{"operation":"document","citation":"06-0276","title":"Thunderbird Cylinder, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2007-11-14","effective_on":null,"summary":"06-0276 response to Thunderbird Cylinder, Inc. concerning 173.28, 180.209.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0276.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0276.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0276","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2007/060276.pdf","body":"<<>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nMr. Fred A. Nachman\nThunderbird Cylinder, Inc.\n4209 E. University Drive\nPhoenix, AZ 85034-73 15\nRef. No.: 06-0276\nDear Mr. Nachman:\nThis is in response to your request for a clarification of the cylinder requalification\nrequirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1 - 180). Your\nquestions are paraphrased and answered as follows:\nQ1. Al. 42. A2. 43. A3. 44. Is a leakproofness test required under $ 180.209(g)? If yes, how is the test performed?\nYes. Section 180.209(g) specifies that the external visual inspection must be\nperformed on the named cylinders in accordance with either Compressed Gas\nAssociation (CGA) C-6 or CGA-6.3, as applicable. CGA C-6 requires the use of soap\nor other suitable solution to check for leaks. CGA C-6.3 is silent concerning how to\ndetect leaks. Based on the provisions in CGA C-6, a gas sniffer may be used in\naddition to coating the cylinder with soap or other solution, but not in place of these\nmethods.\nUnder the non-bulk packaging reuse requirements in 5 173.28, paragraph (b)(2)(i)\nrequires packagings subject to the leakproofness test in 8 178.604 to be retested\nwithout failure. Does this provision apply to cylinders?\nNo. Section 178.600 specifies that the testing requirements in Part 178, Subpart M\n($9 178.600 through 178.609) apply to the performance-oriented packagings identified\nin Part 178, Subpart L. Cylinder requirements are specified in Part 178, Subpart C\nand, therefore, are not subject to the leakproofness testing requirements in 5 178.604.\nDo the HMR require all DOT specification cylinders to be marked with a tare weight?\nNo. Unless otherwise specified in the HMR, DOT specification cylinders are not\nrequired to be marked with the tare weight.\nWhen should the cylinder requalifer verify the tare weight on a DOT specification\ncylinder?\n\n<<>>\n\nA4. Currently, the HMR require verification of the tare of DOT 4-series and 8-series\ncylinders, under certain conditions. See 5 180.209(c) and (i) respectively.\nI hope this information is helpful. If you have fiuther questions, please do not hesitate to\ncontact this office.\nHattie L. Mitchell\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials, Standards\n\n<<>>\n\n5 204 Cy)\nDrakeford, Carolyn cPHMSA>\n\" A -\" .... -- ,-.-.-...-.----- ... -. . -- . . .- , . .. . --Ii!s-t.!.: .!? %. . . - . .\nFrom: Mitchell, Hattie \nSent: Friday, December 08,2006 7:43 AM\nTo: fredn Q cyIinder.com\nCc: Posten, Ryan ; Hilts, Donald ; Drakeford, Carolyn \nSubject: RE: DOT Clarification Tare Wt-Leakproofness 12806.doc\nThanks, Fred. We will get a written response to you.\nHattie L. Mitchell\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials Safety\nPipeline and Hazardous Materials Safety\nAdministration\nU.S. Department of Transportation\n400 7th Street, S.W. Room 8421\nWashington, D.C. 20590-0001\nTel. (202) 366-8553\nFax (202) 366-3012\nWebsite: -gov/\nFrom: Fred A. Nachman [mailto:fredn@cylinder.com]\nSent: Thursday, December 07, 2006 11:28 AM\nTo: Mitchell, Hattie ; Hilts, Donald \nCc: Posten, Ryan \nSubject: DOT Clarification Tare ~ t - ~ e a k ~ r o o f n e ; ~ 12806.doc\nThunderbird Cylinder, Inc.\nDecember 8,2006\nMr. Don Hilts\nMs. Hattie Mitchell\nPHMSA, Department of Transportation\nRoom 8100 Div. 41.3\n400 7th Street S. W.\nWashington, D. C. 20509\nDear Don and Hattie,\nRequest for Clarification No. 1- Leah~roofness test:\nIs a leakproofness test required by 49CFR180.209(g) IYisual inqections of low pressure cylinders who's\nRecords must include. . .conditions checked (e.g., leakage.. .)?\n, Since it has been verbally interpreted by DOT to be required, how is it to be performed? DOT references.\nCGA C6-2001 4.2.4 Leaks which states.. .To checkfor leaks the glinder shall be cha~ged and car$ul& examzned.. .\nAny leakage is cause jor rgection. While it refers to coating with soap or other suitable solutions, is a\n\n<<>>\n\n, - - - ' ---- rage L 01 3\nhydrocarbon sniffer acceptable for leakage verification of propane or propylene cylinders if pressurized with\ntheir respective gases? If so, is it sufficient to pressurize the cylinder under 49CFR173,28(b)(2)(i) Retested\nwithout failure in accordance with 49CF'R 1 78.604 . . . ming. . . at least. . .7.0 psig. . . ? Or, is it necessary to\nleakproofness check the cylinder at service pressure or proof pressure? Until advised in writing by DOT,\nThunderbird shall continue its procedure of utilizing a'hydrocarbon sniffer at 7 psig to verify leakproofness\nof propane and propylene cylinders being requahfied by Vistlalin@ection.\nRequest for Clarification No. 2- Tare weight verification requirements:\nIn HM-220E, the final rule requires all UN cylinders manufactured after September 11,2006 to have the\nempg or tare weight in kilograms stamped on the cylinder. Does or should DOT require correct tare weights on\n(1) all cylinders being manufactured, (2) those cylinders already in service, (3) only those cylinders being\nfilled by weight regardless of their respective levels of corrosion, or (4) none?\nCGA C6-2001 4.2.1.1 Corrosion limits states (1) When a cylinder exhibits corrosion, the cylinder shall be condemned when\nthe tare weight is less than 90% ofthe original stamped tare we@. A cylinder shall be rejected when the tare weight is less\nthan 95% of the otiginal stamped t a n weight.\nCGA Technical Bulletin TB-15- 1997 ( R e a f h e d 2004) addresses cylinders that are charged with a liquefied\ncompressed gas by weigh that should be marked with an empg reference weight, i.e., tare weight to include the valve as\nthey are filled by weight. It goes on to direct that each time an operation that my change the tare weight ispefomed\non the cylinder such as a valve change, shot blasting, foohing replacement, etc., the tare weight shall be venfed and should be\nadjusted fthe weight dgersfi-om the marked tare weight more than 1%. The cylinder, then, should be marked with\nthe corrected tare weight prefixed with a “T\" and the original tare weight over stamped with \"----\" s SO as to\nremain visible. Please note that HM-220E does not reference the \"T\".\nUntil HM-220E, DOT has never required tare weights on newly manufactured cylinders. It is common to\nhave inaccurate tare weights on cylinders for any of the following reasons: (1) manufacturers stamped entire\nproduction lots with the same tare weight without weighing each cyhder, (2) cylinders have had their valves\nand footrings replaced with those of different weights, (3) cylinders have various amounts of paint or\ncorrosion, (4) cylinders may hold various amounts of liquefied hydrocarbons or water, etc..\nUntil advised in writing by DOT, Thunderbird will continue its procedure of tare weighting cylinders when\nrequested by its customers. It wdl also continue requiring its customers for whom it is filhng C02 to have\ntare weights. Thunderbird suggests, moreover, that DOT make a determination and clarify whether or not\nthere is a need for tare weights on all cylinders, since cylinders in one service are frequently converted to\nC02 or other liquefied services as they age and should have tare weights at the time of requalification and\nconversion to a liquefied service.\nThunderbird Cylinder holds a RIN No. whch authorizes it to requalify cylinders accordng to the CFR's and\nall referenced materials. It endeavors to train and cerufy its personnel to perform their requalification\nprocedures to be in compliance with those regulatory codes. We have no problem when a client requires us\nto exceed the regulatory requirements. We do, however, face a dilemma in doing the right thing, specifically,\nas stated above: (1) how and when do we perform leakproofness tests and (2) when should we verify and\nretare weight a cylinder?\nRespectfully,\n\n<<>>\n\nrage 3 or 3\nt Fred A. Nachman\nPresident\n(DOT Clalrification Tare W~Leakproofness 12806.doc)\n4209 E. University Drive Phoenix, AZ 8 85034-7315\nPHONE: 602.437.4600 FAX: 602.437.5052 EMAIL: fredn@cylinder.com","truncated":false,"body_characters":8161}