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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.


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

Section Subject
180.205 General requirements for requalification of specification cylinders
180.213 Requalification markings
180.213 Requalification markings
180.213 Requalification markings