Letters of Interpretation

The following is a list of written interpretations from Office of Hazardous Materials relating to the re-qualification of cylinders.

You can view all interpretation letters to the Office of Hazardous Materials by CFR section at this link

September 18, 2014 Letter of Interpretation Despite what some other instructors-trainers-inspectors may of told you, here is a letter from PHMSA stating that Hydro-Test pressure gauges meet/exceed requirements of Title49 section 180.205(g)(3)(i).

June 25, 2012 Letter of Interpretation regarding the testing of dry chemical fire suppression system cylinders to fire extinguisher specs.

August 9, 2010 Letter of Interpreation About Using the CGA C-1.1 Pamphlet as a Training Resource

May 13, 2008 Letter of Interpretation concerning the use of latest edition CGA pamphlets vs cited editions

May 17, 2007 Letter of Interpretation About Marking a “VE” on Cylinders That Do Not Require a Eddy Current Examination

June 5, 2006 Letter of Interpretation that allows the end use to star stamp a cylinder

May 24, 2006 Letter of Interpertation Concerning the Proof Testing Requirements of Specification 4B Refrigerent Cylinders

March 23, 2006 Letter of Interpretation Concerning the Use of 3HT Specification Cylinders in the Paintball Industry – DOT’s Interpretation May Suprise You!

September 13, 2004 Letter of Interpretation Concerning Condemned Markings, Maximum Test Pressures, Repeated Test, Star Stamping, Publication Dates

December 17, 2002 Letter of Interpretation Concerning Required Training Being Provided By Independent Inspectors

November 27, 2002 Letter of Interpretation Concerning the use of Labels on Fire Extinguishers

April 2, 2002 Letter of Interpretation Concerning Requalification of 4B Cylinders by Non Licensed Company

March 26, 2002 Letter of Interpretation Concerning Testing of E8840 Exemption Cylinder

November 30, 2001 Letter of Interpretation Concerning Transportation of Cylinder After 15 Year Life

June 21, 2001 Letter of Interpretation Concerning Condemning a Cylinder by a Unauthorized Person

March 15, 2001 Letter of Interpretation Concerning Number of Repeat Test

January 19, 2022 Test Records

January 19, 2022 Visual Records

March 24, 2021 Concerning 3AL Requalification Period

 April 19, 2023 Marking UN Cylinders

 April 20, 2023 Concerning 4D Over-Pressurization

 April 25, 2022 Concerning Outsourcing Eddy Current Examination

 June 24, 2025 Concerning 90 Pretest

 July 10, 2025 Marking DOT on UN Cylinders

 July 22, 2025 Concerning Condemning End of Service Life

 August 28, 2023 Concerning Tested if not Transporting

Did you know that the Office of Hazardous Materials has a support staff available to answer your regulation questions ? You can contact them by email or phone by clicking here.