{"operation":"document","citation":"00-0046","title":"Taylor-Wharton — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2000-03-24","effective_on":null,"summary":"00-0046 response to Taylor-Wharton concerning 178.57.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0046.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0046.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0046","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000046.pdf","body":"<<<PAGE 1>>>\n\nUS. Department\nof Transportation\n400 Seventh Street, S.W.\nWashington, D.C.\n20590\nResearch and\nAdministration\nspecial Program:\nMAR 2 4 2000\nMr. Glenn Curtis\nTaylor-Wharton\nRef. No: 00-0046\n4075 Hamilton Blvd.\nTheodore, AL 36582\nDear Mr. Curtis:\nThis is in response to your February 7, 2000, letter requesting clarification of the term \"lot\" as it\npertains to DOT specification 4L welded cylinders under the Hazardous Materials Regulations\n(HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows:\nQ. We manufacture different cylinder models that are identical in all respects, except for a 7%-8%\nvolumetric capacity due to a difference in shell length. May the two models be considered a \"lot\"\nprovided their combined quantity doesn't exceed 200?\nA. No. A \"lot\" is considered to be cylinders of the same size that are successively produced in the\nsame shift (see § 178.65(f). Although $ 178.65 pertains to DOT Specification 39 cylinders, \"lot\"\nhas the same meaning throughout the HMR. This will be clarified in a future rulemaking action.\nQ. Due to a delay we interrupt manufacturing of a lot of cylinders. At some later time we resume\nproduction using the same heats of materials, designs, equipment, and process. Are all cylinders\nmanufactured both before and after the interruption considered as one \"lot\" in relation to the testing\nrequirements of § 178.57(1)(1)(2) or (3)?\nA. No, for the same reasons.\nI hope this information is helpful.\nSincerely,\nWhen th things,\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n000046\n178.57\n\n<<<PAGE 2>>>\n\n) TAYLOR-WHARTON\n4075 Hamilton Blvd\nCorpse Controlid\nTheodore, AL 36582 USA\ncorporation Control Group\nFacsimile (334) 443-2251\nTelephone (334) 443-8680\nFebruary 7, 2000\nLavalle\n$178.57\nRSPA Office of Hazardous Materials Standards (DHM 10)\nU.S. Department of Transportation\n00 - 0046\n400 Seventh Street, SW.\nWashington, DC 20590-0001\nRe: Interpretation Request\nTo Whom It May Concern:\nIn a review of our manufacturing operation, discussions emerged prompting us to seek your\ninterpretation for a couple of issues concerning \"a lot\" as it relates to 49CFR178.57, Specification 4L\nWelded Insulated Cylinders.\n• Assume we manufacture, back to back, different cylinder models that are identical in all\nrespects, except for a 7%-8% volumetric capacity difference resulting from a different shell\nlength. Are we correct, in our determination that the 2 models could be considered \"a lot\"\nprovided their combined quantity doesn't exceed 200?\n• Assume, because of time constraint or another extraneous delay, we interrupt manufacturing\nof a lot of cylinders, and at some later time, resume production using the same heats of\nmaterials, designs, equipment, and process. Are we correct in our determination that all the\ncylinders manufactured both before and after the interruption can be considered as 1 lot in\nrelation to the testing requirements of 49CFR178.57, (I), (1), & (2) or (3)?\nI'm looking forward to your response.\nI can be reached at 334-443-2205 between the hours of 7:00 AM and 4:00 PM, Central Daylight\nSavings Time.\nRespectfully,\nRem Quitin\nGlenn Curtis\nQuality Assurance Manager\n-","truncated":false,"body_characters":3214}