{"operation":"document","citation":"07-0170","title":"American Cap Co. L.L.C — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2007-10-02","effective_on":null,"summary":"07-0170 response to American Cap Co. L.L.C concerning 173.301.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0170.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0170.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0170","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2007/070170.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nMaterials Safety\nPipeline and Hazardous\nAdministration\nOCT 0 2 2007\nMr. Kerry Hricsina\nDirector of Engineering and\nRef. No.: 07-0170\nProduct Development\n15 Church Street\nAmerican Cap Co. L.L.C\nWheatland, PA 16161\nDear Mr. Hricsina:\nThis responds to your August 22, 2007 letter requesting clarification of the Hazardous\nvalve caps and guards. Your questions are paraphrased and answered below.\nMaterials Regulations (HMR; 49 CFR Parts 171-180) requirements applicable to cylinder\nmust have a valve assembly that is of sufficient strength or protected such that no leakage\nQ1. Section 173.301(h)(3) specifies that each cylinder manufactured after October 1, 2007\nrequirement to be marked \"DOT CFR 49\" to specify that they are in compliance with\n§ 173.301(h)?\ncomply with § 173.301(h), such a marking would not be considered a prohibited mark.\nAl: Yes. Although the HMR do not require such a mark to be placed on valve caps that\nguard to meet the testing requirements in the Compressed Gas Association publication, CGA\nQ2: Is there any requirement in the HMR for either a cylinder protection valve cap or valve\nV-9?\nproposed rulemaking published April 17, 2007 (72 FR 18446).\nA2: No. However, we proposed to incorporate CGA V-9 into the HMR in a notice of\nSincerely,\nour say\n/ - Hattie L. Mitchell\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n173.301 (h)\n070170\n\n<<<PAGE 2>>>\n\nSatterthwarte\nacci\n$173.301(h 3X1\nAmrican Cap Company, LLC\n15 Church Street, Wheatland, PA\nyonders\nPH: 724-981-4461: 800-448-0501 - Fax: 724 981-4495\n07 - 0170\nKerry Hricsina\nwww.americap-mfg.com\nDirector of Engineering and Product Development\nEmail: kih@americap-mfg.com\nWeb Page: www.americap-mfg.com\nD.O.T.\nPipeline and Hazmat Safety Administration\n8/22/07\n1200 New Jersey Ave. S.E.\nOffice of Hazardous Material Safety\nEast Bidg\n2^d Floor\nWashington, D.C. 20590\nAttn: Ed Massullo\nDirector Hazmat STDS (Phh-10)\nMr. Massullo,\nOur company would like to have an interpretation on the DOT CFR 49 regarding cylinder cap testing for\nalve protection. We have read section 173.301 para (h) regarding cylinder valve protection and sectio\n73.50 para (d) \"General packaging requirements for toxic materials packaged in cylinders\". The testin\nrequirements are clear in both sections on the purpose, height and result of the drop test.\nAs we are a manufacturer of metal caps and guards for valve protection, we would like to mark our caps so\nInterpretation request #1:\nspecific requirement in the CFR 49 that the caps need to be stamped or marked. Other governmental\nthat they may be identified as being tested in accordance with the DOT requirements. I did not see any\nspecifications, ISO 11117 and EN 962 require testing as well, but when tested to these standards the caps\ntesting as prescribed in the DOT CFR 49, are we permitted to stamp our manufactured cap with\nQuestion 1: Once we have manufactured and tested our caps and they have passed the drop\n\"DOT CFR 49\", showing that this design has met the DOT requirements? If not, is there any other\nwording that would be acceptable to achieve the same purpose?\nInterpretation request #2:\nThe Compressed Gas Association pamphlet V-9 has information on valve protection, and for cap and valve\nguard testing. The CGA pamphlet is referred to in several sections of the CFR 49, however, all of the\nsections refer to valve information only and not to any specific testing that is required for valve protectior\ncaps and guards.\nvalve guard has to meet the testing requirements set forth in the CGA pamphlet V-9?\nQuestion 2: \"Is there any DOT requirement that specifies that a cylinder valve protection cap or\nRegards,\nesticsina\nKerry Hricsina\nDirector of Engineering and Product Development\nAmerican Cap Co. Ilc\nA Manufacturing Company - Deep Drawn Products, Stampings, Custom Machining, Cylinders, Fabrications & Powder Coating","truncated":false,"body_characters":3972}