Interpretation Response #99-0034 ([Quality Gas Products] [Mr. Chuck Wilson])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Quality Gas Products
Individual Name: Mr. Chuck Wilson
Location State: LA Country: US
View the Interpretation Document
Response text:
October 14, 1999
Mr. Chuck Wilson Ref. No. 99-0034
Quality Gas Products
10172 Mammoth Avenue
Baton Rouge, LA 70814
Dear Mr. Wilson:
This is in response to your letter dated February 3, 1999, requesting clarification of the cylinder marking requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You state that it is your understanding that the only markings required to be placed on a cylinder consist of a "DOT stamping" and a hydrostatic test date and that no other markings are required, such as the cylinder/serial number.
Your understanding is not correct. The required specification markings that must be stamped on a DOT specification cylinder at the time of manufacture are prescribed in §178.35(f). (See enclosure). Unless otherwise specified in the applicable specification, all markings on a cylinder must be stamped plainly., and permanently on the shoulder, top head, or neck. Certain additional marking requirements unique to the individual cylinder specifications may be found in §§ 178.36 through 178.68.
Requalification marking requirements are prescribed in §173.34(e) (7). Depending on the cylinder's specification and the type of exclusive product service use, most cylinders must be periodically requalified varying from 3, 5, 10, 12, or 20 years from the date of manufacture.
All required specification and requalification markings must be legible and, with certain exceptions, may not be covered or removed. See § 173.34(c). For your information, the HMR are accessible on the internet through the Hazardous Materials Safety homepage at “http://hazmat.dot.gov.”
I trust this satisfies your inquiry. Please contact us if we can be of more assistance.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
Enclosure
173.34