Taylor-Wharton — Hazardous Materials Safety Interpretation

Page 1.S. Depanmer f Transportatiol OCT 13 2005 400 Seventh Street, S.W. Washington, D.C. 20590 Pipeline and Administration lazardous Materials Safety Mr. Les Musselman, P.E. Reference No.: 05-0179 Manager of Product Technology Taylor-Wharton P. O. Box 2365 Harrisburg, PA 17105-2385 Dear Mr. Musselman: This responds to your letter requesting clarification of the requirements for visual inspection of steel cylinders under § 180.205(f) of the Hazardous Materials Regulations (HMR; 49 CFR inspections." Parts 171-180). Specifically, you ask what level of paint constitutes "inhibiting visual Section 180.205(f) requires the visual inspection of a steel cylinder to be performed in accordance with CGA Pamphlet C-6. The HMR and CGA Pamphlet C-6 are silent on the level of paint that would inhibit visual inspection of a cylinder. It is our opinion that excessively caked paint or evidence of exfoliation, such as peeling, blistering or scaling paint, warrants the removal of the paint in the affected area to detect abnormalities that indicate a potential or actual weakness that could make the cylinder unsafe for transportation. I hope this satisfies your inquiry. Sincerely, Male x mitches Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 180.205(f) 050179#

Page 2Jul.27. 2005 2:41PM No. 1393 P. 2/2 M TAYLOR WHARTON 19 : Harsco GasServ 1001 Herr Street P.O. Box 2365 Fax: 717-232-6755 Harrisburg, PA 17105-2365 USA Tel: 717-234-8021 Corbin July 27, 2005 Acting Director Ms. Susan Gorsky $180.205 € U.S. Department of Transportation Pipeline and Hazardous Material Safety Administration Cylinders Office of Hazardous Material Standards PHH-10 05-0179 400 7* Street SW 20590 Washington DC Ms. Gorsky, In 49 CFR 180.205 (f) (1) the statement is made that a visual inspection of steel cylinders must be performed in accordance with CGA Pamphlet C-6. In C-6 section 5.3.1 the statement is made that all rust, scale, caked paint, caked coatings, etc. shall be completely removed from the exterior surface. In 49 CFR 180.205 (f) (2) the statement is made that the exterior coating shall be removed if it would inhibit the visual inspection of the cylinder. Does the Office have a position on what level of paint constitutes "inhibiting visual inspection"? We are unclear on the position of the Office concerning the level of removal of surface paint prior to external visual inspection. Your assistance with this matter is most appreciated. Sincerely, Les Musselman, I Mgr. of Product Technology Taylor-Wharton Page 1 of 1#