Guidanceguidance
06-0133
Global Fire and Safety, Inc. — Hazardous Materials Safety Interpretation
Current as of source date Government source
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Page 1.S. Departmer f Transportatio Washirigton, D.C. 20590 400 Seventh Street, S.W. Pipeline and Hazardous Materials Safety Administration JUN 30 2006 Mr. Bill McDonald Ref. No. 06-0133 2601 Adeline Suite 150 Global Fire and Safety, Inc. Oakland, CA 94607 / Dear Mr. McDonald: This is in response to your June 6, 2006 letter requesting clarification regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to your exemption cylinder. In your scenario, you have an exemption cylinder marked DO accordance with § 180.209(g), which allows for external visual inspections of cylinders used exclusively for certain named gases. The answer is yes. Upon review by the Office of Hazardous Materials Special Permits requalified in accordance with § 180.209(g). and Approvals, it has been determined that the cylinder specified in your request may be I hope this information is helpful. Hattie L. Mitchell, Chief Regulatory Review and Reinvention Office of Hazardous Materials Standards 180.209 (9) 060133#
Page 2Satterthwarte $180.209(9) Cylinders 06-0133 THE PROFESSIONALS IN WORLOWIDE SERVICE Director, Office of Hazardous Materials Standards 400 7th Street S.W. U.S. DOT/PHMSA (PHH-10 June 6, 2006 Washington, D.C. 20590-0001 Mr. Edward T. Mazzullo, Ref: E-8795 We have a cylinder marked DOT E-8795 500ET with an original mfg. date of 2-85. The Cyliner i cha fre with urined ayload a mixtures therco that are: The exemption letter, eighth edition, states applicable regulations to a DOT specification is service qualifies for the modified external visual cylinder re-qualification as po B240ET with note exceptions. There is no clarification indicating that this cylinder i CFR-49 section 180.209(g). It is my understanding that the intent of section 180.209(g) was to allow external visual re-qualification in order to minimize the unnecessary discharge of Halon 1301 and other environmentally harmful agents. Can this cylinder be re-qualified as per section 180.209(g)? Please review this inquiry and provide a written response to indicating your decision. espectfully Satan Conald Bill McDonald 2601 Adeline Suite 150 Global Fire and Safety, Inc. 510-834-2323 Oakland, Calif. 94607 • cc: Dave Rubino#
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