City Carbonic Sales & Service, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 1200 New Jersey Avenue, SE Washington, D.C. 20590 Materials Safety Administration Pipeline and Hazardous MAY 17 2007 President Ms. Amy Morgan Bruecks Ref. No. 07-0082 406 S.W. 4'" St. City Carbonic Sales & Service, Inc. Oklahoma City. OK 73109 Dear Ms. Bruecks: service. Specifically. you ask whether only these specific cylinders may be eddy current tested and marked with the VE marking as required by $$ 180.209 and 180.213. respectively. The answer is no. Any cylinder may be eddy current tested and marked with the VE cylinders for which the eddy current test and marking are not required. the test exceeds marking regardless of whether the test is required for the particular cylinder. For those the HMR requirements and is not prohibited. I hope this information is helpful. Please contact this office if you have additional questions. Sincerely. Hath thes Hattie L. Mitchell Office of Hazardous Materials Standards Chief. Regulatory Review and Reinvention 180.209 070082#

Page 2Apr 16 07 08: 24a City Larponic sa MCIntyre $180.209 Cylinders 07-0082 Phone: (405) 239-2068 • Oklahoma City, OK 73109 406 S.W. 4th Street Toll Free: (800) 286-4291 Fax: (405) 236-5429 April 13, 2007 PHH-12 Office of Hazardous Materials Standards Attn: Mrs. Hattie Mitchell Washington, D.C. 2059( 400 Seventh Street, S.W 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? n) DOT-3AL cylinders manufactured of 6351-T6 aluminum alloy. In addition to t FR 49 § 180.209 Requirements for requalification of specification cylinde VE. Marking any cylinders other than those "manufactured of aluminum alloy 6351-T6 used in It is my interpretation that only these cylinders may be eddy current tested AND marked with the self-contained underwater breathing apparatus (SCUBA), self-contained breathing apparatus (SCBA), or oxygen service" would result in a violation upon a DOT inspection. this requirement intended to be a minimum requirement? Is it an acpeptable practice to eda urrent test and mark all aluminum cylinders with the VE regardless of their alloy or use Thank you for your assistance in this matter. Sipcerely, RIN B435 President#