Hagemeyer North America — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave, S.E. Washington, D.C. 20590 JUN 3 0 2009 Mr. Bill McDonald Hagemeyer North America 2 1 70 Commerce Avenue, Suite D Concord, CA 94520 Ref. No.: 09-0050 Dear Mr. McDonald: This responds to your letter regarding the requirements in 5 180.205(c) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1 - 1 80) for periodic requalification of DOT specification cylinders and non-DOT specification cylinders authorized under a DOT special permit. In accordance with 8 180.205(c) of the HMR, a cylinder may be requalified at any time before or during the month and year that the requalification is due. A cylinder filled before the requalification becomes due may remain in service until it is emptied. A cylinder with a specified service life may not be refilled and offered for transportation after its authorized service life has expired. Your questions are paraphrased and answered as follows: Q1. Do the requirements in 8 180.205(c) mean that a cylinder filled in 1986 need not be requalified and/or hydrostatically tested if it has never been emptied? A1 . Under the HMR, a charged cylinder filled in 1986 which is past due for its hydrostatic retest date need not be emptied to meet a testing schedule and may remain in service until it is emptied. However, a cylinder with a specified service life that was filled in1986 may not be refilled and offered for transportation after its authorized service life has expired. In addition, the use of a cylinder may be subject to applicable standards and regulations of other Federal agencies (See 171.l(e)). Q2. A DOT 3AA breathing air cylinder rated at 2216 psi, used for airline supplied air respirators, reaches its low air alarm (approximately 20% of full or 550 psi) but is not. May the cylinder remain in service until emptied? May the cylinder be completely filled (topped off) if it is beyond its retest and requalification date?#

Page 2A2. 43. A3. A charged, partially filled DOT 3AA cylinder may remain in service until it is emptied. A DOT 3AA cylinder that is not completely empty, but past its test date, may not be charged or filled (including topped off) with a hazardous material and offered for transportation in commerce unless that cylinder has been inspected and retested in accordance with fj 180.205(c). In addition, cylinders used onboard aircraft are subject to the Federal Aviation Administration's (FAA) Regulations under 14 CFR. You should contact the FAA for any applicable requirements. Does fj 180.205(c) apply to a non-DOT specification cylinder authorized under Special Permit 7277 that was filled in 1990 but never emptied? May the non- DOT specification cylinder remain in service beyond its prescribed service life of 15 years? Does the cylinder require periodic retest and requalification? The non-DOT specification cylinder authorized under the Special Permit 7277 must be used under the terms of the special permit. A non-DOT specification cylinder authorized under Special Permit 7277 that was filled in 1990 but never emptied may remain in service until emptied; however, it may not continue to be used past its prescribed service life of 15 years from the date of manufacture as marked on the cylinder. (See paragraph d(6) (operational controls) of Special Permit 7277). Each cylinder used under the terms of Special Permit 7277 must be re-inspected and hydrostatically retested every three years in accordance with $9 180.205 and 180.209 as prescribed for DOT 3HT cylinders. (See paragraph c(1) (requalification) of Special Permit 7277). I hope this satisfies your inquiry. If we can be of further assistance, please contact us. e. Betts ief, Standards Development f Hazardous Materials Standards#

Page 3Mr. Edward T. Mazzullo Director, Office of Hazardous Materials Standards U. S. DOTiPHMSA (PHH-10) 1200 New Jersey Avenue, SE East Building, 2nd Floor Washington, DC 20590 Reference 49-CFR 180.205(c) (c) Periodic pregualification of cylinders. Each cylinder bearing a DOT specification marking must be requalified and marked as specified in the requalification Table in this subpart. Each cylinder bearing a DOT special permit number must be requalified and marked in conformance with this section and the terms of the applicable special permit. No cylinder may be filled with a hazardous material and offered for transportation in commerce unless that cylinder has been successfully requalified and marked in accordance with this subpart. A cylinder may be requalified at any time during or before the month and year that the requalification is due. However, a cylinder filled before the requalification becomes due may remain in service until it is emptied. A cylinder with a specified service life may not be refilled and offered for transportation after its authorized service life has expired. Section 180.205(c) states that "a cylinder may be re-qualified at any time during or before the month and year that the re-qualification is due. However, a cylinder filled before the re- qualification becomes due may remain in service until it is emptied. A cylinder with a specified service life may not be refilled and offered for transportation after its authorized service life has expired. QUESTIONS: 1) Does that mean a cylinder filled in 1986 need not be re-qualified andlor hydrostatically tested if it has never been emptied? 2) If a 3AA breathing air cylinder rated at 2216 psi used for airline (supplied air respirators) respirators is used and reaches it's low air alarm (approximately 20% of full or 550 psi ) but is NOT COMPLETELY EMPTY, (a) can that cylinder "remain in service until emptied" as stated in 180.205(c)? @) can that cylinder, that is not completely empty, be brought back to full (topped off) if it is beyond it's re-qualification period? 3) Does this section also apply to Special Permit cylinders. Example: E-7277 is used as an "Emergency Escape Breathing Device" and is filled in 1990 but never emptied. (a) Can this cylinder remain in service beyond it's prescribed service life of 15 years? (b) Does this cylinder require periodic re-qualification if not emptied? Please provide written clarification. Respectfully, Bill McDonald Hagemeyer North America 2 170 Commerce Ave. Suit "D" Concord, CA 94520 5 10-258-8 107 bmcdonald@hagemeyerna. com#