Interpretation Response #99-0243 ([Amtrol Inc.] [Mr. Joseph A. Lane])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Amtrol Inc.
Individual Name: Mr. Joseph A. Lane
Location State: RI Country: US
View the Interpretation Document
Response text:
December 15, 1999
Mr. Joseph A. Lane Ref. No. 99-0243
Director Technical Services
Amtrol Inc.
1400 Division Road
West Warwick, RI 02893-2300
Dear Mr. Lane:
This is in response to your letter dated August 27, 1991, requesting clarification on the periodic qualification of DOT 4BA cylinders used exclusively for refrigerant gases which are commercially free of corroding components. Specifically, you state that the cylinders were marked with a 5-year retest due date at the time of manufacture. You asked whether this 5-year due date may be removed and replaced with a 10-year due date.
The HMR contains no requirement to mark a DOT specification cylinder with the next due date. Therefore, the due date . marking, which would be considered as additional information under § 173.34(c)(1), may be removed. Please note that the retest date marked on a cylinder is the date (month and year)the test is actually performed. See § 173.34(e)(1) and (7).
I hope this information is helpful. If we can be of further assistance, please contact us.
Sincerely,
Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.34