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

Page 1U.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#

Page 2May. 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#