# HSB Global Standards — Hazardous Materials Safety Interpretation **Citation:** 13-0176 **Type / status:** guidance / guidance **Agency:** Pipeline and Hazardous Materials Safety Administration **Effective:** Not stated **Published:** 2013-11-19 13-0176 response to HSB Global Standards concerning 178.57. ## Document text <<>> U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590 NOV 1 9 20tl Mr. Oberst Mulet HSB Global Standards One State Street P.O. Box 299 Hartford, CT 53403-5011 Ref. No. 13-0176 Dear Mr. Mulet: This responds to your August 22, 2013 email regarding physical testing of DOT Specification 4L cylinders under the Hazardous Materials Regulations (HMR; 49 CFR Parts I 71-180). You note that for most of the DOT Specification "300 series and 400" series cylinders, when physical testing of specimens is required, the specimen must conform to the following: "A gauge length of8 inches with a width not over I \'2 inches, a gauge length of2 inches with width not over 1 Yz inches, or a gauge length at least 24 times thickness with a width not over 6 times 3 thickness (authorized when cylinder wall is not over / 16 inch thick)." You fmiher note, however, that for physical testing of DOT Specification 4L cylinders under§ 178.57(j)(2)(i), the criterion for the cylinder wall is "not over 1 / 16 inch thick." You ask whether this value is correct or whether it should read "not over 3 I 16 inch thick" consistent with the value for other DOT specification cylinders. The criterion for the cylinder wall should read ''not over 3/ 16 inch thick." Under rulemaking HM-220B (61 FR 25940; May 23, 1996), we restructured the cylinder specification requirements by consolidating repetitive requirements and implementing other formatting changes. In doing so, for a DOT Specification 4L cylinder, the cylinder wall thickness value was inadvertently changed to 'd/16 inch." Prior to HM-220B, the value had been 'd/16 inch" consistent with the other DOT specifications. We thank you for bringing this matter to our attention. PHMSA will revise this language in a future rulemaking. I hope this information is helpful. If you have further questions, please contact this office. Sincerely, /~0~ Robert Benedict Chief, Standards Development Branch Standards and Rulemaking Division ------------------- <<>> ber kt~deven § 11'6. 51Q)Cz]J Drakeford, Carolyn (PHMSA) From: Sent: To: Cc: Subject: Betts, Charles (PHMSA) Friday, August 23, 2013 10:57 AM Drakeford, Carolyn (PHMSA) 1'--3 -o 11 ~ Cassidy, Duane (PHMSA) FW: 4BW Cylinder specification 178.57U)(2)(i) Specimens dimensions for physical testing. ~Jinder:s Importance: High Carolyn- Please log and assign to a specialist for handling. Thanks, Charles From: Mulet Oberst - Hartford-HSBCT [mailto:oberst mulet@hsbct.com] Sent: Thursday, August 22, 2013 4:57PM To: cassidy, Duane (PHMSA) Subject: 4BW Cylinder specification 178.57(j)(2)(i) Specimens dimensions for physical testing. Dear Mr. Cassidy: I hope you are doing well. I have the following question concerning paragraph 178.57(j)(2)(i) of the 49 CFR Transportation. For 300 series and 400 series cylinders specifications, when required, the conditions for obtaining a specimen from a cylinder or sphere for the required physical testing, one of the options among others is as follows: "A gauge length of 8 inches with a width of not over 1-1.12 inches, a gauge length of 2 inches with a width of not over 1- 1.12 inches, or a gauge length of at least 24 times the thickness with a width not over 6 times thickness is authorized when a cylinder wall is not over 3/16 inch thick." While for 4L Cylinder Specifications the requirement reads: 178.57(j)(2)(i) "A gauge length of 8 inches with a width not over 1-1.12 inches, a gauge length of 2 inches with width not over 1-1.12 inches, or a gauge length at least 24 times thickness with a width not over 6 times thickness (authorized when cylinder wall is not over 1/16 inch thick)." My question is: For 4L cylinder specification is the one-sixteenth (1/16) inch the correct value and not three-sixteenth (3/16) inch? I have searched the regulation and 4L is the only specification I found with this requirements and I thought it was possibly a mistake therefore I am requesting your corroboration. Thank you in advance. Regards; Oberst Mulet Engineer II HSB ·Global Standards ONE STATE STREET 1 <<>> P.O. BOX 299 HARTFORD, CT 06416-0299 T: (860) 722-5528 F: (860) 722-5705 - HSBGiobaiStandards.com Oberst Mulet@hsbct.com The information contained in this e-mail, including any attachment(s), is intended solely for use by the named addressee(s). If you are not the intended recipient, or a person designated as responsible for delivering such messages to the intended recipient, you are not authorized to disclose, copy, distribute or retain this message, in whole or in part, without written authorization from HSB CT. This e-mail may contain proprietary, confidential or privileged information. If you have received this message in error, please notify the sender immediately. Thank you for your cooperation. 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Although this email and any attachments are believed to be free of any virus or other defect that might affect any computer system into which it is received and opened, it is the responsibility of the recipient to ensure that it is virus free and no responsibility is accepted by Global Standards, LLC or its subsidiaries or affiliates either jointly or severally, for any loss or damage arising in any way from its use. 2 ## Provenance - Official: Yes - Source: - Source ID: `phmsa` - SHA-256: `da74c69de51f27cd7deb4f527c3413dafa8874c857941b49ca049f4118608d41` - Retrieved: 2026-08-20T00:59:31.977Z - Exported: 2026-08-22T17:26:46.305Z - Document slug: `phmsa-interpretation-13-0176` ### Source metadata ```json { "materialSubtype": "interpretation", "interpretationArea": "hazardous_materials", "representation": "full_text_from_official_pdf", "companies": [ "HSB Global Standards" ], "individuals": [ "Mr. Oberst Mulet" ], "refIds": [ "13-0176" ], "catalogDates": [ "2013-11-19" ], "catalogParts": [ 178 ], "catalogRowCount": 1, "sourceRecordUrls": [ "https://www.phmsa.dot.gov/node/66606" ], "linkedAttachmentUrls": [], "unavailableResponseUrls": [], "duplicateRepresentationUrls": [], "citedSections": [ "178.57", "178.57(j)(2)(i)", "178.57U" ], "catalogPageUrls": [ "https://www.phmsa.dot.gov/regulations/title49/section/17857" ], "pdfUrls": [ "https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2013/130176.pdf" ], "representations": [ { "viewUrl": "https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2013/130176.pdf", "detailUrl": null, "detailHtmlPath": null, "pdfUrl": "https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2013/130176.pdf", "pdfArtifactPath": "data/sources/phmsa-interpretations/13-0176-912c916bac.pdf", "pdfArtifactSha256": "3b63554d56286e06f88fa99c9596b192416735e423635477fd4d0977182f2174", "extractedTextPath": "data/sources/phmsa-interpretations/13-0176-912c916bac.v2.txt", "extractedTextSha256": "7e14b2842ebe4173b1c7b3b63774c818a014d82a121a693f1e262d8c39ad4841", "pageCount": 3, "extractionVersion": 2 } ], "caveat": "Interpretations apply regulations to the facts presented and do not create independently enforceable requirements.", "jurisdiction": "US" } ```