# Hydro-Test Products Inc — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 04-0094
- **title:** Hydro-Test Products Inc — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2004-05-12
- **effective on:** Not available
- **summary:** 04-0094 response to Hydro-Test Products Inc concerning 180.215.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-04-0094.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-04-0094.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-04-0094
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2004/040094.pdf
**body:**

<<<PAGE 1>>>

of 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 2>>>

MCInture
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
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