Taylor-Wharton — Hazardous Materials Safety Interpretation

Page 1US. Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590 Research and Administration special Program: MAR 2 4 2000 Mr. Glenn Curtis Taylor-Wharton Ref. No: 00-0046 4075 Hamilton Blvd. Theodore, AL 36582 Dear Mr. Curtis: This is in response to your February 7, 2000, letter requesting clarification of the term "lot" as it pertains to DOT specification 4L welded cylinders under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows: Q. We manufacture different cylinder models that are identical in all respects, except for a 7%-8% volumetric capacity due to a difference in shell length. May the two models be considered a "lot" provided their combined quantity doesn't exceed 200? A. No. A "lot" is considered to be cylinders of the same size that are successively produced in the same shift (see § 178.65(f). Although $ 178.65 pertains to DOT Specification 39 cylinders, "lot" has the same meaning throughout the HMR. This will be clarified in a future rulemaking action. Q. Due to a delay we interrupt manufacturing of a lot of cylinders. At some later time we resume production using the same heats of materials, designs, equipment, and process. Are all cylinders manufactured both before and after the interruption considered as one "lot" in relation to the testing requirements of § 178.57(1)(1)(2) or (3)? A. No, for the same reasons. I hope this information is helpful. Sincerely, When th things, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 000046 178.57#

Page 2) TAYLOR-WHARTON 4075 Hamilton Blvd Corpse Controlid Theodore, AL 36582 USA corporation Control Group Facsimile (334) 443-2251 Telephone (334) 443-8680 February 7, 2000 Lavalle $178.57 RSPA Office of Hazardous Materials Standards (DHM 10) U.S. Department of Transportation 00 - 0046 400 Seventh Street, SW. Washington, DC 20590-0001 Re: Interpretation Request To Whom It May Concern: In a review of our manufacturing operation, discussions emerged prompting us to seek your interpretation for a couple of issues concerning "a lot" as it relates to 49CFR178.57, Specification 4L Welded Insulated Cylinders. • Assume we manufacture, back to back, different cylinder models that are identical in all respects, except for a 7%-8% volumetric capacity difference resulting from a different shell length. Are we correct, in our determination that the 2 models could be considered "a lot" provided their combined quantity doesn't exceed 200? • Assume, because of time constraint or another extraneous delay, we interrupt manufacturing of a lot of cylinders, and at some later time, resume production using the same heats of materials, designs, equipment, and process. Are we correct in our determination that all the cylinders manufactured both before and after the interruption can be considered as 1 lot in relation to the testing requirements of 49CFR178.57, (I), (1), & (2) or (3)? I'm looking forward to your response. I can be reached at 334-443-2205 between the hours of 7:00 AM and 4:00 PM, Central Daylight Savings Time. Respectfully, Rem Quitin Glenn Curtis Quality Assurance Manager -#