Department of the Air Force — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590 MAY 1 2 2014 Mr. Brett Schlueter 423 SCMS/GUEA 3001 StaffDr. Ste. IAC1-100B Tinker AFB, OK 73145 RefNo.: 14-0053 Dear Mr. Schlueter: This is a response to your March 18, 2014 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CPR Parts 171-180) with regard to requalification markings on DOT specification cylinders and DOT Special Permit (DOT -SP) Cylinders used as fire extinguishers. Specifically, you request clarification on what specifications or types of cylinders may be marked using a pressure sensitive label. In your email you indicate you are performing requalifications of DOT 4D, DOT 4DA, DOT 4DS, DOT-SP 7945, DOT-SP 7971, DOT-SP 8439, and DOT-SP 8495 cylinders that are used as fire extinguishers. Requirements for requalification markings for cylinders are found in § 180.213. In accordance with§ 180.213(c)(l), cylinders used as fire extinguishers may be marked using a pressure sensitive label. This paragraph is not limited to DOT specification cylinders listed in § 180.209(j), but applies to all cylinders used as fire extinguishers. I hope this information is helpful. If you have any more questions, please do not hesitate to contact this office. Sincerely, Robert Benedict Chief, Standards Development Standards and Rulemaking Division#

Page 2DEPARTMENT OF THE AIR FORCE 848t11 SUPPLY CHAIN MANAGEMENT GROUP (AFMC} TINKER AIR FORCE BASE OKLAHOMA 18 March 2014 MEMORANDUM HJR: Office of the Administrator U.S. Department ofTransportation Pipeline and Hazardous Materials Safety Administration East Building, 200 Floor Mail Stop: E27-300 1200 New Jersey Ave., SE Washington, DC 20590 FROM: 423 SCMS/GUEA 3001 Staff Dr. Ste. IACl-lOOB Tinker AFB, OK 73145-2713 SUBJECT: Request letter ofinterpretation regarding 49 CFR Section 180.213 (c)(l) l. This request is for an official interpretation of Section 180.213 (c)( I) of49 CFR which states, "A cylinder used as a fire extinguisher (180.209(j)) may be marked by using a pressure sensitive label." This request applies specificaHy to requalification markings for severai DOT-specification cylinders currently being used as fire extinguishers for use onboard U.S. Air Force aircmft. The reference-d DOT- specification cylinders are: 4D, 4DA, 4DS, Special Permits SP-5861, SP-7945, SP-7971, SP-8439, and SP-8495. Permission to use pressure sensitive labels in this application is required as many of these cylinders no longer have adequate space for requalification markings in the areas allowed to be stamped. 2. Following the references in the 49 CFR starting "\vith Section 180.209(j) leads to Section 173.309, Fire Extinguishers, which lists DOT-specification cylinders by name. The cylinders listed above are not specifically named in Section 173.309leading to some confusion as to the intent of Section 180.213 (c)( 1 ). An initial request for interpretation made by phone to the HAZMA T Information Center hotiine (1-800-467-4922) was answered by referencing a prior letter of interpretation (Reference No.: 05-0266). This Jetter appears to apply specifically to composite (fiber wrapped) cylinders, however, it may also be interpreted as allowing blanket approval for any DOT-specification cylinder being used as a fire extinguisher. 3. Please provide an official interpretation of Section 180.213 (c)(l) relating specifically to the DOT- specification cylinders listed above. May the requaiification markings for these cylinders be marked by using a pressure sensitive label so long as they are being used as fire extinguishers? 4. if additional information is needed, please contact the Air Force engineering POC for this request, Brett Schlueter, 405-734~ 7733 or email brett.schlueter@us.af.mil. '-UIJ k:. - ~E~ J. r; HAN, Flight Chief Accessories Engineering Flight Accessories Squadron#