Interpretation Response #15-0174
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
June 29, 2016
Mr. Takashi Hashimoto
Chief Operating Officer
Japan Aero Pressure Co., Ltd.
2-1-8 Kokaba Iwatsuki-ku
Reference No. 15-0174
Dear Mr. Hashimoto:
This letter is in response to your email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the marking of cylinders. Specifically, you ask whether chemical etching is an acceptable cylinder requalification marking method under § 180.213(c).
The answer is yes. Requalification markings must conform to requirements in § 180.213, including minimal wall thickness and specifications for the marking size and location. Further, each cylinder must be plainly and permanently marked on the metal of the cylinder as permitted by the applicable specification. Provided all applicable conditions are met, the HMR permit the chemical etching of requalification markings on cylinders.
I hope this information is helpful. Please contact us if we can be of further assistance.
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division