Guidanceguidance
25-0027
Ningbo Boahulu Fire-Fighting Equipment Co., Ltd. — Hazardous Materials Safety Interpretation
Current as of source date Government source
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Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration July 10, 2025 Hu Guohua General Manager Ningbo Boahulu Fire-Fighting Equipment Co., Ltd. No.28, Lane 155, North Jingu Road Yinzhou District, Ningbo, China Reference No. 25-0027 Dear Mr. Hu Guohua: This letter is in response to your March 5, 2025, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the marking of refillable United Nations (UN) pressure receptacles in accordance with § 178.71(q) of the HMR. We have paraphrased and answered your questions as follows: Q1. Is it permissible to mark the letters “DOT” within the required marking of § 178.71(q)? A1. UN pressure receptacles cannot have the letters “DOT” marked on them unless they also meet the requirements and standards of a U.S. Department of Transportation (DOT) specification cylinder. Q2. Is it permissible to mark the letters “DOT” in parentheses underneath the required markings of “USA” and the M number (USA/MXXXX)? A2. See answer A1. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, 1200 New Jersey Avenue, SE Washington, DC 20590 T. Glenn Foster Chief, Regulatory Review and Reinvention Standards and Rulemaking Division#
Page 2Ningbo Baohulu Huayun Fire-fighting Equipment Co.,Ltd No.28, Lane 155, North Jingu Road, Yinzhou District, Ningbo, China. +86 574-88213608 baohulu@huayunfire.com.cn March 5, 2025 Standards and Rulemaking Division Pipeline and Hazardous Materials Safety Administration Attn:PHH-10 US Department of Transportation East Building 1200 New Jersey Avenue, SE Washington, DC 20590-0001 Reference: 49 CFR Part 178.71 Interpretation Request To whom it may concern: I am writing to request a letter of interpretation on the 49 CFR in regard to the marking of UN refillable pressure receptacles in 49 CFR 178.71(q). Question 1: Is it permissible to mark the letters "DOT" within the required marking of 178.71(q)? Question 2: If the Q1 is yes, is it permissible to mark the letters "DOT" in parenthesis underneath the USA/MXXXX, like "USA/ MXXXXX"? (DOT) A reply as soon as possible would be greatly appreciated. General Manager Ph:+86 1390661 8808 E-mail: baohulu@huayunfire.com.cn Ningbo Boahulu Fire-Fighting Equipment Co.,Ltd#
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