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Interpretation Response #15-0203 ([FIBA Technologies, Inc.] [Mr. Christopher Adams])

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

Interpretation Response Details

Response Publish Date:

Company Name: FIBA Technologies, Inc.

Individual Name: Mr. Christopher Adams

Location State: MA Country: US

View the Interpretation Document

Response text:

March 29, 2016

Mr. Christopher R. Adams
Manager, Regulatory Affairs
FIBA Technologies, Inc.
P.O. Box 360
1535 Grafton Road
Millbury, MA  01527

Reference No. 15-0203

Dear Mr. Adams:  

This letter is in response to your October 1, 2015, e-mail and letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to training requirements.  Specifically, you refer to training for personnel who perform ultrasonic examinations to requalify seamless steel cylinders and tubes and ask if the training requirements for materials incorporated by reference in § 171.7(w) are acceptable under §§ 172.702(c) and 180.207(d)(1).  We have paraphrased your questions and answered them in the order you provided:

Q1. Are personnel requalifying United Nations (UN) pressure receptacles in conformance with ISO 6406(E) Gas cylinders—Seamless steel gas cylinders—Periodic inspection and testing, Second edition, February 2005 also required to comply with the qualification and experience requirements in ISO 9712 Non-destructive testing—Qualification and certification of non-destructive testing personnel?  ISO 9712 is referenced in Clause of ISO 6406 but is not specifically prescribed in § 171.7?

A1. The answer is yes.  Because ISO 6406(E) is incorporated by reference into the HMR under § 171.7, one must comply with all the requirements prescribed in that standard, including the requirement to comply with ISO 9712, unless otherwise excepted under the HMR.  Based on your description, this would be considered function-specific training under § 172.704(a)(2).

Q2. Are FIBA Technologies, Inc. staff authorized to perform periodic inspection and testing of seamless steel gas cylinders using the ultrasonic examination method applied in conformance with ISO 6406, excepting that the equipment shall be operated by, and its operation supervised by, personnel qualified and certified in conformance with The American Society for Non-destructive Testing (ASNT) Recommended Practice No. SNT-TC-1A, Personnel Qualification and Certification in Nondestructive Testing?  This recommended practice is not prescribed in the HMR.

A2. The answer is no.  Please refer to Answer A1.  FIBA is not authorized to perform testing using personnel certified only to ASNT.  Personnel must also be certified in accordance with ISO 9712.  

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


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

171.7(w), 172.702(c), 180.207(d)(1), 171.7,  172.704(a)(2)

Regulation Sections

Section Subject
171.7 Reference material
171.7 Reference material
172.702 Applicability and responsibility for training and testing
172.704 Training requirements
180.207 Requirements for requalification of UN pressure receptacles