Structural Composites Industries (SCI) — Hazardous Materials Safety Interpretation

Page 1U.S. Department Research and of Transportation 400 Seventh St., S.W. Washington, D.C. 20590 Special Programs Administration APH - 3 2003 Mr. Robert Beck Director of Quality and Technical Services Structural Composites Industries (SCI) Ref No. 02-0295 325 Enterprise Place Pomona, CA 91768 Dear Mr. Beck: This is in response to your November 13, 2002, letter requesting clarification of the marking requirements of cylinders manufactured to the Carbon-Fiber Reinforced Aluminum Lined Cylinders (DOT-CFFC) standard. You stated that most carbon composite cylinders manufactured by SCI have an outside layer of a resin-based material (FlowCoat) added to the cylinder. Specifically, you asked if it is permissible to place the cylinder label containing the manufacturing standard information under this FlowCoat. The answer is no. The marking requirements in DOT-CFFC Standard, Section CFFC-14, state that cylinders made in conformance with this standard and the applicable DOT exemption must be permanently marked (other than stamping) in the composite overwrap on the sidewall. Therefore, your proposed label application does not meet the requirements of the DOT-CFFC standard. You may submit a request to modify the terms of the applicable exemption by providing supporting information to demonstrate that your proposed modification will achieve a level of safety at least equal to that established by the current standard and current exemption. If we can be of further assistance, please contact us. Sincerely, Delmer F. Billings Chief, Regulations Development Office of Hazardous Materials Standards 178.35 020295#

Page 2• Structural Composites Industries SCE Harsco Pomona, CA 91768 USA 325 Enterprise Place Telephone: 909.594.7777 Web: www.scicomposites.com Fax: 909.594.3939 November 13, 2002 Webb Via Federal Express $178.35 Mr. Ed Mazzullo I. S. Department of Transportatio Cylinders Standards Section office of Hazardous Material: 02-0295 Washington, D.C. 20590 400 South Seventh Street S.W. Subject: Request for Interpretation of CFFC-14 MARKING Dear Mr. Mazzullo: conformance with this standard and the applicable DOT exemption must be permanently CFFC Specification, section CFFC-14 Marking (a) reads; "Each cylinder that is made in narked (other than stamping) in the composite over wrap on the sidewall. The marking environment and handling." nust be easily visible and must be protected from external damage due to the Most carbon composite cylinders manufactured by Structural Composites Industries have an outside layer of a resin-based material (FlowCoat) added to the cylinder. In the ylinder label under this coating. In the case where there is no FlowCoat as the exterio ase where the cylinder has FlowCoat as the exterior coating, SCI wants to put th coating, SCI will continue to put the label under a layer of fiberglass. it is our position that both of the above cases of label application meet the intent of the specification; i.e. "must be easily visible and protected from external damage due to the environment and handling." Please issue a formal written interpretation on our position. Sincerely Director of Quality and Technical Services Harsco Corporation Gas & Fluid Control Group#

Page 3DOT-CFFC BASIC REQUIREMENTS (FOURTH REVISION) PAGE 20 and operated so as to obtain accurate data The pressure reading must be accurate withir calibration. CGA pamphlet C-1 "Methods of Hydrostatic Testing of Compressed Gas Cylinders." in each lot must be subjected to a Visual inspection and marking: thorough visual All cylinders marking requirements. inspection for quality and for conformance with the CFFC-14 MARKING: (a) Each cylinder that is made in conformance with this standard and the applicable DOT exemption must must be easily visible and must be protected from The marking external damage due to the environment and handling. requirements of this standard and the DOT exemption (b) The details of the marking must conform to the marking must contain the following: under which the cylinders are manufactured. The followed by service pressure expressed ir (1) DOT Exemption number (DOT E-XXXXX) pounds per square inch gauge (psig) . identification number or a symbol as obtained (11) A serial number and the manufacturer's Materials safety, from the Associate Administrator for Hazardous immediately following the DOT marking above. located just below or must be placed near the serial number. (iii) The DOT inspector's official mark marking must contain date (month and year) of The the initial hydrostatic test for that cylinder. * (iv) Rejection elastic expansion (REE) marking in cubic centimeters. design type cylinder is obtained as follows: The REE for each#