{"operation":"document","citation":"24-0118","title":"The Hartford Steam Boiler Inspection and Insurance Co. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2025-04-21","effective_on":null,"summary":"24-0118 response to The Hartford Steam Boiler Inspection and Insurance Co. concerning 180.205, 180.212.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-24-0118.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-24-0118.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-24-0118","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2025-05/240118.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nApril 21, 2025\nTimothy J. Nuoffer\nField Services Manager\nThe Hartford Steam Boiler Inspection and Insurance Co.\nOne State Street\nP.O. Box 5024\nHartford, CT 06102-5024\nReference No. 24-0118\nDear Mr. Nuoffer:\nThis letter is in response to your November 27, 2024 letter requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to rethreading of\nDOT 3-series specification cylinders. Specifically, you ask about re-tapping (also known as\nrethreading) in accordance with §§ 180.205(f)(7) and 180.212, respectively.\nWe have paraphrased and answered your questions as follows:\nQ1.\nDoes letter of interpretation (LOI) Reference No. 09-0111 allow repair facilities with an\napproval in accordance with § 107.805 to rethread DOT 3-series specification cylinders?\nA1.\nPHMSA’s Office of Hazardous Materials Safety provides written clarifications of the\nHMR in the form of LOIs, in accordance with 49 CFR 105.20(a). These letters reflect\nthe agency’s current application of the regulations to the specific facts presented by the\nperson requesting the clarification. LOIs are not generally applicable, do not create\nlegally-enforceable rights or obligations, and are provided to help the specific requestor\nunderstand how to comply with the regulations in their specific circumstances. Section\n180.212(a) requires a repair facility to hold an approval issued under the provisions of\n§ 107.805 to repair a DOT 3-series or a seamless United Nations (UN) pressure\nreceptacle, which includes rethreading a DOT 3-series specification cylinder.\nQ2.\nIs the cylinder manufacturer—permitted to perform rethreading of DOT 3-series\nspecification cylinders under the exception in § 180.212(b)(2)—required to be the\noriginal cylinder manufacturer?\n\n<<<PAGE 2>>>\n\nA2. No. The rethreading of a DOT 3-series specification cylinder is not required to be\nperformed by the original manufacturer. However, please note the cylinder manufacturer\nperforming rethreading must be a manufacturer of the specific cylinder type for which the\nrethreading is being performed. PHMSA recognizes that § 180.205(f)(7) states re-\ntapping of cylinder threads is not permitted, except by the original manufacturer, as\nprovided in § 180.212. In an earlier rulemaking1, PHMSA revised the wording in\n§ 180.212(b)(2) to clarify that the rethreading of cylinders may be performed by a\nmanufacturer of the type of cylinder being rethreaded instead of limiting the work to the\noriginal manufacturer, who may no longer be in business. PHMSA may consider a\nsimilar revision to § 180.205(f)(7) in a future rulemaking.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nDirk Der Kinderen\nChief, Standards Development Branch\nStandards and Rulemaking Division\n1 “Hazardous Materials: Editorial Corrections and Clarifications (RRR)”, 70 FR 55678 (Oct. 1, 2007).\n\n<<<PAGE 3>>>\n\n24-0118\nRoundtree\nJones, Jessie Jane (PHMSA)\nFrom: Cardez, Eugenio (PHMSA)\nSent: Wednesday, November 27, 2024 1:17 PM\nTo: Hazmat Interps\nSubject: FW: Request for Interpretation Regarding Rethreading and Interp 09-0111\nAttachments: Rethread Interp09-0111_Interp11202024.pdf\nFollow Up Flag: Follow up\nFlag Status: Flagged\nHey Alice and Jessie, please add to interp q.\nThanks,\nEugenio\nFrom: Cassidy, Duane (PHMSA) <Duane.Cassidy@dot.gov>\nSent: Wednesday, November 27, 2024 12:15 PM\nTo: Cardez, Eugenio (PHMSA) <Eugenio.cardez@dot.gov>\nSubject: FW: Request for Interpretation Regarding Rethreading and Interp 09-0111\nPlease take a look regarding a question to an interp received to approvals@dot.gov.\nDuane M. Cassidy\nChief, Pressure Vessels Branch (PHH-25)\nSciences and Engineering Division\nOffice of Hazardous Materials Safety\nUS Department of Transportation\nPipeline and Hazardous Materials Safety Administration\nE21-301, 1200 New Jersey Ave SE, Washington, DC 20590\nOffice/Mobile: 202.596.0583\nPHMSA Home | LinkedIn | Twitter | HAZMAT | OPS\nFrom: Nuoffer Timothy - Hartford-Remote-HSB <Timothy_Nuoffer@hsb.com>\nSent: Wednesday, November 27, 2024 12:08 PM\nTo: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov>\nCc: Cassidy, Duane (PHMSA) <Duane.Cassidy@dot.gov>\nSubject: Request for Interpretation Regarding Rethreading and Interp 09-0111\nCAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links\nor open attachments unless you recognize the sender and know the content is safe.\nPlease see the attached request for interpretation regarding rethreading of DOT 3-series cylinders and DOT\ninterpretation 09-0111.\n1\n\n<<<PAGE 4>>>\n\nRegards,\nTimothy Nuoffer\nField Services Manager- Transportation Services\nThe Hartford Steam Boiler\nInspection and Insurance Company\nOne State Street\nP.O. Box 5024\nHartford, CT 06102-5024\nTelephone: +1 (618) 444-7628\nTimothy_Nuoffer@hsb.com\nhsb.com\nIMPORTANT NOTICE:\nThis email (including any attachments) contains confidential and proprietary information that is intended only for the individual or entity designated\nabove. If you are not the intended recipient, please be aware that any use, review, distribution, reproduction, copying, or action taken in reliance upon\nthis email is strictly prohibited. If you received this email in error, please notify the sender immediately, and permanently delete and destroy this email\nand any hard and electronic copies thereof. Although we have taken reasonable precautions to reduce the risk of transmitting software viruses, it is the\nresponsibility of the recipient to ensure that this email is virus-free. The Hartford Steam Boiler Inspection and Insurance Company (including its\nsubsidiaries and affiliates) disclaims any and all liability for any loss or damage caused by this email whether due to viruses, interference, interception,\ndata corruption, unapproved access, misrepresentation, or otherwise.\nIMPORTANT NOTICE:\nThis email (including any attachments) contains confidential and proprietary information that is intended only for the individual or entity designated above. If you\nare not the intended recipient, please be aware that any use, review, distribution, reproduction, copying, or action taken in reliance upon this email is strictly\nprohibited. If you received this email in error, please notify the sender immediately, and permanently delete and destroy this email and any hard and electronic\ncopies thereof. Although we have taken reasonable precautions to reduce the risk of transmitting software viruses, it is the responsibility of the recipient to ensure\nthat this email is virus-free. The Hartford Steam Boiler Inspection and Insurance Company (including its subsidiaries and affiliates) disclaims any and all liability for\nany loss or damage caused by this email whether due to viruses, interference, interception, data corruption, unapproved access, misrepresentation, or otherwise.\n2\n\n<<<PAGE 5>>>\n\nStandards and Rulemaking Division\nPipeline and Hazardous Materials Safety Administration\nAttn: PHH-10\nUS Department of Transportation\nEast Building\n1200 New Jersey Avenue, SE\nWashington, DC 20590-0001\nTo whom it may concern:\n180.205(f)(7) Rethreading and Interpretation 09-0111\nI have the following inquiry concerning the validity of US DOT interpretation 09-0111\nand paragraphs 49CFR180.205(f)(7) and 49CFR180.212(b)(2) regarding who can\nrethread DOT 3-series cylinders.\nBackground: Paragraph 180.205(f)(7) allows the re-tapping of threads to only be\nperformed by the original manufacturer in accordance with 180.212. It appears this\nrequirement was added in the 10/1/2021 edition of the HMR. Paragraph\n49CFR180.212(a)(1) allows repairs of DOT-3 series cylinders to be performed by a\nrepair facility that holds an approval issued under 49CFR107.805 or the repairs are\nperformed under an approval issued under subpart H of part 107 or by a facility\nregistered by Transport Canada. In addition, paragraph 49CFR180.212(b)(2) allows\nfor the cylinder manufacturer to rethread cylinders without prior approval. The words\nin the 180.212 paragraphs appear to be the same words at the time of interpretation\n09-0111 was issued. Interpretation 09-0111 date of issue was 12/03/2012. Answer\nnumber 2 of the interpretation allows repair facilities to rethread DOT 3-series\ncylinders.\nQuestion #1: Is interpretation 09-0111, which allows repair facilities that have\napproval per 49CFR107.805 to rethread DOT-3 series cylinders?\nAnswer #1: Yes. Paragraph 49CFR180.212(a)(1) provides an exception to the\n49CFR180.205(f)(7) requirement of re-tapping of threads can only be performed by\nthe original cylinder manufacturer. DOT-3 series rethreading may be performed by a\nrepair facility that has approval per 49CFR107.805.\n27 November 2024\nTimothy J. Nuoffer\nField Services Manager\nCodes & Standards\nTel.: (618) 444-7628\nTimothy_Nuoffer@hsb.com\nThe Hartford Steam Boiler\nInspection and Insurance Co.\nOne State Street\nP.O. Box 5024\nHartford, CT 06102-5024\nwww.munichre.com/HSB\n\n<<<PAGE 6>>>\n\nPage 2 27 November 2024\nQuestion #2: Paragraph 49CFR180.212(b)(2) allows the rethreading of DOT-3\nseries cylinders to be performed without prior approval by a manufacturer of DOT-3\nseries cylinders. Must this manufacturer be the original cylinder manufacturer?\nTimothy J. Nuoffer\nField Services Manager\nCodes & Standards\nTel.: (618) 444-7628\nTimothy_Nuoffer@hsb.com\nAnswer #2: No\nA reply as soon as possible would be greatly appreciated. Should you have\nadditional questions or need to discuss, please call 618-444-7628.\nSincerely,\nThe Hartford Steam Boiler Inspection and Insurance Co.","truncated":false,"body_characters":9663}