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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 #22-0092

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

Interpretation Response Details

Response Publish Date:

Company Name: Independent Cylinder Training

Individual Name: Amy Morgan Bruecks

Location State: OK Country: US

View the Interpretation Document

Response text:

April 19, 2023

Amy Morgan Bruecks
Independent Cylinder Training
406 S.W. 4th Street
Oklahoma City, OK  73109

Reference No. 22-0092

Dear Ms. Bruecks:

This letter is in response to your September 10, 2022, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to requalification marking of United Nations (UN) pressure receptacles requalified by the hydraulic proof pressure test method. In your email, you state that it is your belief that relevant International Organization for Standardization (ISO) standards and relevant PHMSA special permits are silent on the marking requirements for cylinders permitted to be requalified by the hydraulic proof pressure test method. Specifically, you ask whether UN pressure receptacles requalified by the hydraulic proof pressure test method are required to be marked in accordance with § 180.213(f)(4).

The answer is yes. As a general requirement, no person may mark a packaging or container as meeting the requirements of Part 180 unless marked—as appropriate—in accordance with Part 180. Section 180.207(d) authorizes the hydraulic proof pressure test for UN pressure receptacle requalification. Furthermore, § 180.207(b) states that each pressure receptacle that is successfully requalified in accordance with the requirements specified in this section must be marked in accordance with § 180.213. Therefore, UN pressure receptacles requalified by the hydraulic proof pressure test to meet the testing requirements of the HMR as authorized by § 180.207(d) must be marked in accordance with § 180.213(f)(4).

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(b), 180.207(d), 180.213, 180.213(f)(4)

Regulation Sections

Section Subject
180.207 Requirements for requalification of UN pressure receptacles
180.213 Requalification markings