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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 #14-0067 ([Transport Canada, TDG] [Ms. Nida Chaudhary])

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

Interpretation Response Details

Response Publish Date:

Company Name: Transport Canada, TDG

Individual Name: Ms. Nida Chaudhary

Country: CA

View the Interpretation Document

Response text:

June 5, 2014

Ms. Nida Chaudhary
Transport Canada, TDG
Place de Ville, Tower C, 9th Floor
330 Sparks Street
Ottawa, Ontario K1A 0N5

Ref No.: 14-0067

Dear Ms. Chaudhary:

This is a response to your April 1, 2014 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) with regard to the requalification of DOT specification cylinders.  Specifically, you seek clarification on the requalification requirements applicable to DOT specification cylinders that are 2 inches or less outside diameter and less than 2 feet in length.

Sections 180.205 and 180.209 provide the requalification requirements applicable to DOT specification cylinders.  In § 180.209, Table 1 provides the minimum test pressure and requalification period for DOT specification cylinders.  Note 1 to Table 1 states that “any cylinder not exceeding 2 inches outside diameter and less than 2 feet in length is excepted from volumetric expansion test.”  You ask whether DOT specification cylinders below the size stated above are subject to requalification by proof pressure test or an internal visual inspection.

Cylinders not exceeding 2 inches in outside diameter and less than 2 feet in length are not subject to any other pressure testing requirements or an internal visual inspection.  However, small cylinders of this type must be tested and inspected prior to further use if they meet any of the criteria in § 180.205(d).

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

180.205, 180.209

Regulation Sections

Section Subject
180.205 General requirements for requalification of specification cylinders
180.209 Requirements for requalification of specification cylinders