Hydro-Test Products, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave, SE Washington. D.C. 20590 AUG 0 9 2010 Mr. Tom Sauta Hydro-Test Proclucls Inc. gS l-Judson Road Slow. MA 01775 Rd. No. W-(lIl06 Dear Mr. Saula: This is in reference to your request for a clarification of a requirement appearing in 49 CFR 180.205(g)(6) thaI states Iraining materials (e.g., CGA publication C-l.l) may be used for training persons who requalify cylinders using the volumetric expansion test methods. Specifically, you ask whether the sole use of the referenced publication would satisfy the training requirements in § 172.702. We apologize for the delay in responding and any inconvenience it may have caused. The answer to your question is no. As you are aware, we specifically stated in the preamble of the H M -244A final rule that CGA C 1.1 could be used as guidance material to assist cylinder requaJifiers in selling up their training procedures and was not to be considered as a stand-alone 1001 for training persons on how to perform requalification of cylinders using the volumetric expclllsion lest method. [n the final rule, we also stated we were removing the entries in §§ 171. 7(b) and 1XO.205(g)(h) that refer to the publication. However, due to an oversight, the amendalory language was inadvertenl1y omitted. These regulatory entries are scheduled for removal in an upcoming (BM-244C) final nile. I hope this information is helpful. Please contact this office shouJd you have additional questions. S incerel y, T. Glenll Fosler Acting Chief. Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 2M;+L-he ~ ( I" 1 Page 1 ofl ~ IBD.206 (j) \.6v March 29, 2010 ~ lIZ. 702-.,..,-. . Attn: Ms. Hattie Mitchell U.S. Department of Transportation ~1'r)oIe..rs I Irk! (\./\j West Building Ground Floor 10-000(' Room W12-l40 1200 New Jersey Avenue, S.E. Washington, DC 20590-0001 Re; Request for written interpretation I am writing to request a written interpretation on § l80.205(g)( 6) of CFR Title49 which states; 'Training materials (e.g. , CGA publication C-1.1) may be used for training persons who requalify cylinders using the volumetric expansion test method." Hydro-Test Products is involved with the re-training requirement of §172.702 for cylinder requa1ifiers. We feel that §l80.205(g)(6) is misleading in that many cylinder requalifiers, independent inspectors and enforcement inspectors are of the opinion that by using this pamphlet, the training requirements are met. Please advice your department's position, as to whether §180.205(g)(6) meets the requirements of §172.702. Thank you for your time and I look forward to your reply. Best Regards, ~"., SAvlA Tom Sauta Hydro-Test Products Inc. H"elro- Test' Product's Inc. 85 71&ison RD6td SlOW, .I.'Jas.sttchtneIU 01775 USA Jel: 1100-225-94881978-897-4647 pox: 978-897-1~2 wwW'.h tf::s't.r£t.iIlN#