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Interpretation Response #14-0053 ([Department of the Air Force] [Mr. Brett Schlueter])

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

Interpretation Response Details

Response Publish Date:

Company Name: Department of the Air Force

Individual Name: Mr. Brett Schlueter

Location State: OK Country: US

View the Interpretation Document

Response text:

May 12, 2014

Mr. Brett Schlueter
423 SCMS/GUEA
3001 Staff Dr. Ste. IAC1-100B
Tinker AFB, OK 73145

Ref No.: 14-0053

Dear Mr. Schlueter:

This is a response to your March 18, 2014 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) with regard to requalification markings on DOT specification cylinders and DOT Special Permit (DOT-SP) Cylinders used as fire extinguishers.  Specifically, you request clarification on what specifications or types of cylinders may be marked using a pressure sensitive label.

In your email you indicate you are performing requalifications of DOT 4D, DOT 4DA, DOT 4DS, DOT-SP 7945, DOT-SP 7971, DOT-SP 8439, and DOT-SP 8495 cylinders that are used as fire extinguishers. Requirements for requalification markings for cylinders are found in
§ 180.213.  In accordance with § 180.213(c)(1), cylinders used as fire extinguishers may be marked using a pressure sensitive label.  This paragraph is not limited to DOT specification cylinders listed in § 180.209(j), but applies to all cylinders used as fire extinguishers.  

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

Sincerely,

Robert Benedict
Chief, Standards Development
Standards and Rulemaking Division

180.209, 180.213

Regulation Sections

Section Subject
180.209 Requirements for requalification of specification cylinders
180.213 Requalification markings