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Interpretation Response #20-0086

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

Interpretation Response Details

Response Publish Date:

Company Name: Cylinder Sales and Testing, LLC d/b/a Coastal Hydrotesting

Individual Name: Jeffery Strong

Location State: MD Country: US

View the Interpretation Document

Response text:

July 28, 2021

Mr. Jeffery Strong
Manager
Cylinder Sales and Testing, LLC
d/b/a Coastal Hydrotesting
7120 Golden Ring Road
Suite 104 
Baltimore, Maryland  21221

Reference No. 20-0086

Dear Mr. Strong:

This is in response to your November 3, 2020, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to hydrotesting and ultrasonic examination of foreign compressed gas cylinders.  Your questions have been paraphrased and answered below.

Q1. You ask whether International Organization for Standardization (ISO) cylinders, manufactured with a country of approval other than the United States, must be retested in accordance with the Requalification of Cylinders table found in § 180.209 or the requirements for requalification of United Nations (UN) pressure receptacles specified in § 180.207.

A1. As discussed on page 85388 of the final rule issued under Docket No. PHMSA-2011-0140 (12/28/2020, 85 FR 85380) (HM-234) ISO cylinders with a country of approval of the United States or Canada must be tested in accordance with the test requirements in § 180.207 which specifies requirements for the requalification of UN pressure receptacles. ISO cylinders must be manufactured with a country of approval of the United States or Canada to be considered an approved package (See § 180.205(a)).

Q2. You ask whether is it acceptable to perform an ultrasonic examination on foreign ISO cylinders (i.e., manufactured with a country of approval other than the United States or Canada) under your current retester's certification letter and your current calibration standards manufactured for UN/ISO 9809-1,2,3 USA cylinders.

A2. The answer is no. Your company's Requalifier Identification Number (RIN) H949, authorizes:

"DOT cylinder specification(s): 3A, 3AA, 3AL, UN ISO: 9809-1, 9809-2 and 9809-3 and Special Permit(s): 6557 and 14175 by the "ultrasonic" test method, in accordance with Special Permit(s): 16461, 14546 and 20831."

PHMSA retester's certification letters authorize RIN holders testing authority for DOT approved cylinders. Your company's RIN does not specifically authorize testing UN ISO cylinders with a country of approval other than the United States or Canada.

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

Sincerely,

T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

180.205(a), 180.207, 180.209

Regulation Sections

Section Subject
180.205 General requirements for requalification of specification cylinders
180.207 Requirements for requalification of UN pressure receptacles
180.209 Requirements for requalification of specification cylinders