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

Page 1of Transportation U.S. Department Washington DC 20590 1200 New Jersey Ave.. SE Pipeline and Hazardous Materials Safety Administration JUN 27 2007 President Ms. Amy Morgan Bruecks Ref. No. 07-0117 406 S.W. 4th St. City Carbonic Sales & Service, Inc. Oklahoma City, OK 73109 Dear Ms. Bruecks: This is in further reference to my May 17 response (ref. no. 07-0082) to your letter requesting clarification of the requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to cylinders manufactured of 6351-T6 self-contained breathing apparatus (SCBA), or oxygen service. Specifically, you ask aluminum alloy and used in self-contained underwater breathing apparatus (SCUBA), 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. and marked with the VE marking regardless of whether the test is required for the As I stated, the answer is no. Any aluminum alloy cylinder may be eddy current tested particular cylinder. For aluminum cylinders made of other than alloy 6351-T6 for which the eddy current test and marking are not required, performance of this additional test exceeds the HMR requirements and is acceptable. I hope this additional information is helpful. Please contact this office if you have further questions. Sincerely. Hattie L. Mitchell Office of Hazardous Materials Standards Chief, Regulatory Review and Reinvention 180.209 070117 180.213#

Page 2Apr 16 07 08:24a City Carbonic Sa 4052365429 p.2 MCIntyre $180.209 3-00: 21- ulinder 07-0082 Phone: (405) 239-2068 Oklahoma City, OK 73109 406 S.W. 4th Street Toll Free: (800) 286-4291 0117 Fax: (405) 236-5429 April 13, 2007 PHt 1f Hazardous Materials Standards Attn: Mrs. Hattie Mitchell Washington, D.C. 20590 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? dioxide, fire extinguisher or other industrial gas service. (SCBA), or oxygen service" would result in a violation upon a DOT inspection. Is this requirement intended to be a minimum requirement? Is it an acceptable practice to eddy current test and mark all aluminum cylinders with the VE regardless of their alloy or use? Thank you for your assistance in this matter. Sincerely, President Amy Morgan Brueck: RIN B435#

Page 3U.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: breathing apparatus (SCUBA), self-contained breathing apparatus (SCBA), or oxygen tested and marked with the VE marking as required by $$ 180.209 and 180.213, ervice. Specifically, you ask whether only these specific cylinders may be eddy curren The answer is no. Any cylinder may be eddy current tested and marked with the VE narking regardless of whether the test is required for the particular cylinder. For thos the HMR requirements and is not prohibited. ylinders for which the eddy current test and marking are not required. the test exceed I hope this information is helpful. Please contact this office if you have additional questions. Sincerely. Hath Mes Chief, Regulatory Review and Reinvention Hattie L. Mitchell Office of Hazardous Materials Standards#