{"operation":"document","citation":"02-0080","title":"Allied Universal Corp. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2003-07-10","effective_on":null,"summary":"02-0080 response to Allied Universal Corp. concerning 173.301, 173.302a, 178.35.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0080.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0080.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0080","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020080.pdf","body":"<<<PAGE 1>>>\n\n•\ni US. Deparment\n400 Seventh St, S.W.\nof Transportation\nWashington, D.C. 20590\nSpecial Programs\nResearch and\nAdministration\nJUL 1 0 2003\nMs. Robin J. Eddy Bolte\nRef. No. 02-0080\nSafety and Regulatory Complaince Manager\nAllied Universal Corp.\n3901 N. W. 115ª Avenue\nMiami, FL 33178\nDear Ms. Bolte:\nThis is in response to your letter and subsequent telephone conversation with Sandra Webb of my staff\nrequesting clarification of the requirements for marking the tare weight on a cylinder under the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you state that your\ncompany is trying to determine the proper procedure for handling DOT Specification 3A and 3AA,\ncylinders that show distinct loss in weight, between five (5) and nine (9) percent of the original stamped\ntare weight. I regret the delay in responding to your letter and hope it has not caused you any\ninconvenience.\nThe requirement previously contained in § 173.34(c) was recently moved to § 173.301(b) in a final rule\npublished on August 8, 2002, under RSPA Docket HM-220D; 67 FR 51652. Your specific questions\nare paraphrased and answered below.\nQI:\nIf the cylinder passes inspection and requalification, may our hydrostatic testers or third party\nhydrostatic testing service mark the new tare weight to the right of the original tare weight on\nthe cylinder?\nAl:\nThe answer is yes. Additional information may be marked on the cylinder provided it does not\naffect the required markings prescribed in § 178.35(1) and the applicable specification as\nspecified in § 173.301(b). However, we recommend that you stamp one diagonal line through\nthe obselete, orginal tare weights), if present, so that it is still legible for future reference.\n02:\nIs it true that a cylinder with a five to nine percent tare weight lost passing inspection and\nhydrostatic testing may only be used for one year from the date of that testing, or may it be used\nuntil additional inspection and hydrostatic testing is warranted or it fails the ten percent tare\nweight lost rule?\nA2:\nWith the exception of DOT Specification 3HT cylinders (see § 173.302a(a)(2) as specified\nunder Docket HM-220D (67 FR 51626; 51646; August 8, 2002)) or cylinders manufactured\nunder exemption, DOT cylinders do not have a specified service life. Therefore, if the cylinder\n\n<<<PAGE 2>>>\n\nconforms to the applicable requirements specified in Part 173 and Part 180 of the HMR, it may\nbe used in the transportation of hazardous materials.\nI trust this satisfies your request. Please contact us again if we can be of further assistance.\nSincerely,\nSiven troy\nSusan Gorsky\nSenior Transportation Regulations Specialist\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nWebb\n{173.34\nCylinders\nALLIED UNIVERSAL CORP., 3901 N.W. 118º Avonuo, Miami, Florida 33178\nFax 305-885-4671\n305-888-2623\nMr. Edward Mazzullo\nDirector for Hazardous Materials Standards\n02-0080\n400 Severith Streel, S.W., DHM-10\nU.S. Department of Transportation\nWashington, D.G. 20590-0001\nMarch 1, 2002\nSubyect: Interpretation, Cylinder Requalification\nDear Mr. Mazzullo:\nMy company is trying to determine the proper procodure for handing DOT Specificalion 3A and 3AA\nfare weight.\ncylinders that show a distinct loss in weight, betwoon five end nine percent, from their original stamped\n$173.34(e), Pamphlet C-l states on page 6, section 3.2.1.1 (copy enclosed) that a cylinder with a tare\nRSPA refers to Compressed Gas Association (CGA) Pamphlet C-6 In their regulations found al 49 CFR\nweight lost of five percent or greater is required to be rejected for service, If the cylinder tare weight loss\nis ten percent or greater, Pamphlet C-b and 49 CFR 173.34(0) both state that the cylinder must be\ncondemned and removed from service. If the loss is five percent of greater, but not more than ten\ntesting. Our questions are regarding cylinders that pass these inspoctions and requalifications.\npercent, the CGA Pamphlet stales that the cylinder must be Inspectod and requalified by hydrostatic\n1. If the cylinder passes inspection and requalification, may our hydrostatic testers of third\nparty hydroststic lasting service mark the now taro weight to the right of the original tare\nfare weight is due to the following safety concems:\nweight on the cylinder? Our reason for requesting this ability to mark the cylinder with the new\na) One, we do not want to overfill the cylinders; hence the reason for the new lase weight for our\nb) Two, though the cylinder passed requalification, if the cylinder continues to lose weight, we need\ncylinder fillers, and,\n1o know the onginal fare weight 1o make sure it is rotested or condemned as indicaled in the\n2. We were told that a cylinder with a tare weight loss of five percent, but not greater than nine percent,\nprevious paragraph.\nthat passes requalification has a use life of one year from the dato of requalification testing. One\nyear from the date of the requalification testing the cylinder must be condemned, and removed from\nservice. Is it true that a, cylinder with a five to nine percent tare weight lost passing\ntesting, or may it be used until additional inspection and hydrostatic testing is warranted or it\ninspection and hydrostatic testing may only be used for one year from the date of that\nfails the ten percent taro weight lost rule?\nIf you should have any questions, please call me al 800-437-8715, extension 183.\nThank you.\nKi Shur\nAllied Universal Corp.\nSately and Regulatory Compliance Mansoer\nz0•\n6662-908-676\n\n<<<PAGE 4>>>\n\nI CGA C-6-1993\nРаде в\nCOMPRESSEO GAS AXSOCIATION AYE\noccurs in the ares of the intersection of the footring\n2.2.6.3 Crevice Corrosion. Crevice corrosion\n2.2.7 Weld Defects. Cracks or faws in weld\nof crevice corrosion.\nor headring with the cylinder. Fig. 4 is an example\nareas reduce the structural strength of metal\nwhich may eause separation when pressurized.\nthat which covers considerable surface areas of the\n2.2.6.4 General Corrosion. General corrosion is\n3. LOW PRESSURE CYLINDERS EXEMPT\nFROM THE HYDROSTATIC TEST\noften difficult to measure or estimate the depth of\ncylinder. It reduces the structural strength. It is\nThis section covers cylinders exempt from\nthe original wall cannot always be made. General\ngeneral corrosion because direct comparison with\nhydrostatic retest requirements of the DOT by\nvirtue of their exclusive use in certain non-\ncorrosion is often accompanied by pitsing. This\ncorrosive gas service. They are nos subject to\nform of corrosion is shown in Figs. 5 and 6.\ninternal corrosion and do not require internal\nshell inspection. il. due to unusual circumstances.\ncylinders of these types suffer internal corrosion.\nthey should be inspected in accordance with the\nprocedure in Section 4.\n3.L Preparation for Inspection. Al the time of\nrequalification. all russ, scale. caked paint, caked\nthe exterior surface so that the surface is\ncoatings, erc., shall be complescly removed from\nadequately prepared for inspection.\nchecked as outlined below for corrosion, general\n3.2 Exterior Inspection. Cylinders shall be\na weakness which would render them unfit for\ndistortion. or any other defcet that might indicate\nservice.\n3.2.) Corrosion\n3.2.1.1 Corrosion Limits. To fix corrosion\nlimits for all types, designs and sizes of cylin.\npracsicable: Failure to meel any of the following\nders. and include them in this standard ts not\nfour general rules is cause for condemning a\ncylinder.\nFig. S. General Corrosion with Pitting.\ntare weight is less than 90% of the original\n(1) A cylinder shall be condemned when the\nstampedisre weight & cylinder shall be rejecred\noriginal stamped tare weight. A rejeczed cylin.\nwhen the rare weight is less than 95% of the\nder may be requalificd in accordance with 49\nexpansion. [1) When decermining rare weight. be\nCER 173.31(e). by water jacket or by direct\nsure the cylinder is empty.\nremaining wall in an area having isolated pitting\n(2) A cylinder shall be condemned when the\nmum allowable wall thickness. Refer to Fig. 2.\nonly is less than one-third of the original mini-\ncrevice corrosion on the cylinder is 3 inches (76:2\n() A cylinder shall ue condemned when line or\nless than three fourths of the original ininimum\nmm) in length or over and the remaining wall is\n-\ncorrosion isless than 3 inches (76.2 mm) inlength\nallowable wall thickness or when line or crevice\nand the remaining wall thickness is less than\nFix. 6. Goneral Corrosion with Pirting on Cylinder Wall\nthickness. Refer to Figs, 3 and 1.\none-hail the original minimum allowable wall\n6662-908-616\n\n<<<PAGE 5>>>\n\n..\nALLIED UNIVERSAL CORPORATION\nPHONE: 800.107.071STEAX:005.883148;1859\n115T* AVENUE.\nFACSIMILE TRANSMITTAL SHEET\n10.\nEdwaro Mazzullo\nFRoM Robin Botto\nCOMPANY:\nMISDOT /RSPA\nDATE.\n3-13-02\nPAX NUMBER\nTOTALNO. ON PAGIX INCIUDING COVEA\n202-334-3012\nPHONE NUMBEY:\n202-344-8853\nInterpretation Request\nO URGENT\nFOR REVIEW\nO PLEASE COMMENT\nOPLEASE REPLY\nNOTES/COMMENTS\nMr. Muzzullo,\nIf you can not read this, please contact me. EPA sent usal a\nletter asking us not to mail anuthing to Dc. To tax it, Feder it,\nCouriex snice it, but no mail.\nRobi\nTo d\n6662-908-616","truncated":false,"body_characters":9107}