as prescribed in Subpart C of part 180. (see § 173.301(a)(1)).

Q2. Are there restrictions on the use of a cylinder stamped “DOT” and “TC” based on the date of manufacture that would impact the use of these cylinders or cross border shipments?

A2. No, provided the cylinder that is stamped “TC” conforms to and is also stamped with a corresponding “DOT” specification.

Q3.  May a DOT specification cylinder that is requalified by an authorized TC retest facility within the last 5 years be filled and transported in the United States?

A3.  An authorized TC retest facility may only requalify a DOT specification cylinder if the facility is also approved to requalifiy DOT specification cylinders in accordance with § 180.205.

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

173.301, 180.205

Regulation Sections

Section Subject
173.301 General requirements for shipment of compressed gases and other hazardous materials in cylinders, UN pressure receptacles and spherical pressure vessels
180.205 General requirements for requalification of specification cylinders