Guidanceguidance
06-0104
CP Industries — Hazardous Materials Safety Interpretation
Current as of source date Government source
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Page 1of Transportation U.S. Department Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Hazardous Materials Safety Administration AY 1 2 200 CP Industries 1r. G. A. Hayden, P Ref. No. 06-0104 2214 Walnut Street McKeesport, PA 15132-7098 Dear Mr. Hayden: This is in response to your April 21, 2006 letter requesting clarification regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to the marking of cylinders. Specifically, you ask if a DOT specification cylinder may contain additional Chinese markings as displayed in your attached cylinder drawing. cylinders provided they are made in low stress areas other than the sidewall, not of a size The answer is yes. Section 178.35(f)(6) authorizes additional markings on specification and depth that will create harmful stress concentrations, and do not conflict with any DOT I hope this information is helpful. Sincerely, Hattie L. Mitchell, Chief Office of Hazardous Materials Standards Regulatory Review and Reinvention 178.35- 060104#
Page 2/ INDUSTRIES 2214 Walnut Street A Division of Reunion Industries, Inc. McKeesport, PA 15132-7098 Tel: 412-664-6604 satlerthwaite April 21, 2006 9178.35 Ms. Hattie L. Mitchell Markings Chief, Regulatory Review and Reinvention 06-0104 Office of Hazardous Materials Standards U.S. Department of Transportation Research and Special Programs Administration 400 Seventh St., SW Washington, DC 20590 Dear Ms. Mitchell, CP Industries manufactures DOT ЗAA, 3AAX, and 3T containers in accordance with 49 CFR Parts 178.35, 178.36, and 178.45. on the left end of the cylinder. markings? (Particularly 178.35 (f)(1) (i), (ii), and (iv), and also 178.35 (f)(6))? Does such a request violate any provisions of 49CFR Part 178.35 (f), which pertains to Note that we would propose to locate the requested Chinese markings always on the opposite end of the cylinder from the DOT required markings. Your interpretation of the acceptability of the requested marking would be very much appreciated. Yours very truly, CP INDUSTRIES stander /A. Hayden. F Chief Metallurgist/ Director QA The leader in pressure vessel technology since 1897#
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