Interpretation Response #99-0213 ([Global Dynamics Corp.] [Mr. Jay Choi])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Global Dynamics Corp.
Individual Name: Mr. Jay Choi
Location State: IL Country: US
View the Interpretation Document
Response text:
January 19, 2000
Mr. Jay Choi Ref No. 99-0213
Project Manager
Global Dynamics Corp.
1874 South Elmhurst Road
Mt. Prospect, IL 60056
Dear Mr. Choi:
This is in reference to your letter and our telephone conversation regarding test reports for certain acetylene cylinders that were manufactured, tested and inspected by Taylor-Wharton Coyne and purchased by your company. Your customer questioned whether the testing should have been performed by a DOT approved independent inspection agency rather than by the manufacturer. In a subsequent letter, you submitted a copy of the inspector's report for our review.
We reviewed the inspector's report for conformance with the DOT 8AL specification requirements contained in
§ 178.60 of the Hazardous Materials Regulations (49 CFR Parts 171 180) and find it to satisfy the requirements. Section 178.35(b) permits the inspections and verifications for cylinders manufactured to the DOT 8AL specification in the United States to be performed by a competent inspector (employee) of the manufacturer. The cylinders in question were manufactured and tested in the United States; therefore, the use of an independent inspection agency is not required.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.34