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Interpretation Response #19-0120

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

Interpretation Response Details

Response Publish Date: 12-19-2019
Company Name: Johnson Controls    Individual Name: Peter Gayon
Location state: WI    Country: US

View the Interpretation Document

Response text:

December 19, 2019

Peter Gayon
Manufacturing Engineer
Johnson Controls
One Stanton Street
Marinette, WI  54143

Reference No. 19-0120

Dear Mr. Gayon:

This letter is in response to your October 10, 2019, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to leakage tests performed on DOT 3A cylinders. Specifically, you ask whether it is permissible to use cameras to detect and closely examine for indications of leakage as required by § 178.36(m)(1).

The answer is yes. Section 178.36(m) specifies that all spun cylinders and plugged cylinders must be tested for leakage by gas or air pressure. A video camera may be used to perform the required examination provided that all areas can be viewed in a manner equivalent to that which would be expected if viewed directly by a person.

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

178.36(m), 178.36(m)(1)

Regulation Sections

Section Subject
§ 178.36 Specification 3A and 3AX seamless steel cylinders