{"operation":"document","citation":"11-0006","title":"Stolt Tank Containers — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2011-02-15","effective_on":null,"summary":"11-0006 response to Stolt Tank Containers concerning 172.101, 173.115.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0006.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0006.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0006","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2011/100006.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration\n1200 New Jersey Ave, SE\nWashington. D.C. 20590\nAUG 0 9 2010\nMr. Tom Sauta\nHydro-Test Proclucls Inc.\ngS l-Judson Road\nSlow. MA 01775\nRd. No. W-(lIl06\nDear Mr. Saula:\nThis is in reference to your request for a clarification of a requirement appearing in 49 CFR\n180.205(g)(6) thaI states Iraining materials (e.g., CGA publication C-l.l) may be used for\ntraining persons who requalify cylinders using the volumetric expansion test methods.\nSpecifically, you ask whether the sole use of the referenced publication would satisfy the\ntraining requirements in § 172.702. We apologize for the delay in responding and any\ninconvenience it may have caused.\nThe answer to your question is no. As you are aware, we specifically stated in the preamble of\nthe H M -244A final rule that CGA C 1.1 could be used as guidance material to assist cylinder\nrequaJifiers in selling up their training procedures and was not to be considered as a stand-alone\n1001 for training persons on how to perform requalification of cylinders using the volumetric\nexpclllsion lest method. [n the final rule, we also stated we were removing the entries in\n§§ 171. 7(b) and 1XO.205(g)(h) that refer to the publication. However, due to an oversight, the\namendalory language was inadvertenl1y omitted. These regulatory entries are scheduled for\nremoval in an upcoming (BM-244C) final nile.\nI hope this information is helpful. Please contact this office shouJd you have additional\nquestions.\nS incerel y,\nT. Glenll Fosler\nActing Chief. Regulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\nM;+L-he ~ ( I\" 1 Page 1 ofl\n~ IBD.206 (j) \\.6v March 29, 2010\n~ lIZ. 702-.,..,-. .\nAttn: Ms. Hattie Mitchell\nU.S. Department of Transportation ~1'r)oIe..rs I Irk! (\\./\\j\nWest Building Ground Floor 10-000('\nRoom W12-l40\n1200 New Jersey Avenue, S.E.\nWashington, DC 20590-0001\nRe; Request for written interpretation\nI am writing to request a written interpretation on § l80.205(g)( 6) of CFR Title49 which states;\n'Training materials (e.g. , CGA publication C-1.1) may be used for training persons who requalify\ncylinders using the volumetric expansion test method.\"\nHydro-Test Products is involved with the re-training requirement of §172.702 for cylinder requa1ifiers. We feel\nthat §l80.205(g)(6) is misleading in that many cylinder requalifiers, independent inspectors and enforcement\ninspectors are of the opinion that by using this pamphlet, the training requirements are met.\nPlease advice your department's position, as to whether §180.205(g)(6) meets the requirements of §172.702.\nThank you for your time and I look forward to your reply.\nBest Regards,\n~\"., SAvlA\nTom Sauta\nHydro-Test Products Inc.\nH\"elro- Test' Product's Inc.\n85 71&ison RD6td SlOW, .I.'Jas.sttchtneIU 01775 USA\nJel: 1100-225-94881978-897-4647 pox: 978-897-1~2\nwwW'.h tf::s't.r£t.iIlN","truncated":false,"body_characters":2944}