Guidanceguidance
10-0100
Wilhelmsen Ships Service — Hazardous Materials Safety Interpretation
Current as of source date Government source
RegulusPipeline researchRegulusPipeline research10-0100
Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave. SE Washington. D.C. 20590 JUN 07 2010 Mr. Dave Finlay Regional HSSE Manager - Americas Wilhelmsen Ships Service 9400 New Century Drive Pasadena, TX 77507 Ref. No.: 10-0100 Dear Mr. Finlay: This responds to your April 19, 2010 email regarding the applicability ofthe Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to a particular CGA publication. Specifically, you ask whether the HMR requires testing ofcylinder valves to be in accordance with the Compressed Gas Association publication, CGA V-9, "Standard for Compressed Gas Cylinder Valves." The answer is no. Currently, § 171.7(a)(2) ofthe HMR do not incorporate by reference the CGA V-9 publication. However, the outside of cylinders are required by § 173.301(a)(2) to be visually inspected prior to each filling. Any cylinder having a defective valve or other detrimental damage may not be filled and offered for transportation. 1 trust this satisfies your inquiry. Please contact us if we can be of further assistance. Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#
Page 2Drakeford, Carolyn (PHMSA) From: Finlay, David [David.Finlay@wilhelmsen.com] Sent: Tuesday, April 20, 2010 11 :38 AM To: INFOCNTR (PHMSA) Subject: FW: C02 valve reconditioning Attachments: CGA V9 Valves. pdf; WSE-50-03-018_Technical bulletin.doc Sir As discussed. We have always used CGA P-15 2.4.3 as our guide which states valve "outlets should be in good condition with clean sharp threads and an undamaged seating surface. If not the valve should be replaced". Although the damage to the valve outlet is minimal, our fear is that we could have liability if we follow the suggestion below. We are also asked to seek USDOT approval for this which is why your opinion is so important to us. My thanks for your quick response it is much appreciated. Best regards Dave Finlay Regional HSSE Manager - Americas Wilhelmsen Ships Service Directtel: 281 8672012 Direct fax: 281 8672812 Mobile: 832 603 1694 E-mail: david.finlay@wilhelmsen.com www.wilhelmsen.com From: Przeradzki, Grzegorz Sent: Friday, April 16, 2010 8:21 PM To: Finlay, David Cc: Hestmann, Mats-Petter; Dalmar, Aage; Scheepers, Eddy; Ashton, Alan Subject: C02 valve reconditioning Hello David, See attached Technical Bulletin - updated and applicable standard, that allows us to perform thread cleaning. Please confirm you can present this to DOT and get this approved. Thanks «CGA V9 Valves.pdf» «WSE-50-03-018_Technical bulletin.doc» Best regards, Grzegorz Przeradzki QA Manager Wilhelmsen Ships Equipment 1#
Page 3Szczecin, Poland I Direct: +4891 4666 171 IMobile: +4869561 9628 grzegorz. przeradzki@wilhelmsen.com IWWIN. wilhelmsen.com/shipsequipment Wilhelmsen Ships Equipment offers safety, insulation and environmental solutions for newbuilds, retrofits and offshore Please consider the environment before printing this email 2#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.