The Chlorine Institute, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Washington, D.C. 20590 400 Seventh St., S.W. Research and Special Programs Administration JUL 1 0 2003 Gary F. Trojak Ref. No. 02-0141 VP Packaging and Technical Services The Chlorine Institue, Inc. 2001 L Street, N. W. Washington, D.C. 20036-4919 Dear Mr. Trojak: This is in response to your letter and subsequent telephone conversation with Sandra Webb of my staff requesting clantication of the requirements in § 173.34 for marking the tare weight on a cylinder under the Hazardous Materals Regulations (HMR; 49 CFR Parts 171-180). I regret the delay in responding to your letter and hope it has not caused you any inconvenience. The requirement was recently moved in a final rule published on August 8, 2002 under RSPA Docket HM-22OD; 67 FR 51652 to § 173.301(b). Your specific question is paraphrased and answered below. Q: If the cylinder passes inspection and requalification, can the approved testers mark the new tare weight to the right of the original tare weight on the cylinder? A: The answer is yes. Additional information may be marked on the cylinder provided it does not affect the required markings prescribed in § 178.35(1) and the applicable specification as specified in § 173.301(b). However, we recommend that you stamp one diagonal line through the obsoleta, original tare weights), if present, so that it is still legible for future reference. I trust this satisfies your request. Please contact us again if we can be of further assistance. Sincerely, Masa Susan Gorsky Senior Transportation Regulations Specialist Office of Hazardous Materials Standards#

Page 2THE CHLORINE INSTITUTE, INC., 2001 L STREET, N.W., WASHINGTON, D.C. 20036 - 4919 202-775-2790 Webb Fax 202-223-7225 $ 173.34 (e) http://www.CL2.com Stephen R. Firzgerald, Chair Cylinders Dr. Robert G. Smerko, President Carol A. Dudley, Vice Chair April 30, 2002 02-0141 Mr. Edward Mazzullo Director for Hazardous Materials Standards U.S. Department of Transportation 400 Seventh Street, S.W., DHC-10 Washington, D.C. 20590-0001 Dear Mr. Mazzullo: The Chlorine Institute, Inc, has been in existence for over 75 years. Our members represent over 99% of all U.S. chlorine production and 90% of the chlorine packaging plants. My questions concern cylinder requalification. CI has been approached by several member companies concerning tare-weight stamping on chlorine 3A and 3AA cylinders. RSPA refers to Compressed Gas Association (CGA) Pamphlet C-6 in their regulations found at 49 CFR §173.34(e). Pamphlet C-6 states on page 6, section 3.2.1.1 that a cylinder with a tare weight loss of five percent or greater is required to be rejected for service. If the cylinder tare weight loss is ten percent or greater, Pamphlet C-6 and 49 CFR 173.34(e) both state that the cylinder must be condemned and removed from service. If the loss is five percent or greater, but less than ten percent, the CGA Pamphlet states that the cylinder must be inspected and requalified by hydrostatic testing. The questions I received are regarding cylinders that pass these inspections and requalifications. 1. If the cylinder passes inspection and requalification, can the approved testers mark the new tare weight to the right of the original tare weight on the cylinder? The reason for requesting this ability to mark the cylinder with the new tare weight is due to the following safety concerns! a) Packagers do not want to overfill the cylinders and the tare weight is needed to prevent this; * " : ...% ***** :** * * •24* А Анороженя СлАя PRATARA ARROGAN#

Page 3Mr. Edward Mazzullo Director for Hazardous Materials Standards U.S. Department of Transportation April 30, 2002 Page 2 Though the cylinder passed requalification, if the cylinder continues to lose weight, packagers need to know the original tare weight to make sure it is retested or condemned if the tare weight decreases below either of these two established percentage levels. Please contact me if you have any questions at: 202-872-4731 or by e-mail: gtrojak@CL2.com Sincerely, F. Tryis *. Trojak VP - Packaging and Technical Services#