Interpretation Response #99-0133 ([Connecticut Department of Public Safety] [Mr. John Blaschik, Jr.])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Connecticut Department of Public Safety
Individual Name: Mr. John Blaschik, Jr.
Location State: CT Country: US
View the Interpretation Document
Response text:
February 4, 2000
Mr. John Blaschik, Jr. Ref. No. 99-0133
Deputy State Fire Marshal
Connecticut Department of Public Safety
Division of Fire, Emergency and Building Services
P.O. Box 2794
Middletown, CT 06457-9294
Dear Mr. Blaschik:
This is in response to your letter dated May 20, 1999, requesting clarification on the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) concerning the requirements for marking propane cylinders. Specifically, you ask whether etching/scribing the retest date on propane cylinders is acceptable. I apologize for the delay in responding.
The answer is no. Section 173.34(e) (1)(ii) specifically states: "No cylinder required to be retested by paragraph (e)(1)(I) of this section may be charged or filled with a hazardous material and transported in commerce unless that cylinder has been inspected and retested in accordance with this section and the retester has marked the cylinder by stamping the date of retest, the cylinder retester identification number ... and any other marking required by this section." Emphasis added. However, we are currently reviewing methods for marking DOT specification cylinders under a notice of proposed rulemaking (NPRM) published on October 30, 1998 [RSPA Docket No. 98-3684(HM-220)]. In the NPRM, we proposed to allow requalification marks to be made by stamping, engraving, scribing or any other method approved in writing by the Associate Administrator for Hazardous Materials Safety. We also solicited comments on methods that should or should not be authorized for applying requalification marks on cylinders. The NPRM and the comments received may be viewed on the Internet by assessing the HazMat Safety Homepage at http://hazmat.dot.gov.
I hope this information is helpful. Should you have further questions, please contact us.
Sincerely,
Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.34