Interpretation Response #24-0093
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: REM Fire Systems Inc.
Individual Name: Tim Reilly
Location State: NY Country: US
View the Interpretation Document
Response text:
February 12, 2025
Tim Reilly
REM Fire Systems Inc.
206 S. George St.
Rome, NY 13440
Reference No. 24-0093
Dear Mr. Reilly:
This letter is in response to your October 11, 2024, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to requalification requirements for compressed gas cylinders. In your email, you provide several photos and a description of Department of Transportation (DOT) specification compressed gas cylinders that were stored in a warehouse that was destroyed by a tornado. You state that the destruction of the warehouse caused the roof and walls to collapse onto the cylinders. Given this evidence of exposure to potential damage, you ask whether these cylinders must be condemned, requalified (by testing and inspection) before further use, or may continue to be used without requalification until their next scheduled test and inspection.
As provided in § 180.205(d), a cylinder must be tested and inspected in accordance with the requirements of § 180.205 prior to further use if—
(1) The cylinder shows evidence of dents, corrosion, cracked or abraded areas, leakage, or any other condition that might render it unsafe for use in transportation;
(2) The cylinder has been in an accident and has been damaged to an extent that may adversely affect its lading retention capability;
(3) The cylinder shows evidence of or is known to have thermal damage, or have been over-heated;
(4) Except in association with an authorized repair, evidence of removal of wall thickness via grinding, sanding or other means;
(5) For a cylinder subject to paragraph (c)(5) of this section, if there is visible corrosion around the neck or under the flange/sleeve, as outlined in Section 4.2 of CGA C-23, it must be removed and examined in accordance with CGA C-23 before being returned to service; or
(6) The Associate Administrator determines that the cylinder may be in an unsafe condition.
Based on the photos you provided, it is likely that the cylinders subjected to the warehouse roof and wall collapse may satisfy either of the first two of the listed conditions above that warrant testing and inspection. Specifically, a cylinder that is identified as having any of those conditions listed in § 180.205(d) must be requalified by a PHMSA-approved cylinder requalifier prior to further use, including both a visual inspection in accordance with the applicable Compressed Gas Association standard (see § 180.205(f)) and then hydrostatic testing (see § 180.205(g)). Cylinders that fail the visual inspection or hydrostatic test must be rejected or condemned in accordance with § 180.205(i) and (j), respectively.
Given the scenario in which the cylinders were recovered, a knowledgeable person, such as a cylinder requalifier, might examine them to determine whether a condition exists that meets any of the § 180.205(d) criterion. Unfortunately, it is not possible for PHMSA to make a definitive determination on your behalf whether requalification is required for each cylinder in the warehouse, based solely on the photographic evidence you provided. The person in possession of the cylinder must determine—based on their knowledge, experience, and objective evidence of the condition of each cylinder—whether a criterion in § 180.205(d) has been met.
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
180.205(d), 180.205, 180.205(f), 180.205(g), 180.205(i), 180.205(j)