Interpretation Response #15-0042 ([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 25, 2015
Ms. Nida Chaudhary
Transport Canada, TDG
Place de Ville, Tower C, 9th Floor
330 Sparks Street
Ottawa, Ontario K1A 0N5
Ref. No.: 15-0042
Dear Ms. Chaudhary:
This is a response to your February 27, 2015 email requesting further clarification of the requalification of Department of Transportation (DOT) specification cylinders under § 180.209 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) with respect to guidance provided in letter of interpretation (LOI) Ref. No. 14-0067 issued June 5, 2014.
In the 14-0067 LOI, you sought clarification on the requalification requirements applicable to DOT specification cylinders that have an outside diameter of 2 inches or less and are less than 2 feet in length. You cited Note 1 to Table 1 (Requalification of Cylinders) in § 180.209 which states that "any cylinder not exceeding 2 inches outside diameter and less than 2 feet in length is excepted from volumetric expansion test." You specifically asked whether DOT specification cylinders below that size are subject to requalification by proof pressure test or an internal visual inspection.
In our response to that question, we answered that "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)."
In your February 27, 2015 email, you ask for additional clarification and regulatory insight. Your questions are answered as follows:
Q1. Is a cylinder less than 2" OD and 2' length exempt from all periodic requalification requirements?
A1. The answer is yes. Small specification cylinders not exceeding 2 inches in outside diameter and less than 2 feet in length are not subject to the periodic requalification in § 180.209(a). 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).
Q2. Specifically, for a cylinder such as a DOT-3AL that is less than 2" OD and 2' length, is there a requirement for the cylinder to undergo an EXTERNAL visual examination, be marked by a facility with a RIN, and have a record kept of this requalification?
A2. The answer to this group of questions is no. Please see A1.
Q3. Is the exemption for these smaller cylinders with regards to periodic requalification an exemption like that for the DOT-3E and DOT-4L specifications?
A3. The exemptions for periodic requalifications of the cylinders you listed are similar. Please see A1.
I hope this information is helpful. If you have any more questions, please do not hesitate to contact this office.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
180.209, 180.205(d)