{"operation":"document","citation":"03-0062","title":"Breed — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2003-03-19","effective_on":null,"summary":"03-0062 response to Breed concerning 178.65.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0062.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0062.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0062","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2003/030062.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\n400 Seventh St., S.W.\nResearch and\nWAR 19 208\nWashington, D.C. 20590\nAdministration s\nMr. David Gamlen\nManager, Packaging Engineering\nBreed\nRef. No.: 03-0062\n5300 Allen K. Breed Highway\nP.O. Box 33050\nLakeland, FL 33807-3050\nDear Mr. Gamlen:\nThis is in reference to your February 27, 2003 letter concerning the specification requirements in\n49 CFR 178.65 for DOT 39 specification non-reusable cylinders and the exemption requirements\nin DOT-E 11993. Specifically, you inquired whether a proof pressure test (without\ndetermination of expansion) must be performed on the cylinder that is hydrostatically tested to\nline to vent the cylinder and prepare it for the hydrostatic test.\ndestruction under § 178.65(f(2). You expressed concern about interrupting the manufacturing\nThe answer is yes. Under § 178.65(f), both pressure tests must be performed. Paragraph (f(1)\nrequires that each cylinder must be given a proof pressure test; whereas, paragraph (f)(2) requires\nthat one cylinder taken from each designated lot be tested to destruction.\nThe cylinder taken from the lot be burst tested may meet the leak test and burst test requirements\nduring the same test. This can be done if the cylinder meets the requirement of § 178.65(f)(1) by\nbeing held at test pressure for at least 30 seconds without leaking, and then continues to be\npressurized to destruction in accordance with the requirements of § 178.65(f(2). For DOT-E\n11993, the hold time would be 10 seconds instead of 30 seconds.\nMost of the other low-pressure cylinder specifications have different requirements. As an\nlesignated lot must be given a hydrostatic test with determination of total and permanent\nexample, the DOT 4B specification in § 178.50(i) requires that one cylinder taken from each\nvolumetric expansions. All other cylinders must be given a proof pressure test.\nI hope this satisfies you inquiry. Should you have any further questions, please contact this\noffice.\nSincerely,\nHathe z. Mithell\nHattie L. Mitchell\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n178.65\nBOHEMINI\n030062\n\n<<<PAGE 2>>>\n\nBREED\n5300 Allen K. Breed Highway\nWorld Headquarters\nLakeland, Florida 33807-3050\nP.O. Box 33050\nTelephone 863-668-6035\nFax 863-668-6228\nMitchell\nFebruary 27, 2003\n8118:656)\nHattie Mitchell\nChief, Regulatory Review and Reinvention\nCylinders\nOffice of Hazardous Materials Standards\nUS Department of Transportation / DHM-12\n03-0062\n400 Seventh St., SW\nWashington, DC 20590-0001\nSubject:\nRequest for Letter of Interpretation Concerning Pressure Tests\nof non-DOT Specification Cylinders, reference DOT-E 11993\nand 49CFR178.65(f).\nDear Ms. Mitchell:\nBREED Technologies, Inc., at the above address, requests a letter of\ninterpretation concerning pressure tests of non-DOT specification cylinders.\nBREED is manufacturing the non-DOT specification cylinders in accordance with\nexemption DOT-E 11993. Pressure tests are referenced in paragraph 7(b)(1) of\nthe exemption. This paragraph requires testing per 49CFR178.65(f), except that\nthe hold time at test pressure specified in 178.65(f)(1) must be no less than 10\nseconds.\nThe issue that has been raised is whether or not proof testing is required to be\noperations currently are and have always performed a proof test, prior to\npertormed on the vessel used for hydrostatic testing. BREED's manufacturing\nperforming the hydrostatic test to destruction. A relatively new employee, who\npreviously worked for one of our competitors, says that the competition is not\nperforming the proof test prior to hydrostatic test. This employee claims that we\nare being held to a more stringent interpretation of the regulations.\nThis is an issue for operations because the proof test is performed on the\nmanufacturing line and the hydrostatic test is performed off-line. The\nmanufacturing line must be interrupted during production so that the gas in the\nproof tested vessel can be carefully vented prior to removal from the production\nline. This process results in down time and loss of productivity.\nBREED Request for Letter of Interpretation of Pressure Tests.\nPare 1 of 2\n\n<<<PAGE 3>>>\n\nThe independent inspection agencies differ in their interpretation of this issue. I\nspoke with a person in the Office of Hazardous Materials Technology who\nthought the regulation could be interpreted either way. The person commented\nthat it a cylinder passed the hydrostatic test, it would certainly pass the proof test.\nIf you have any questions or require additional information or documentation to\n(863)668-6228 or by e-mail at gamlend@breedtech.com.\nprocess this request, I can be reached by telephone at (863)668-6035, by fax at\nSincerely,\nDavid Gamber\nDavid Gamlen\nManager, Packaging Engineering\nBREED Request for Letter of Interpretation of Pressure Tests.\nPage 2 of 2","truncated":false,"body_characters":4846}