PHMSA Response Letter

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Mr. Darrel K. Garton
CTC Certified Training Co.
62537 North Star Drive
Montrose, CO 81401

Ref. No. 07-0166

Dear Mr. Garton:

This responds to your letter requesting clarification of the cylinder requalification requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask three questions pertaining to the requalification requirements applicable to DOT specification 3AL cylinders manufactured from 6351-T6 aluminum alloy, as follows:

Q1. Is it permissible for a retester to subcontract with an outside company who does not hold a current approval (RIN) to provide the eddy current examination service, as prescribed by § 180.209(m)?

A1. No.

Q2. Is it permissible for a retester to subcontract with an outside company who does hold a current approval (RIN) to provide the eddy current examination service, as prescribed by § 180.209(m)?

A2. Yes.

Q3. If the answer to Q2 is yes, is it possible for a company who is not a retester to obtain a “V” number RIN for the purposes of eddy current examination and visual inspection only and then be authorized as a subcontractor in accordance with Q2?

A2. Yes.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.

Sincerely,

Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards

180.209(m)