Interpreting paragraph 7.b. of DOT-E 10915 (13th revision), and in addition to the existing 5 year retest authorizations, we intend that cylinders manufactured prior to May 11, 2001, only back to May, 1998, that were not retested prior to May 11, 2001 are authorized for the 5 year requalification interval. For example, a DOT-E 10915 cylinder manufactured in January, 2000 that has not yet been retested is due for periodic inspection and requalification in January, 2005. The cylinder in this example was manufactured to the same criteria to those manufactured after May 11, 2001 (5 year standard) and therefore would not pose an increase in hazard to those presently authorized for the 5 year requalification interval. The reason for the manufacture date cut-off of May, 1998 is that nearly all cylinders manufactured prior to this date would have been retested by May, 2001 and therefore not qualified for the above interpretation.
A DOT-E 10915 cylinder manufactured in January, 1999 that was retested/requalified in April 2001 is due for it's next periodic requalification in April, 2004. The reason for 3 year retest interval is that the standards and testing criteria in which the cylinder was requalified and certified to successfully meet (pass) at the time of retest was written for 3 years (in the 7th Revision of E-10915). I hope this helps you determine the proper retest schedule for DOT-E 10915 cylinders.
R. Ryan Posten Exemptions Program Officer Office of Hazardous Materials Exemptions and Approvals Research and Special Programs Administration U.S. Department of Transportation 400 Seventh Street SW (DHM-30) Washington DC 20590
