{"operation":"document","citation":"12-0091","title":"Chief Daniel H. Graves — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2012-06-25","effective_on":null,"summary":"12-0091 response to Chief Daniel H. Graves concerning 180.205.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0091.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0091.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0091","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2012/120091.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\nJUN 2 5 2012\nDaniel H. Graves\nFire Chief\nSt. Pete Beach Fire Department\n7301 Gulf Boulevard\nSt. Pete Beach, FL 33706\nRef. No.: 12-0091\nDear Chief Graves:\nThis responds to your March 14, 2012 letter regarding the Hazardous Materials Regulations\n(HMR; 49 CFR Parts 171-180) as they pet1ain to carbon fiber wrapped cylinders marked\nwith Department of Transportation Exemption .(DOT -E) l 0915 (renamed special permit\n(SP) I 0915). Cylinders manufactured under this special pennit are limited to a fifteen (15)\nyear service life.\nComposite cylinders older than their authorized service life may have reduced strength\nwithout any visual indication of damage. At this time, there is no effective non-destructive\nmethod of detecting the degree of strength loss for a composite cylinder. We are aware of,\nand concerned about, the financial burden associated with limiting the service life of\ncomposite cylinders, but PHMSA must weigh this burden against the safety risk of a\ncylinder failure to firefighters and other users.\nA service life extension approval may only be accommodated by modification ofthe special\npermit authorizing cylinder construction. Accordingly, no service life extension is\nauthorized for cylinders manufactured in accordance with DOT -SP 10915. Therefore, once\na cylinder marked DOT-E 10915 or DOT-SP 10915 has reached the end of its authorized\nservice life, it must be condemned in accordance with§ 180.205.\nI hope this information is helpful. If you have further questions, please contact this office.\nSincerely,\nRobert Benedict\nChief, Standards Development\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nMarch 14, 2012 FIRE DEPARTMENT\n7301 Gulf Boulevard, St. Pete Beach, Florida 33706\n727-363-9206 • Fax: 727-360-6744\nT. Glen Foster\nChief, Regulatory Review and Reinvention\nU.S. Department of Transportation\nEast Building, Second Floor\nMail Stop: E21-317\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nDear Chief Foster:\nThe City of St. Pete Beach Fire Department purchased several MSA Stealth Self Contained Breathing\nApparatus (SCBA) cylinders, which are carbon-wrapped cylinders that received all approvals in March of\n1997. The cylinders were certified with a fifteen year life. However, during the certification process\n(according to the attached letter from MSA) \" ... the DOT wrote in their standard that in twelve (12)\nyears the DOT would revisit the total service life issued and possibly increase the carbon-wrapped\ncylinders to another fifteen (15) years\".\nBecause the City purchased cylinders manufactured in late 1997 and early 1998, they will come to the end\nof their certified life in the very near future. The City of St. Pete Beach like most US cities is suffering\nfrom sigriificant·revenue shortfalls and the $55,000 needed to replace the bottles will be a hardship to the\ndepartment and the citizens of St. Pete Beach.\nWith the aforementioned in mind I have a couple questions:\n1. Has the DOT made a determination on extending the life of the carbon-wrapped cylinders? If so,\nplease forward your determination.\n2. 3. If not, do you intend to do so?\nWhat is the time frame for a decision?\nAn expedient response to this request is important as many of our cylinders will expire during this\ncalendar year. You may contact me at 727-363-9206, at the address above or via email at\nfirechief@stpetebeach.org. Thank you for your consideration.\nSincerely, '\nDaniel H. Graves,\nFire Chief\n\n<<<PAGE 3>>>\n\nMine Safety Appliances Contpany\nSafety Products Division\nPO Box 426, Pittsburgh, PA 15230\nPhone: 1-888-421-8324 :Fa.x: (412) 967-3059\nMay 18, 2000\nDear Valued Customer,\nRE: Life of Composite and Carbon-Wrapped Cylinders\nThe Fiberglass-Wrapped and Kevlar-Wrapped Cylinders only have a 15-\nyear life per the Department of Transportation (DOT}. These cylinders need to\nbe hydrotested every 3-years. If you have cylinders that will be expiring, you\ncan purchase the cylinder kit less valve and reuse the valve that you have.\nTl·1e MSA Stealth cylinders, which are carbon-wrapped cylinders. received\nall approvals in March of 1997. They currently have a 15-year life but the DOT\nwrote in their standards that in 12 years they would revisit the total service life\nissue and possibly increase the carbon-wrapped cylinders to another 15 years.\nThe carbon cylinders previously had a 3-year hydrotest and they were recently\nextended to 5 years. Please see the enclosed letter that addresses the new\nhydrctesting requirements of the carbon cylinders\nT!1e Associate Administrator for Hazardous Materials (AAHMS) is the\norganization that would review the approval of the service life extension to a\npossible total of 30 years. This statement is found in the DOT-CFFC Basic\nR.equirements (second revision).\nFor additional information on the DOT Regulations for all cylinders, a web\nsite has been established by DOT. See http://HAZMAT.DOT.GOV/EXSYS.HTM.\nscroll to available Documents and Files, then to the exemptions for the cylinder\nin question.\nSteel (3AA) and Aluminum (3AL) cylinders still have a 5-year hydrotest\nand t.mlimited shelf life as long as it passes the hydrotest and visual inspections.\nPlease call Customer Service at 1·800~672·2222 or our Technic.al Group\nLine at 1-888-421-8324 if you !1ave any questions. If you are a Fire Department\nor Fire Service Distributor and have questions you can call toll free ~t 1~8T1-672-\n3473. Thank you for calling MSA!\nSincerely,\nLori l. Barsic\nSenior Customer SeNice Rep .\n•","truncated":false,"body_characters":5603}