{"operation":"document","citation":"09-0236","title":"Department of State INL/A — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2011-03-28","effective_on":null,"summary":"09-0236 response to Department of State INL/A concerning 177.840, 180.205, 180.209.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0236.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0236.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0236","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2009/090236.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation Pipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Ave. SE\nWashington. D.C. 20590\nMAR 2 8 20\"\nMr. James A. Sherman\nMaintenance Production\nControl Specialist\nDepartment of State INL/ A\n1038 S. Patrick Dr. HGR 985\nPatrick AFB, FL 32955\nRef. No. 09-0236\nDear Mr. Sherman:\nThis responds to your e-mail requesting clarification of the Hazardous Materials Regulations\n(HMR; 49 CFR Parts 171-180) applicable to the requalification requirements for DOT\nspecification 3A and 3AA cylinders as specified in § 180.209. We apologize for the delay in\nresponding and any inconvenience it may have caused. Your questions are paraphrased and\nanswered as follows:\n01. Under § 180.209(b), if a cylinder is removed from a cluster, bank, group, rack, or vehicle\nfor inspection and is not returned to that particular form of exclusive service, what must\noccur?\nA1. As specified in § 180.209(b)(3), the cylinder must be requalified five years from the\nmarked test date or prior to the first filling with a compressed gas jf the required five-year\nrequalification period has passed. Additionally, the \"star\" indicating exclusive service\nfollowing the most recent test date must be obliterated.\n02. If a cylinder is no longer in service as part of a cluster, bank, group, rack or vehicle and its\ninspection (requalification) becomes due, how long may the cylinder be used before it\nmust be inspected (requalified)?\nA2. As specified in § 180.205(c), no cylinder may be filled with a hazardous material and\noffered for transportation in commerce unless that cylinder has been successfully\nrequalified and marked in accordance with the HMR. A cylinder filled before the\nrequalification becomes due may remain in service until it is emptied. A cylinder with a\nspecified service life may not be refilled and offered for transportation after its authorized\nservice life has expired. This requirement is applicable regardless of whether the cylinder\nis part of a cluster, bank, group, rack, vehicle, or otherwise.\n\n<<<PAGE 2>>>\n\nQ3. Please define \"cluster, bank, group, rack or vehicle\" as it is used in the HMR.\nA3. The term \"cluster, bank, group, rack or vehicle\" is not currently defined in the HMR. As\nused in § 180.209(b), it represents a generalization of a type of service where one or more\ncylinders are secured and transported in or on a vehicle in a cluster, bank, group or rack\nspecifically designed for such transportation. See § 177.840(a).\nI trust this satisfies your inquiry. Please contact us if we can be of further assistance.\nSincerely,\nr~/}c9d~-\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\nPage 1 of2\nDrakeford, Carolyn (PHMSA)\nFrom: Gorsky, Susan (PHIVISA) vens\nSent: Tuesday. October 20. 2009 7:29 AM\nTo: Drakeford. Carolyn (PHMSA) § J gO.lort\nCc: Mitchell, Hattie (PHMSA); Mazzullo, Ed (PHMSA)\nSubject: FW: Clarification of 49 CFR\n09 -02.>3('\nFrom: PHMSA_Guidance_Complaints (PHMSA)\nSent: Tuesday, October 20,20096:15 AM\nTo: Mitchell, Hattie (PHMSA)\nCc= Mazzullo, Ed (PHMSA); Gorsky, Susan (PHMSA)\nSubject: FW: Clarificatio~ of 49 CFR\nWould you please respond to this request?\n~llnder..s\nFrom: Sherman, James A. [mailto:shermanj@ginl.state.gov]\nSent: Monday, October 19, 20094:05 PM\nTo: PHMSA_Guidance_Complaints (PHMSA)\nSubject: Clarification of 49 CFR\nTo whom it may concern;\nI would like some clarification regarding 49 CFR 180,207\ns service pressure, except noncorrosive service (see\n9(0 )\n\"(b) DOT 3A or 3AA cylinders. (1) A cylinder conforming to specification DOT 3A or 3AA with a water capacity of\n56.7 kg (125 Ib) or less that is removed from any cluster. bank, group, rack, or vehicle each time it is filled, may be\nrequalified every ten years instead of every five years, provided the cylinder conforms to all of the following\nconditions .... ,\n.'(t) Poisonous materials. A cylinder conforming to specification DOT 3A 3AA, 4BA or 4BW having a service\npressure of 300 psig or less and used exclusively for methyl bromide, liquid; mixtures of methyl bromide and\nethylene dibromide, liquid; mixtures of methyl bromide and chlorpicrin, liquid; mixtures of methyl bromide and\npetroleum solvents, liquid: or methyl bromide and nonflammable, nonliquefied compressed mixtures, liquid;\ncommercially free of corroding components, and protected externally by a suitable corrosion resistant coating\n(such as galvanizing or painting) and internally by a suitable corrosion resistant lining (such as galvanizing) may\nbe tested every 10 years instead ofevery five YFlars, provided a visual internal and external examination ofthe\ncylinder is conducted every five years in accordance with CGA Pamphlet C-6, The cylinder must be examined at\neach filling. and rejected if a dent, corroded area, leak or other condition indicates possible weakness.\n(h) Cylinders containing anhydrous ammonia, A cylinder conforming to specification DOT 3A480X, or 4AA480\nused exclusively for anhydrous ammonia, comlTiercially free from corroding components, and protected externally\nby a suitable corrosion-resistant coating (such as paint) may be requalified every 10 years instead ofevery five\nyears ... \"\n(j) Cylinder used as a fire extinguisher. Only a DOT specification cylinder used as a fire extinguisher and meeting\nSpecial Provision 18 in §172.102(c)(1) of this subchapter may be requalified in accordance with this paragraph (j).\nMy questions are as follows:\n10/2012009\n\n<<<PAGE 4>>>\n\nPage 2 of2\nIf a cylinder that is marked with a 5 point star to indicate 10 year inspection period is removed from the cluster, bank,\ngroup, rack, or vehicle for inspection but it is NOT reinstalled in the cluster, bank, group, rack, or vehicle. Then what happens?\nThe way I interpret the CFR is that the star is removed I obliterated and the inspection period reverts to a 5 year time period.\nAlso, if the cylinder is now a single, not installed in a cluster, bank, group, rack, or vehicle, how long can the inspection be\noverdue? I.E. the inspection was due in May OB,and the cylinder is still half full as of Oct 09, Can it stili be used? When should\nit exchanged?\nI would also like the PHMSA definitions of: cluster, bank, group, rack, or vehicle.\nThank you for your help and support.\nSincerely, Jim\n)c!Vl.A..es A SheyVl.A..C!1I\\.\nMaintenance Production Control Specialist\nDept of State INUA\n1038 S. Patrick Dr. HGR 985\nPatrick AFB, FL. 32955\n321-783-9821 x33301 - Office\n321-514-5589 - Cell\n321-323-5948 - Fax\n10/20/2009","truncated":false,"body_characters":6522}