Interpretation Response #26-0059
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Hydro Stat, LLC
Individual Name: Matthew Buys
Location State: MI Country: US
View the Interpretation Document
Response text:
July 23, 2026
Matthew Buys
Divisional Manager
Hydro Stat, LLC
P.O. Box 510
Warren, MI 48015
Reference No. 26-0059
Dear Mr. Buys:
This letter is in response to your May 11, 2026 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the removal of paint or loose material from cylinders under § 180.205(f)(6). Your email discusses the use of a pulse laser cleaning machine as an authorized alternative to shot blasting for the removal of clearcoat and paint from aluminum and steel high-pressure gas cylinders. You add that the use of pulse laser cleaning machines are not specifically mentioned in the HMR or any Compressed Gas Association (CGA) publications for visual inspection of steel and aluminum cylinders. Specifically, you ask whether a device that relies on a laser to remove clear coat and paint may be used for the preparation and cleaning of a cylinder for inspection in accordance § 180.205(f)(6) of the HMR.
Yes. Neither the HMR nor the CGA standards for visual inspection of steel and aluminum cylinders restrict specific devices for removing paint or loose material. While shot blasting is mentioned in § 180.205(f)(6), it is meant to be an example, and not a limitation to using other methods. Note that cleaning methods that could remove cylinder material and reduce wall thickness are not permitted under this section. Please note that any evidence of the removal of wall thickness via grinding, sanding, or other means, except in association with an authorized repair (see § 180.205(d)(4)), would trigger the cylinder to require full testing and inspection under § 180.205.
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