# Volvo Aero Services (Seattle) LLC — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 06-0105
- **title:** Volvo Aero Services (Seattle) LLC — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2006-07-03
- **effective on:** Not available
- **summary:** 06-0105 response to Volvo Aero Services (Seattle) LLC concerning 180.205.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-06-0105.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-06-0105.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-06-0105
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2006/060105.pdf
**body:**

<<<PAGE 1>>>

U.S. Department
of Transportation
400 Seventh Street, S.W.
Washington, D.C. 20590
Pipeline and
Administration
Hazardous Materials Safety
JUL - 3 2006
Mr. Ronnie Hamblin
18516 8th Avenue South
Volvo Aero Services (Seattle) LLC
Ref. No.: 06-0105
Kent, Washington 98032
Dear Mr. Hamblin:
the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
This responds to your letter regarding periodic retest of compressed gas cylinders under
beyond its requalification/retest interval, may be transported via any mode from its place
Specifically, you ask whether a charged compressed gas cylinder (oxygen, etc.,) that is
of origin to another facility, to a requalification/retest facility, or be stored indefinitely in
a warehouse environment without being requalified/retested.
The answer is yes. A cylinder may be requalified at any time during or before the month
the requalification becomes due may remain in service until it is emptied, and a
and year that the requalification is due. A cylinder filled (1.e., charged) before
commercial enterprise may transport those cylinders in commerce by highway, rail, air,
or vessel in compliance with the HMR (see §180.205).
I hope this information is helpful. If we can be of further assistance, please contact us.
Sincerely,
(
Chief, Standards Development
Office of Hazardous Materials Standards
180.205
060105

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May. j. 2006 12:27PM
VOLVO AERO
No. 1815 P. 1
Engrum
From: Ron Hamblin
$180.205 C)
E-mail: ronnie.hamblin@volvo.com
Cylinders
To: USDOT DHM-10
400 7* Street S.W.
06-0105
Washington, DC
20590
Attention: Director of Hazard Material Standard, Edward Mazzull
Letter of Interpretation
I have read CFR49, 180.205, (c) and have a few questions.
The following questions are regards to the transportation on compressed gas
cylinders:
1. Can charged compressed gas cylinders (oxygen and etc) that are
beyond their requalification / retest interval be transported via any
mode from its place of origin to another facility?
2. Can charged compressed gas cylinders (oxygen and etc) that are
beyond their requalification test interval be transported via any mode
from its place of origin to a requalification/retest facility?
3. Can charged compressed gas cylinders (oxygen and etc) that are
beyond their requalification test interval be stored indefinitely in a
warehouse environment without being requalified / retested?
Beyond their requalification test interval may be as much as 10 to 15 years.
Would like either yes or no answer if possible but if the CFR specifically
answers the above questions would like the location within CFR the
information can be found.
If possible I would like a response via E-mail but if not possible I will
supply my address information if needed.
Thank you,
Ron Hamblin
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