BOC Gases — Hazardous Materials Safety Interpretation

Page 1or ransporation 400 Seventh St., S.W. Washington, D.C. 20590 APR 2 9 2002 Mr. Jack B. Wert Ref. No.: 02-0083 BOC Gases 575 Mountain Avenue Murray Hill, NJ 07974 Dear Mr. Wert: This is in response to your letter dated March 12; 2002 requesting clarification on § 172. 400a(a) (1) of the Hazardous Materials Regulations (HMR;; 49 CFR Parts 171 -180) regarding the use of a cylinder • identification collar in lieu of a cylinder label. For our review, you provided a sample of your company's cylinder identification collar affixed to the top part of a cylinder. As provided by §172.400a (a)(1), cylinders containing flammable (Division 2.1) and nonflammable (Division 2.2) compressed gases that are carried by private or contract motor carrier and which are not overpacked are authorized to be marked in accordance with CGA Pamphlet C-7, appendix A without further DOT labeling. As set forth in CGA: Pamphlet C-7, appendix A, A-7, shoulder markings are permissible as long as the basic markings do not cover any permanent markings. The cylinder identification collar you provided covers the permanent DOT specification markings. Therefore, the cylinder identification collar does not meet the conditions set forth in CGA Pamphlet C-7 appendix A. However, except for your identification collar covering the permanent markings on the DOT specification cylinder, the sample collar otherwise conforms to the provisions specified in § 172.400a(a)(1). I trust this satisfies your inquiry. If we can be of further assistance, please contact us. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 172400å ДНИНИННІ 020083#

Page 2Webb • $172.400a AMN BOC GASES Labeling Murray Hill, NJ 07974 575 Mountain Avenue 02-0083 March 12, 2002 Mr. Ed. Mazzullo Director Office of Hazardous Materials Standards Research and Special Programs Administration. US Department of Transportation 400 Seventh Street-SW Washington, DC 20590 Subject: Clarification on the Use of Cylinder Identification Collars in Lieu of . Cylinder Labels Dear Mr. Mazzullo, Some time ago, September 1999, BOC had decided that they wanted to use cylinder identification collars in lieu of the traditional cylinder labeling. This system would provide BOC with not only with all the DOT required labeling, but also the capability to track cylinders by bar code and transponders. Pursuant to this endeavor I contacted the Department of Transportation to determine if there were any regulatory or technical reasons which would preclude use.#

Page 3• • If there are any further questions please call or e-mail me and I will address any concerns. I look forward to your favorable reply. Respectfully, Jack B. Wert Manager, Compressed Materials and Related Technology * Tel: 908-771-1338 = Fax: 908-508-3627 X mailto:.Jack. Wert@us.gases.boc.com £ 575 Mountain Avenue, Murray Hill, NJ 07974, USA Enclosure (1) E-mail correspondence between BOC and the Department of' Transportation.#