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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #17-0056

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: Chris Adams

Location State: MA Country: US

View the Interpretation Document

Response text:

September 26, 2017
Chris Adams
Manager, Regulatory Affairs
FIBA Technologies, Inc.
53 Ayer Road
Littleton, MA  01406
Reference No. 17-0056
Dear Mr. Adams:
This letter is in response to your May 25, 2017, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the repair of seamless DOT 3-series specification cylinders.  You describe a scenario in which a DOT 3AAX specification cylinder was not equipped with external neck threads at the time of manufacture.  You ask if the cylinder may be threaded with external threads and be considered a “re-threaded” repair under the provisions of § 180.212(b)(2), and therefore not require prior approval.
The answer is no.  The provisions of § 180.212(b)(2) apply only to cylinders already machined with threads.  If a person wishes to machine external threads on a cylinder originally manufactured without external threads, the work must be done in accordance with § 180.212(a), which requires an approval under Part 107, Subpart H.
I hope this information is helpful.  Please contact us if we can be of further assistance.

Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
180.212(b)(2), 180.212(a)

Regulation Sections

Section Subject
180.212 Repair of seamless DOT 3-series specification cylinders and seamless UN pressure receptacles