{"operation":"document","citation":"12-0005","title":"Global Passive Safety System Ltd. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2012-05-01","effective_on":null,"summary":"12-0005 response to Global Passive Safety System Ltd. concerning 173.315.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0005.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0005.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0005","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2012/120005.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nMAY 0 1 2012\nMr. Andy Abrams\nGlobal Passive Safety System Ltd.\n761 West Sproul Road, Suite 208\nSpringfield, PA 19064\nRef. No.: 12-0005\nDear Mr. Abrams:\nThis responds to your January 4, 2012letter requesting clarification of the Hazardous Materials\nRegulations (HMR; 49 CFR Parts 171-180) applicable to hose assemblies. Specifically, you\ninquire whether a metallic hose assembly made with a corrugated tube of 316SS and an outer\nbraid of 304SS with a working pressure of 400+ p.s.i. and a burst of 2000 can be used in\nliquefied petroleum gas (LPG) and anhydrous ammonia (NH3) cargo tanker service.\nIn accordance with § 173.315(n)(2), for a cargo tank motor vehicle in other than metered\ndelivery service, there are no specific HMR provisions dictating the material from which a\ndelivery hose must be comprised. However, Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) does specify in§ 178.337-9 the requirements (burst pressures,\nweights, damage protection, free from leaks, etc.) for piping, valves, hoses, and fittings on MC\n331 cargo tanks intended to contain compressed gases. Further, the hose identification,\ninspection, and testing requirements for a delivery hose assembly on a cargo tankused to\ntransport liquefied compressed gases are specified in § 180.416 of the HMR, including the\nrejection criteria in paragraph (g). Additionally, it is the responsibility of the person offering a\nhazardous material for transportation to ensure that the packagings and its appurtenances\n(piping, valves, hoses, fittings, etc.) are compatible with its lading.\nPlease be aware that these hoses may be subject to the Occupation Safety and Health\nAdministration (OSHA) Standards in 29 CFR, and specific questions about requirements for\nequipment such as a hose should be directed to OSHA and any applicable state regulatory\nauthorities. However, a review of 29 CFR § 1910.111(b )(8) states that hoses used in ammonia\nservice shall conform to the joint Agricultural Ammonia Institute - Rubber Manufacturers\nAssociation (RMA) Specifications for Anhydrous Ammonia Hose. Subsequently, a cursory\n\n<<<PAGE 2>>>\n\nanalysis of the documents published by RMA make no mention of a metallic hose assembly as\nis described above. For further assistance, you may contact Jeffrey J. Wanko, Safety Engineer\nfor OSHA Directorate of Enforcement Programs, by phone at (202) 746-2667 or email at\nJWanko@dol.gov.\nI hope this satisfies your inquiry. Please contact us if we can be of further assistance.\nSincerely,\n--7.'M71/YU :v?X)z-~\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n2\n\n<<<PAGE 3>>>\n\nJanuary 4 2012\nDirector- Office of Hazardous Materials Standards\nPipeline and Hazardous Materials Administration\nUS Department of Transportation\n1200 New Jersey Avenue, SE Building 2nd Floor\nWashington, DC 20590\nLetter of Interpretation\nDear Sir/Madam\nWe are writing in connection with the regulations set forth below to inguire specifically if a\nmetallic hose assembly made with a corrugated tube of 316SS and an outer braid of 304 SS\nwith a working pressure of 400+PSI and a burst of 2000 can be used in LPG and NH3\nCargo Tanker service.\nA. GPSS USA Regulatory Position: Under 49 CFR 315, the following Passive Device\nRequirements are promulgated.\n(2) Cargo tank motor vehicles in other than metered delivery service. A cargo\ntank motor vehicle in other than metered\ndelivery service must have a means to automatically shut off the flow of product\nwithout the need for\nhuman intervention within 20 seconds of an unintentional release caused by a\ncomplete separation of a liquid delivery\nhose (passive shut-down capability).\n(i) Designed flow of product through a bypass in the valve is acceptable when\nauthorized by this subchapter.\n(ii) The design for the means to automatically shut off product flow must be\ncertified by a Design Certifying Engineer.\nThe certification must consider any specifications of the original component\nmanufacturer and must explain\nhow the passive means to shut off the flow of product operates. It must also\noutline the parameters (e.g., temperature,\npressure, types of product) within which the passive means to shut off the flow of\nproduct is designed to operate.\nAll components of the discharge system that are integral to the design must be\nincluded in the certification. A\ncopy of the design certification must be provided to the owner of the cargo tank\nmotor vehicle on which the equipment\nwill be installed.\n(iii) Installation must be performed under the supervision of a Registered\nInspector unless the equipment is installed\n1\n\n<<<PAGE 4>>>\n\nand removed as part of regular operation (e.g., a hose). The Registered Inspector\nmust certify that the equipment\nis installed and tested, if it is possible to do so without damaging the equipment,\nin accordance with the Design\nCertifying Engineer's certification. The Registered Inspector must provide the\ncertification to the owner\nof the cargo tank motor vehicle.\n(3) Cargo tank motor vehicles in metered delivery service. When required by the\ntable in paragraph (n)(l) of this section,\na cargo tank motor vehicle must have an off-truck remote means to close the\ninternal self-closing stop\nvalve and shut off all motive and auxiliary power equipment upon activation by a\nqualified person attending the unloading\nof the cargo tank motor vehicle (off-truck remote shut -off).\nIt is our position that the metallic hoses we are providing are being used on DOT application and\nOSHA jurisdictions. As such, they are subject to the standards set forth under 49 CFR 173.315\nwhich does not specify hose material or out of service standards. It is our position that when we\nprovide hoses in OSHA jurisdictional service, we comply with the hose performance standards\nand even comply with 1910.111 (b )(8)(iv) independent of additional valves since our system has\ninternally integrated shut-off valves. We recognize that you can not opine over OSHA standards\nbut there is some overlap.\nB. Technical Standards- Why is a metallic hose equal to or greater than a rubber hose?\nThere are many different types of hose available on the market, including metal, rubber,\ncomposite, PTFE, and fabric. There are eight factors that make a metal hose a superior\nchoice to rubber hose:\n1. TEMPERATURE EXTREMES\nIf either the temperature of the media going through the hose or the surrounding\natmospheric temperature is very cold or hot, metal may be the only material that\ncan withstand such temperature extremes.\n2. CHEMICAL COMPATIBILITY- NO ERROR IF USED IN EITHER LPG OR\nNH3\nMetal hose can handle a wider variety of chemicals than most other hose types. If the\nhose will be exposed to aggressive chemicals (either internally or\nexternally), metal hose should be RECOMMENDED. Case in point: In the article below\na RUBBER LPG hose was erroneously used in NH3 service because the layline on the\nhose was worn away.\n2\n\n<<<PAGE 5>>>\n\nPosted on Thu. Jul. 16. 2009\nAmmonia cloud kills woman, injures 7\nLeak at chemical plant near SWansea prompts evacuation\nD<lnna Petrey got a call just after 8 a.m. Wednesday\nfrom her son. telling her the ohernical plant across\nthe street had sprung a leal<.\n'I grabbed my 7-year-old grandoan. Hunter, and our\ndog, Oreo. and put them in the car,\" she said.\nAt the end of the driveway, she glanced left and was\nstunned.\n•n looked fike a huge colton boD. It was so thick. you\ncouldn1 see anything through il' said Petrey, 50,\nwho liVes acros~ from Tanner Industries, just south of\nSwansea in Lexington County.\nPetrey didn't kntrw il hut a motorist alreadY had\ndriVen into that doud - a vast poisonous mist of a\ndeadly ohern~cal called anhydrous ammonia, typically\nused in cleaning products- and hadn't made I! oul\nJacqueline Patrice Gmynrd, 38. of Wagener couldn't\nget her car out of the fog and tried to flee on fool\naccording to the Lexington County Sheriff's\nDepartment Her bodY tater was found next to her\ncar.\nWednesday's leak also sent seven people to IJren\nhospitals and prompted the evacuation of numeroun\nnearby homes. By late afternoon, roughly 20 homes\nwere being tested lor contamination, though\nauthorities found none.\nHad a metallic hose been used the incident would have been avoided and no injury would\nhave occurred.\n3. PERMEATION CONCERNS\nNonmetal hose is susceptible to gas permeation through the hose wall and into the\natmosphere. Metal hose, on the other hand, does not allow\npermeation. If containing the gases inside the hose is important, metal hose may be required.\n4. POTENTIAL FOR CATASTROPHIC FAILURE\nWhen a metal hose fails, it usually develops small holes or cracks. Other hose types tend to\ndevelop larger cracks or come apart completely. If a sudden hose\nfailure is potentially catastrophic, a metal hose may help minimize the effects of a failure by\nleaking product at a slower rate.\n5. FIRE SAFETY -EXCESSIVE HEAT\nOther hose types will melt when exposed to fire, while metal hose maintains its integrity up\nto 1300 degree F.\n6. FRIGID/CRYOGENIC CONDITIONS- EXCESSIVE COLD\nLPG and NH3 hoses frequently are used in below zero conditions which can cause or\ncontribute to hose tube failures. Metallic hoses are designed with a substantially wider\ntemperature range.\n7. ACHIEVING FULL VACUUM\nUnder full vacuum, metal hose maintains its shape while other hose types may collapse.\n3\n\n<<<PAGE 6>>>\n\n8. FLEXIBILITY IN FITTING CONFIGURATION DUE TO WELDING\nMetal hoses are welded which avoids the risk of crimping and crimp failures ..\nC. Other Standards- OSHA speaks in a very limited manner to this issues.\n1. In 1926.153(h)(7) - Hose shall be designed for a working pressure of at least 250 p.s.i.g.\nDesign, construction, and performance of hose, and hose connections shall have their suitability\ndetermined by listing by a nationally recognized testing agency. The hose length shall be as short\nas practicable. Hoses shall be long enough to permit compliance with spacing provisions of\nparagraphs (h)( 1) through ( 13) of this section, without kinking or straining, or causing hose to be\nso close to a burner as to be damaged by heat.\n2. OSHA 29 1910.1ll(b)(8)(i)\n• Hose used in ammonia service shall conform to the joint Agricultural Ammonia\nInstitute - Rubber Manufacturers Association Specifications for Anhydrous Ammonia\nHose.\n• 1910.111(b)(8)(ii)\n• Hose subject to container pressure shall be designed for a minimum working pressure\nof350 p.s.i.g. and a minimum burst pressure of 1,750 p.s.i.g. Hose assemblies, when\nmade up, shall be capable of withstanding a test pressure of 500 p.s.i.g.\n• 1910.111(b)(8)(iii)\n• Hose and hose connections located on the low-pressure side of flow control of\npressure-reducing valves shall be designed for a bursting pressure of not less than 5\ntimes the pressure setting of the safety relief devices protecting that portion of the\nsystem but not less than 125 p.s.i.g. All connections shall be so designed and\nconstructed that there will be no leakage when connected.\n• 1910.111(b)(8)(iv)\n• Where hose is to be used for transferring liquid from one container to another, \"wet\"\nhose is recommended. Such hose shall be equipped with approved shutoff valves at\nthe discharge end. Provision shall be made to prevent excessive pressure in the hose.\n3. State Regulations\nThe use of Rubber hoses is also being phased out of many state regulations. For\nexample in Texas, Texas Administrative Code, TITLE 16 ECONOMIC\nREGULATION PART 1 RAILROAD COMMISSION OF TEXAS, CHAPTER 9\nLP-GAS SAFETY RULES, SUBCHAPTER B LP-GAS INSTALLATIONS,\nCONTAINERS, APPURTENANCES, AND EQUIPMENT REQUIREMENTS\nRULE §9.143 Bulkhead, Internal Valve, API 607 Ball Valve, and ESV Protection\nfor Stationary LP-Gas Installations with Individual or Aggregate Water Capacities\nof 4,001 Gallons or More provides:\ng) In addition to NFPA 58 §§5.9.6 and 6.9.6.1, by February 1, 2003, rubber flexible\nconnectors which are 3/4-inch or larger in size installed in liquid or vapor piping at an\nexisting liquid transfer operation shall have been replaced with a stainless steel flexible\nconnector. Stainless steel flexible connectors shall be 60 inches in length or less, and shall\n4\n\n<<<PAGE 7>>>\n\n4. comply with all applicable LP-Gas Safety Rules. Flexible connectors installed at a new\ninstallation after February 1, 2001, shall be stainless steel.\nNFPA 58 Section 2.4.6 provides the working/operational pressures ofhoses but\nmakes no mention except to provide that the must be corrosion resistant such as\nstainless steel.\nTherefore, we are of the opinion that the metallic hose that we are offering is compliant with the\nDOT, OSHA, NFPA and Federal/State regulatory standards. We welcome any comment or\nopinion on our conclusion.\nRegards~\nGlobal Passive Safety Systems Ltd.\n761 West Sproul Road, Suite 208\nSpringfield, P A 19064\nToll Free 855-GPSS-USA (855-477-7872)\nM-267-307-0949\nF- (267) 937-2081\nE-Mail: AndyAbrams@GPSafetySystems.Com\nWWW.GPSAFETYSYSTEMS.COM\nGP~\n5","truncated":false,"body_characters":13065}