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Interpretation Response #16-0170

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 04-13-2017
Company Name: Bancroft Hinchey Ltd    Individual Name: Mr. Chris Hinchey
Country: UK

View the Interpretation Document

Response text:

April 13, 2017

Mr. Chris Hinchey
Bancroft Hinchey Ltd
School House
Slaugham Lane
West Sussex, United Kingdom
RH17 5TJ

Reference No. 16-0170

Dear Mr. Hinchey:

This letter is in response to your October 20, 2016, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the marking of cylinders. You note that requalification marking requirement for cylinders in § 180.213(c) allows a label embedded with epoxy that is legible and durable throughout the life cycle of the cylinder. You add that § 180.213(b) states that unless authorized by the cylinder specification, the marking on the cylinder sidewall is prohibited. You further reference § 178.35(f)(4), which states that unless otherwise specified in the applicable specification, the markings on each cylinder must be stamped plainly and permanently on the shoulder, top head, or neck.

In your email, you provide the following assumptions:

  • There is no manufacturer authorization to label the sidewall which negates § 180.213(b).
  • The use of a label on the sidewall is therefore in conflict with the requirements to not mark a sidewall.
  • Applying a label to the dome, top head, or neck is impractical. Therefore, the amended texts refer to the common practice of placing labels on the sidewall of composite cylinders.

Specifically, you ask for confirmation that the application of labels overcoated with epoxy as described in § 180.213(c) is an acceptable method of applying a requalification marking for a composite cylinder.

The answer is yes. It is the opinion of this Office that the assumptions stated in your email regarding the labeling of composite cylinders are correct. When requalifying composite cylinders under § 180.213, a label embedded with epoxy is permissible provided it produces a mark that is both legible and durable.

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

Regulation Sections

Section Subject
§ 180.213 Requalification markings