Q3. You ask whether the recertification (i.e., the requalification) requirements in 49 CFR Part 180 are applicable to stationary cylinder systems installed in a building and refilled by a third party.
A3. The answer is yes if the cylinders are represented as meeting the requirements of the HMR. Section 180.3(a) states no person may represent a packaging, such as a cylinder, as meeting the requirements of Part 180 whether or not it is intended to be used for the transportation of a hazardous material. If the owner of the DOT specification cylinder wishes to continue to use the cylinder but does not wish to re-qualify the cylinder as a DOT specification cylinder, the owner must cover or obliterate any DOT specification markings.
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