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Interpretation Response #15-0174 ([Japan Aero Pressure Co., Ltd.] [Mr. Takashi Hashimoto])

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

Interpretation Response Details

Response Publish Date:

Company Name: Japan Aero Pressure Co., Ltd.

Individual Name: Mr. Takashi Hashimoto

Country: JP

View the Interpretation Document

Response text:

June 29, 2016

Mr. Takashi Hashimoto
Chief Operating Officer
Japan Aero Pressure Co., Ltd.
2-1-8 Kokaba Iwatsuki-ku
Saitama-City Saitama
339-0072 Japan

Reference No. 15-0174

Dear Mr. Hashimoto:

This letter is in response to your email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the marking of cylinders. Specifically, you ask whether chemical etching is an acceptable cylinder requalification marking method under § 180.213(c).

The answer is yes. Requalification markings must conform to requirements in § 180.213, including minimal wall thickness and specifications for the marking size and location. Further, each cylinder must be plainly and permanently marked on the metal of the cylinder as permitted by the applicable specification. Provided all applicable conditions are met, the HMR permit the chemical etching of requalification markings on cylinders.

I hope this information is helpful. Please contact us if we can be of further assistance.



T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

180.213(c), 180.213

Regulation Sections

Section Subject
180.213 Requalification markings