Western International Gas & Cylinder, INC — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department OCT 26 2004 400 Seventh St., S.W. Washington, D.C. 20590 Special Programs Research and Administration Ms. Kathy McKenzie Ref. No.: 04-0045 Safety and Compliance Director Western International Gas & Cylinder, INC. P.O. Box 668 7173 Highway 159E Bellville, TX 77418 Dear Ms. McKenzie: This is in response to your February 25, 2004 letter requesting clarification regarding the requalification marking requirements for specification cylinders under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if your requalification markings may be smaller than the size requirements specified under § 180.213(e). Please accept my apology for our delay in responding to your letter. Section 180.213(d) (1) allows modification of requalification marking requirements (e.g., smaller marking size) under the conditions of an approval. The procedure for applying for an approval is specified in § 107.705. There are other options that you may want to consider. One option would be to attach a metal plate with the applicable requalification markings. Another option would be to remove the older requalification markings to create space for the new requalification markings. I hope this information is helpful. Please contact us if you require additional assistance. Sincerely tittie z. Mohel Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 040045 180.213#

Page 2P F WESTERN INTERNATIONAL GAS & CYLINDERS, INC. P.O. Box 668, 7173 Hwy 159E WESTERN INTERNAL Bellville, TX 77418 FIRS (979) 413-2100 FAX (979) 413-2250 or (979) 413-2260 Stevens $180.213 Markings of Cylinders February 25, 2004 04t-0045 DOT/RSPA/OHMS LINI US DOT Ryan Posten 400 7" Street, S.W. Office of Exemptions & Approvals Washington, DC 20590 Dear Mr. Posten; CFR 49 180.213 (e) states the size of the marking must be at least 6.35mm (1/4 in), except RIN characters must be at least 3.18mm (1/8 in.) high. On MC & B cylinders there is a minimal area available to stamp. The manufacturing stamping is all done in smaller than a 1/4in.character because of the limited room. As long as the stamping is legible as required is it permissible to use a smaller than a (1/4in.) character stamps for the retest dates. Please advise in writing at your earliest convenience. Respectfully Submitted, Bathy Merenze. Safety & Compliance Director#