{"operation":"document","citation":"11-0117","title":"Worthington Cylinders — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2011-06-13","effective_on":null,"summary":"11-0117 response to Worthington Cylinders concerning 173.301, 173.304a, 178.65.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0117.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0117.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0117","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2011/110117.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department 1200 New Jersey Avenue SE\nof Transportation Washington. DC 20590\nPipeline and Hazardous\nMaterials Safety\nAdministration\nJUN 1 3 2011\nMr. Steve Gentry\nWorthington Cylinders\n1085 Dearborn Drive\nColumbia, Ohio 43085\nReference No.: 11-0117\nDear Mr. Gentry:\nThis responds to your May 12, 2011 letter requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to the internal capacity\nlimits and pressure relief devices (PRD) required for Specification Department of\nTransportation (DOT) 39 cylinders intended to contain a Division 2.1 liquefied\ncompressed gas.\nSpecifically, in your letter, you state that you plan to ship a Division 2.1 liquefied\ncompressed gas, HFO-1234yf, that you have classified as \"UN3161, Liquefied gas,\nflammable, n.o.s. (2,3,3,3-Tetrafluoroprop-l-ene)\" in a specification DOT 39 cylinder. We\nhave paraphrased your questions and answered them below .\n. Ql: Can HFO-1234yf be packaged in specification DOT 39 cylinders of any volume\ncapacity as long as the service pressure and test pressure of the cylinder are in\naccordance with the applicable specifications?\nAI: HFO-1234yf may be packaged in specification DOT 39 cylinders; however, there\nare limits on the volume capacity of these cylinders. As previously stated in a letter\nof interpretation, Ref. No. 11-0052 (see attached letter), the filling requirements for\nliquefied compressed gases in DOT specification cylinders are based on the type of\ngas contained in the cylinder and are found in § 173.304a of the HMR. In addition,\n§ 173.304a(a)(2) provides a table listing various types of liquefied gases and their\ncorresponding maximum permitted filling densities. Based on your incoming\nletter, the material you wish to ship is not specifically listed in the table in this\nsection. For gases not specifically listed in the table in § 173.304a(a)(2), the filling\ndensity can be determined using the formula provided in \"Note I\" to that Table.\nTherefore, the filling density for any cylinder containing your material, including a\nspecification DOT 39 cylinder, can be determined by calculating the percent ratio\nof the weight of the gas in the packaging to the weight of the water the container\nwill hold at 16°C (60 OF).\n\n<<<PAGE 2>>>\n\nPlease note that, in accordance with § 178.65, cylinders built to meet a DOT 39\nspecification may not have a maximum water capacity that exceeds 55 pounds\n(1,526 cubic inches) for cylinders with service pressure of 500 p.s.i.g. or less, and\n10 pounds (277 cubic inches) for cylinders with service pressure in excess of 500\np.s.i.g.\n02: If HFO-1234yf can be packaged in specification DOT 39 cylinders, what PRD\nshould be used?\nA2: As stated in AI, HFO-1234yf may be packaged in specification DOT 39 cylinders\nprovided certain filling requirements are met. In addition, in accordance with\n§ 173.301(f)(4), a PRD is required on a specification DOT 39 cylinder regardless of\ncylinder size or filled pressure. A specification DOT 39 cylinder used for liquefied\nDivision 2.1 materials must be equipped with a metal PRD. Fusible PRDs are not\nauthorized on specification DOT 39 cylinders containing liquefied gas.\nFurthermore, in accordance with § 173.301(f)(1), a specification DOT 39 cylinder\nfilled with HFO-1234yf would need to comply with the requirements specified in\nCGA Publication S-l.l. As you stated in your incoming letter, CGA Publication S1.1\ndoes not specifically identify your commodity. CGA Publication S-l.l does,\nhowever, mandate a CG-7 PRD for other similar liquefied compressed gases and it\nis the opinion of this Office that cylinders containing HFO-1234yf must be fitted\nwith a CG-7 PRD.\nI hope this satisfies your inquiry. Please contact us if we can be of further assistance.\nSincerely,\nr~~~06\"k---\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\n~ned~d-\n9 113· 304Q.,\n~ (78. b5\nCMlI'fl ders • ~ ~\n11-'-6111 ..\nWORTHINGTON\nCYLINDERS\nA Worthington Industries Company\nMay 12,2011\nOffice ofHazardous Materials Standards\nPipeline and Hazardous Materials Safety Administration\nPHH-I0\nU.S. Department ofTransportation\nEast Building\n1200 New Jersey Avenue, SE\nWashington, DC 20590-0001\nDear Madam or Sir:\nIn accordance with 49 CFR 105.20, Worthington Cylinder Corporation is requesting an interpretation of\nthe requirements for packaging and shipping HFO-1234yf(a liquefied flammable material, red diamond,\n2.1 material) in Specification 39 (49 CFR 178.65) cylinders as defined in 49 CFR 173 J04a (see\nAttachment 1 for MSDS). I have reviewed the interpretations on the PHMSA website and could not\nlocate anything that directly answers my questions.\nName: Steven T. Gentry\nPosition: Regulatory Affairs Manager\nCompany: Worthington Cylinder Corporation\nAddress: 1085 Dearborn Drive\nColumbus, Ohio 43085\nTelephone: 614-438-3057\nFax: 614-840-4830\nE-Mail: steve.gentry@worthingtonindustries.com\nQuestion #1: Can HFO-1234yf be packaged in Specification 39 cylinders of any volume capacity as\nlong as the service pressure and test pressure of the cylinder are in accordance with the applicable\nSpecifications?\nWorthington Interpretation: In 2001 DOT started the consolidation and rewriting of 49 CFR. This\nwas when 173J04 was renumbered to 173J04 and 173J04a. A Note was removed from the Table of\n173.304 that stated the following ... Note 9. When used for the shipment of flammable gases, the\ninternal volume of a Specification 39 cylinder must not exceed 75 cubic inches (see Attachments 2\nand 3 of 49 CFR from 2001 and 2002).\n49 CFR 173J04a is titled \"Charging ofcylinders with liquefied compressed gas\". Therefore, removal of\nNote 9 from the Table and no further prohibitions in 173J04a would permit HFO-1234yfto be packaged\nand transported in Specification 39 cylinders ofany capacity.\nDoes DOT confirm the interpretation of Worthington?\n\n<<<PAGE 4>>>\n\nQuestion #2: IfDOT confirms that HFO-1234yf can be packaged in Specification 39 cylinders as\ndefined in Question #1, what pressure relief device should be used?\nWorthington Interpretation: The general cylinder requirements noted in 49 CFR 178.35 defaults to\n49 CFR 173.301(t) for the requirements of the pressure relief device. Basically, 173.301(t) tells the user\nto follow CGA Publication S-I.1 and that the pressure relief device shall be capable of preventing rupture\nofthe normally filled cylinder when subjected to a fire test conducted in accordance with CGA\nPublication C-14. Therefore, the device selection and set pressure ofthe pressure relief device on a\nSpecification 39 cylinder charged with HFO-1234yf would need to comply with the requirements ofCGA\nPublication S-I.1.\nTable 3 ofCGA Publication S-1.1 doesn't not specifically identify the commodity HFO-1234yf. Since\nCGA Publication S-I.1 mandates a CG-7 for other liquefied flammable gases (i.e. butane, propane,\npropylene), Worthington would conclude that the CG-7 device would be the device selected by DOT for\nthe commodity HFO·123 4 yf.\nDoes DOT confirm the interpretation of Worthington?\nThank you for your assistance in this matter. If! can be of any further assistance, please contact me at\n614-438-3057 or e-mail atsteve.gentry@worthingtonindustries.com.\nRespectfully Submitted:\nSt~en~kdr\nRegulatory Affairs Manager\nWorthington Cylinder Corporation\nAttachments\n2","truncated":false,"body_characters":7347}