ABCO Fire Protection, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Research and APR 5 2004 400 Seventh St., S.W. Washington, D.C. 20590 Special Programs Administration Mr. David L. Marciniak Reference No.: 03-0280 Manager ABCO Fire Protection, Inc. 1391 Frey Road Pittsburgh, PA 15235 Dear Mir. Marciniak: This responds to your letter requesting clarification of the requirements for requalification of cylinders under § 180.205 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- 180). Specifically, you ask if the manufacturer's label on a fire extinguisher must be removed to perform a visual inspection of the cylinder surface. Section 180.205(f)(2) requires removal of the coating or attachments prior to performing the visual inspection if the coating or attachments inhibit the visual inspection of a DOT specification or exemption cylinder. The requirements in § 180.205 do not apply to non- specification cylinders. To give us a better understanding of the extent that the label is covering the cylinder, we would appreciate receiving a photograph of the labeled cylinder. I trust this satisfies your request. Sincerely, Hathe z mitthell Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards. * 180.205 (f)E) 030280#

Page 2Corbin $180.205(Y2) Cylinders ABCO ABCO Fire Protection, Inc. 03-0280 1391 Frey Road Pittsburgh, PA 15235 Phone (412) 373-7730 Fax (412) 372-5860 FAX TRANSMISSION To: 202/366-3308 February 10, 2003 Research and Special Programs Administration U.S. Department of Transportation Office of Hazardous Materials Safety - Exemptions and Approvals 400 7' Street, S.W. Washington, DC 20590 Reference : RIN #A645 Gentlemen, This is a request for clarification. In the discussion of CFR 49 Section 180.205 ($ (2), labels and coatings on cylinders being retested are discussed. It is our understanding that labels must be removed to allow a thorough visual inspection of the cylinder surface. The language of DOT largely agrees with that of NFPA 10 Section 1.5.11 that discusses HMIS and other labeling. Our specific question is ... Shall the original manufacturer's label be preserved? It is our understanding that the UL/Factory Mutual marks and Serial Number, often contained on Amerex and General brand Fire Extinguisher labels must be preserved in order for the unit to remain listed for use. Of course, where the original manufacturer's label is skinned or scraped, suggesting impact damage, the cylinder would be subject to test. Please assist us in the interpretation of this matter. It appears to us that the original in most cases. manufacturer's label, unavailable to any reseller, should not be summarily removed Sincerely, DiNarcinia 4 David L. Marciniak Manager REPORT NUMBER: - U.S. DOT/RSPA/OHME/EASTERN REGIC: EXHIBIT NUMBER: 03423008 PAGE NUMBER:.. 7.32#