Fike Corporation — Hazardous Materials Safety Interpretation

Page 1of Transportation J.S. Departmen Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Administration Hazardous Materials Safety MAR 18 2005 Mr. Randy Pettitt Ref. No. 05-0009 Welding Specialist-Mechanical Engineering Fike Corporation 704 South 10th Street Blue Springs, Missouri 64013 Dear Mr. Pettitt: This responds to your letter and subsequent telephone conversation with Cheryl Freeman, Office Hazardous Materials Technology, concerning requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to authorized materials for construction of Specification 4BW cylinders. Specifically, you asked if you are correct that §178. 61(b)(2) contains a typographical error as it pertains to the authorized material for Specification 4BW cylinder heads. Authorized materials for construction of Specification 4BW cylinders are specified in § 178.61(b). Section 178.61(b)(1) authorizes the use of materials listed in Table 1 of Appendix A. Material for heads are prescribed in § 178.61(b)(2), in addition to the materials listed in Table 1 of Appendix A. Low carbon steel is an authorized material of construction. Low carbon steel is a steel with a carbon content typically 0.06% to 0.13%. You are correct that, as currently written, § 178.61(b)(2) references § 178.61(a), which applies to the type, size, and service pressure of specification 4BW cylinders and not the authorized material for heads. The reference should be § 178.61(b)(1). We will correct the authorized material requirements in a future rulemaking. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Chief, Standards Development Office of Hazardous Materials Standards 178.61 050009#

Page 2Webb $178.61 Cylinders 05-0009 •CORPORATION 704 South 10Street OBot 610• Blue Springs, Missour 64013 US.A. • 816) 229-3405 • Telefax 816) 229-5082 World Wide Web- http://www.fike.com January 10, 2005 Director, Office of Hazardous Materials Standards Edward Mazzullo 400 7* Street SW, DHM-10 Washington, D.C. 20590 Dear Mr. Mazzullo: This letter is to formally request clarification, in writing on DOT letterhead, of the material requirements for heads used in the manufacture of DOT 4BW cylinders (Ref. 49CFR. 178.61). As per the attached E-mail Material Technology, we I understand the Department of Transportation's Interpretation, the use of the communication between our company representative and Cheryl Freeman of the Office of Hazardous phrase "low carbon steel" in CFR 178.61 (b) (2) refers to a classification of steels (e.g., 1015, 1008, etc.) (HSLA) steel. We further understand that it is not DOT's intention to mandate a strength penalty on HSLA and does not refer to a specific carbon content that may occur in a steel such as a High Strength Low Allow steels that may have a carbon content below .15%, so long as all other applicable requirements are met. Secondly, we understand that there is a typographical error in the current release of CFR 178.61 (b) (2). Appendix A to Part 178}, or {be open hearth, electric or basic oxygen carbon steel of uniform quality with The DOT's intent is to allow steel for heads that either {conform to the limits specified in Table I of a content percent not to exceed the following: Carbon 0.25, Manganese 0.60, Phosphorus 0.045, Sulfur requirements. 0.050.}. The content percent requirements of the latter do not apply to the Table I Appendix A Sincerely, Randy Pettitt Mechanical Engineering Welding Specialist (816) 229-3405 Ext. 1218 Fike Corporation E-mail: randy.pettitt@fike.com Fike Canada, Inc., Burlington, Ontario, Canada • Fike South Ecist Asia Pte. Ltd., Singapore Fike Japan Corporation, Tokyo, Japan • Fike Europe B.v.b.a., Herentals, Belgium Fike Latina LTDA., Sao Paulo, Brazil • Fike India Private Ltd., Pune, India • Fike Protection Systems Ltd., Guildford, U.K#