Hydro-Test Products Inc — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh St., S.W. Research and Washington, D.C. 20590 Administration Special Programs MAY 12 2004 Mr. Tom Sauta Ref. No. 04-0094 Hydro-Test Products Inc. P.O. Box 286 Stow, MA 01775 Dear Mr. Sauta: This is in response to your letter and subsequent telephone conversation with a member of my staff asking whether the require the cylinder manufacturer's symbol to be included on Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) known. the requalification record if the manufacturer's name is not program poses You state that importing the symbol into your computer a problem. You also ask that comprehensive list of cylinder manufacturers' symbols, we provide a including the old graphic symbols. Section 180.215 (b) states that either the symbol or the manufacturer's name must be included on the requalification records. brief description of the symbol such as "B inside of Section 180.215 (b) may be satisfied by entering a triangle." In addition, if the manufacturer's name is not known for a particular symbol, you may contact the Research and Special Programs Administration (RSPA) Office of Hazardous Materials Exemptions and Approvals at 202/366-4512. there is no computerized list containing the old graphic Although the assignments. symbols, the Approvals Office maintains certain information on office I hope this information is helpful. Please contact this should you have additional questions. Sincerely, Hothe z. Michell Hattie I. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 180.215 (b) (z) 040094#

Page 2MCInture 3180 Ellinders November 14, 2003 Mr. Edward T. Mazzullo 04-0094 U.S. DOT/RSPA (DHM-10) Director, Office of Hazardous Materials Standards 400 7th Street S.W. Washington, D.C. 20590-0001 blank if a symbol is present, but it is not known to whom that symbol is registered to? In regards to sec. 180.215(b)(2). Is it acceptable to leave the entry for cylinder manufacturer For example a DOT specification cylinder with a cylinder manufacturers mark of a "B" inside a required to draw the symbol on the test record form? triangle. It is not known who that symbol is registered to, but it is present. Is the requalifier to import symbols into the computerized program, if they cannot identify the symbol with a With the influx of automated test equipment, it is not practical to ask that the requalifier be made manufacturer. If RSPA is going to enforce that the symbol must be on the test record form, if present, I would ask that RSPA make available a list of symbols for all manufacturers of cylinders, both current and those manufacturers that are no longer in business. If this listing is not available, what are MR. SAutA your recommendations? Thank you for your time, Tom Sauta specific Hydro-Test Products REQUEST, This NAS MADE up 05 AN ExAmple. J. HYDRO-TEST PRODUCTS INC. 85 HUDSON ROAD P.O. BOX 286 Tel # 800-225-9488 Fax # 978-897-1942 STOW, MA 01775 Email: tfsauta@hydro-test.com Page 1#