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Interpretation Response #16-0050 ([Hydro-Test Products, Inc.] [Mr. Tom Sauta])

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

Interpretation Response Details

Response Publish Date:

Company Name: Hydro-Test Products, Inc.

Individual Name: Mr. Tom Sauta

Location State: FL Country: US

View the Interpretation Document

Response text:

July 25, 2016

Mr. Tom Sauta
Hydro-Test Products, Inc.
85 Hudson Road
Stow, MA 01775

Ref. No. 16-0050

Dear Mr. Sauta:

This responds to your March 15, 2016 letter requesting clarification of the cylinder requalification marking requirements under § 180.213 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you request clarification on the use of labels to satisfy the requirements in § 180.213.  Your questions are paraphrased and answered as follows:

Q1. Are cylinder requalification markings permitted on the sidewall if the marking is done with a label?

A1. As provided by § 180.213(b)(1), requalification markings may be placed on any portion of the upper end of the cylinder excluding the sidewall.

Q2. Is it acceptable to use a label with the word “CONDEMNED” in lieu of stamping “CONDEMNED” for all cylinders?

A2. The use of a label with the word “CONDEMNED” is authorized only for composite cylinders (see § 180.205(i)(2)).  

Q3. Is a label authorized to comply with the requalification marking requirements in                § 180.213 for DOT 3HT cylinders?

A4. A label is not authorized for requalification markings on DOT 3HT cylinders (see                  § 180.213(c)(2)).

I hope this answers your inquiry.  If you need additional assistance, please contact the Standards and Rulemaking Division at (202) 366-8553.

Sincerely,

Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division

180.213, 180.213(b)(1), 180.205(i)(2), 180.213(c)(2)

Regulation Sections