Interpretation Response #25-0027
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Ningbo Boahulu Fire-Fighting Equipment Co., Ltd.
Individual Name: Hu Guohua
View the Interpretation Document
Response text:
Hu Guohua
General Manager
Ningbo Boahulu Fire-Fighting Equipment Co., Ltd.
No.28, Lane 155, North Jingu Road
Yinzhou District, Ningbo, China
Reference No. 25-0027
Dear Mr. Hu Guohua:
This letter is in response to your March 5, 2025, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the marking of refillable United Nations (UN) pressure receptacles in accordance with § 178.71(q) of the HMR.
We have paraphrased and answered your questions as follows:
Q1. Is it permissible to mark the letters "DOT" within the required marking of § 178.71(q)?
A1. UN pressure receptacles cannot have the letters "DOT" marked on them unless they also meet the requirements and standards of a U.S. Department of Transportation (DOT) specification cylinder.
Q2. Is it permissible to mark the letters “DOT” in parentheses underneath the required markings of "USA" and the M number (USA/MXXXX)?
A2. See answer A1.
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
Standards and Rulemaking Division
§ 178.71(q)
Regulation Sections
| Section | Subject |
|---|---|
| 178.71 | Specifications for UN pressure receptacles |