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Interpretation Response #18-0127

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

Interpretation Response Details

Response Publish Date:

Company Name: Dominion Technology Gases Ltd.

Individual Name: Eric Watson

Location State: Aberdeen AB21 0GP Country: GB

View the Interpretation Document

Response text:

April 8, 2019

Eric Watson
Dominion Technology Gases Ltd.
Howe Moss Avenue
Kirkhill Industrial Estate
Dyce, Aberdeen AB21 0GP
United Kingdom

Reference No. 18-0127

Dear Mr. Watson:

This letter is in response to your October 5, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to cylinder requalification.  You state that your company has a fleet of United Nations (UN) ISO 9809-2, USA/M8304 cylinders that you intend to retest (requalify) in the United Kingdom under ISO 6406 once they reach their 10-year requalification period.  However, you note that testing will be done without a United States Requalification Identification Number (RIN).  Specifically, you ask whether these cylinders may be used and transported in the United States after being requalified.

The answer is no.  UN pressure vessels due for requalification cannot be filled and offered for transportation in commerce unless they have been successfully requalified and marked in accordance with the HMR (see § 180.207(a)(2)).  Section 180.205(b) states that no person may represent that a repair or requalification of a cylinder has been performed in accordance with the HMR unless that person holds a current approval issued under the procedural requirements in Subpart I of 49 CFR Part 107 (see § 107.801).  Therefore, the facility where the cylinders are to be tested (requalified) must be an approved and authorized RIN holder.

If a facility is not an authorized RIN holder and seeks approval to engage in the requalification of UN pressure receptacles, an Independent Inspection Agency (IIA) must conduct a review of a facility’s requalification operations.  Once the review has been completed with satisfactory results, the applicant (ex., Dominion Technology Gases Ltd.) must submit a letter of recommendation from the IIA, an inspection report, and an application certifying that the facility will perform requalification operations for UN pressure receptacles in compliance with the applicable requirements of the HMR (see § 107.805).

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

Sincerely,

Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division

180.207(a)(2), 180.205(b), 107.801, 107.805

Regulation Sections

Section Subject
107.801 Purpose and scope
107.805 Approval of cylinder and pressure receptacle requalifiers
180.205 General requirements for requalification of specification cylinders
180.207 Requirements for requalification of UN pressure receptacles