City Carbonic Sales & Service — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Hazardous Materials Safety 2 3 200€ Ms. Amy Morgan Bruecks Ref. No.: 05-0218 City Carbonic Sales & Service 406 S. W. 4' Street Company, Inc. Oklahoma City, OK 73109 Dear Ms. Bruecks: This responds to your September 9, 2005 letter asking if a DOT-3HT specification cylinder may be used for "paintball" service and then be hydrostatically retested in accordance with §180.209 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). The HMR provides that a DOT-3HT specification cylinder is authorized for aircraft use requirements for DOT-3HT cylinders. In accordance with §180.209(k), in addition to the only and only for nonflammable gases. The HMR also prescribes the requalification other requirements of this section, a cylinder marked DOT-3HT must be requalified in accordance with CGA C-8 pamphlet. For reasons of safety, it is at the discretion of an authorized retester whether it will accept a cylinder for requalification and perform a hydrostatic retest on the cylinder. We do not recommend retest of such cylinders that are used in unauthorized cylinder service, and suggests that you inform your customers. I hope this satisfies your inquiry. If we can be of further assistance, please contact us. Sincerely, Chief. Standards Development Office of Hazardous Materials Standards cc: Doug Smith, PHMSA Office of Enforcement Mike Hilder, PHMSA Office of the Chief Counsel 180.209 (5) 050218#

Page 2Sep 09 05 01:36p City Carbonic Sa 4052365429 p. 1 $180.209( Cylinders 05-02% Phone: (405) 239-2068 Okiahoma City, OK 73109 406 S.W. 4th Street Toll Free: (800) 286-4291 Fax: (405) 236-5429 September 9, 2005 Office of Hazardous Materials Standards DHN-10 Attn: Mr. Edward Mazzulo 400 Seventh Street, S.W. Washington, D.C. 20590 VIA FACSIMILE: 202-366-3012 Subject: Request for a letter of interpretation Can you please help my company with a written letter of clarification on the following issue? CFR 49 § 180.209 Requirements for requalification of specification cylinders cylinder marked DOT-3HT must be requalified in accordance with CGA C- (k) 3HT cylinders. In addition to the other requirements of this section, a 8 (IBR, see §171.7 of this subchapter) CGA C-8 states: 1.3 Cylinders made in accordance with 3HT specifications are similar to fabrication. The major difference is that 3HT specification cylinders those made under 3AA specifications in function and methods of allowable design stress; and, therefore, have a thinner wall thickness are containers only for inside aircraft use; are made to a higher and a lower weight. 2. Filled 3HT series cylinders shall be shipped in suitable outside considered sufficient to protect the cylinders from the adverse affects containers such as corrugated cartons or wooden boxes, which are of rough handling during shipment. It is strongly recommended that empty 3HT series cylinders also be stored and transported in the same type of outside container to prevent damage to the cylinder. ...the productivity people#

Page 3Sep 09 05 01:37p City Carbonic Sa 4052365429 p. i We have had numerous 3HT cylinders designed for paintball service come in for hydro test. It is my interpretation that 3HT specification cylinders are not suitable and thus may not be used for paintball service. Cylinders in paintball service definitely do not receive the delicate treatment mentioned in CGA C-8 section 2. aintball service a suitable application for 3HT specification cylinders an 3HT paintball cylinders be tested, filled and used in such a manner? Is tr The manufacture of the cylinders | refer to is M9001, Gas Cylinder Technology Inc., P.O. Box 3188, STN Main, Tecumseh, Ontario N6N 2M4 Canada. Thank you for your assistance in this matter. Any Mogar Bruscks Amy Morgan Brueck: President RIN B435 ...the productivity people#

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