{"operation":"document","citation":"05-0270","title":"Fire Protection Certification — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2005-12-30","effective_on":null,"summary":"05-0270 response to Fire Protection Certification concerning 180.215.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0270.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0270.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0270","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2005/050270.pdf","body":"<<<PAGE 1>>>\n\nMr. Edward O'Brien\nRef No.: 05-0270\nPresident\nFire Protection Certification\n8719 Pete Wiles Road\nMiddletown, MD 21769\nDear Mr. O'Brien:\nThis is in response to your October 12, 2005 letter requesting clarification of the record\nretention requirements for cylinder requalifiers under the Hazardous Materials\nRegulations (HMR; 49 CFR Parts 171-180). Specifically, you ask which number a\nrequalifier should maintain in his records as the serial number when recording the\nperformance of a 12-year hydrostatic test on a DOT 4B cylinder used as a fire\nextinguisher. You indicate that two numbers are marked on the cylinder - a batch\nnumber that applies to an entire lot of cylinders is stamped on the shell, and a serial\nnumber is displayed on the manufacturer's label. The cylinder was manufactured by\nAmerex Corporation.\nSection 178.35(f) requires each specification cylinder to be marked with a serial number.\nFor the purpose of cylinder identification, § 180.215(b)(2) requires the person performing\ncylinder requalification to record and retain the serial number of the cylinder that was\ntested.\nIn the situation you describe, it is likely that the cylinder was manufactured by Amerex\nCorporation under DOT exemption DOT-E 9837. The exemption authorizes Amerex\nCorporation to stamp the lot number instead of the serial number on DOT 4B cylinders.\nThe lot must consist of less than 500 cylinders and each cylinder must have a volumetric\ncapacity not exceeding 170 cubic inches and a service pressure not exceeding 200 psig.\nAssuming that your cylinder meets DOT-E 9837, your records should display the lot\nnumber that is permanently stamped in the cylinder. The serial number may be entered\nas additional information to clearly identify the cylinder.\nI hope this information is helpful. Please contact us if you require additional assistance.\nSincerely,\nJohn\nGale\nChief, Regulations Development\nOffice of Hazardous Materials Standards\n180•215(61(3)\n050270\n\n<<<PAGE 2>>>\n\nширко\nOctober 12, 2005\n$180.2156(2)\nU.S. Dept. of Transportation\nOffice of Hazards Materials Standards OHMS\nCylinders\nAttn: Edward Mazzullo\n05-0270\n400 Seventh Street, SW\nWashington, DC 20590\nRef: Interpretation of serial # recording\nI conduct DOT Haz Mat training for Fire Protection Companies\nthroughout the U.S.. It has been brought to my attention several times that\nthere are 4B cylinders manufactured as fire extinguishers by Amerex Corp.\nthat have the same serial number stamped into the shell. I contacted Amerex\nand they advised me that they have made batches of these units with the\nsame serial number for the batch. When it is finally assembled and filled as\na fire extinguisher it gets a label attached with a serial number that identifies\nThe request for interpretation is as units are due for their 12 year\nlydrostatic test, what number do cylinder requalifiers put on their record:\nhen they requalify these units, the batch number stamped on the shell o\nthe serial number on the label attached to the shell?.\nSincerely\nFPC LTD\nStado Bone\nEdward O'Brie\nPresident\nC.C. Linda Cooper\nRyan Posten\nRaymond LaMagdelaine\nColleen Abbenhaus\nDaniel Derway\nBilly Hines\nJohn Heneghan","truncated":false,"body_characters":3167}