Interpretation Response #16-0170
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
April 13, 2017
Mr. Chris Hinchey
Bancroft Hinchey Ltd
West Sussex, United Kingdom
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