{"operation":"document","citation":"12-0170","title":"Sandler, Travis & Rosenberg, P.A. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2012-12-17","effective_on":null,"summary":"12-0170 response to Sandler, Travis & Rosenberg, P.A. concerning 173.301, 173.304a.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0170.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0170.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0170","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2012/120170.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\nDEC 1 7 2012\nMr. Mark Ludwikowski\nSandler, Travis & Rosenberg, P.A.\n1300 Pennsylvania Ave, NW, Suite 400\nWashington, DC 20004-3062\nRef. No.: 12-0170\nDear Mr. Ludwikowski:\nThis is in response to your August 7, 2012 letter requesting clarification of the term \"lot\" as\nit petiains to the testing of rupture disks in accordance with Compressed Gas Association\n(CGA) publication S-1.1. Specifically you ask for confirmation of the appropriate lot size\nfor the purposes of testing and subsequent shipment of rupture disks in accordance with the\nHazardous Materials Regulations (HMR; 49 CFR parts 171-180).\nSection 6.3 .1 of CGA S-1.1 (Rupture disk burst pressure measurement) requires testing of at\nleast 2 samples from each lot (no more than 3,000) of rupture disks. Section 6.3.2 requires\ntesting of at least 2 samples from each lot (no more than 3,000) of rupture disk holders\nwhich are assembled with rupture disks. Section 6.3.3 provides that testing ofthe rupture\ndisk holders which are assembled with rupture disks will satisfy the testing requirements of\nboth 6.3.1 and 6.3.2, so long as the specific tests specified in those two sections are\nsuccessful.\nFor the purposes of testing rupture disk devices in accordance with CGA S-1.1, a lot is\nconsidered to be not more than 3000 disks or rupture disk holders. So long as tests are\nperformed in samples for each lot of not more than 3,000 rupture disks and rupture disk\nholders, any number of these items may be packaged together for shipment and called a\n\"lot.\"\nI hope this information is helpful. If you have further questions, please do not hesitate to\ncontact this office.\nSi)lcerely,\n(;!. ;/ ~£4 (fc\nJJ:_;..L-1 ./ VJ4d'{fD\nDelmer Billings '\nSenior Regulatory Advisor\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nSANDLER, TRAVIS & ROSENBERG, P.A.\nATTORNEYS AT LAW\nMARK LUDWIKOWSKI, ESQ.\nMember, D.C. Bar\n(202) 471-3239 Direct\n(202) 216-9307 Telephone\n(202) 842-2247 Facsimile\nE-MAIL ADDRESS:\nmludwikowski@ strtrade.com\nAugust 7, 2012\nU.S. DOT\nPHMSA Office of Hazardous Materials Standards\nAttn: PHH-10\nEast Building\n1200 New Jersey Avenue, SE\nWashington, DC 20590-0001\nRE: Compressed Gas Association (\"CGA\") S-1.1.\nTo Whom it May Concern:\nOn behalf of Daicel Safety Systems America, Inc. (\"DSSA\"), we seek your guidance regarding the\nrequirements under the Hazardous Materials Regulations (HMR; 49 CFR 171-180) applicable to CGA\nS-1.1. Standard.\nDSSA is a manufacturer of automotive airbag inflators and sources rupture disks for its inflators from a\nthird party supplier.\nThe HMR reference CGA S1.1 Standard at 173.301, 173.304a and 178.75 and adopt the entire\ndocument (except that compliance with paragraph 9.1.1.1 is not required).\nWe wish to turn your attention to section 6.3.2 of CGA S-1.1. Standard (an excerpt of which is\nincluded in Attachment A) regarding the \"Rupture disk holder test\" which notes that the \"production\nof rupture disk holders (that part containing the pressure opening) of 3000 or less shall be considered a\nlot\" (emphasis added).\nOSSA's supplier defines a rupture disk lot size of 10,000 parts. It is important to note that these are not\nrupture disk holders but rather rupture disks. Based on the foregoing, please advise whether a 10,000\npart lot size for rupture disks is acceptable under the HMR' s interpretation and adoption of CGA S-1.1.\n1300 Pennsylvania Avenue, N.W., Suite 400, Washington, D.C. 20004-3062 USA\nCHICAGO • HONG KONG • MIAMI • NEW YORK • SAN FRANCISCO • SCOTTSDALE • WASHINGTON, D.C.\n\n<<<PAGE 3>>>\n\nSANDLER, TRAVIS & ROSENBERG, P.A.\nThank you in advance for your attention to this request. Please let us know if you have any questions\nor require additional information.\nSincerely yours,\nSANDLER, TRAVIS & ROSENBERG, P.A.\nAttorney for Daicel Safety Systems America, Inc.\nAttachments\n\n<<<PAGE 4>>>\n\nATTACHMENT A\n\n<<<PAGE 5>>>\n\nPACile Licensed for the sole use of the purchaser. See license agreement penalties for distribution.\n20. ______ ...._ __ ......~~c~o~Mil,!;P.I.lR::Esl£:s~e~o~G.::A:::os~A;llis~s~o~c!O'A:..wTl~:.O:!lNJ...!, li.!JN.lo!.c • ..__ ______ cGA S-1.1-2007\n6.3.2 Rupture disk holder test\nThe production of rupture disk holders (that part containing the pressure opening) of 3000 or less shall be con-\nsidered a lot. Two representative holders selected at random from the lot shall be assembled with proper rup-\nture disks from an acceptable lot as tested in 6.3.1 and subjected to the burst pressure test of 6.3.1. The actual\nburst pressure shall not be in excess of the rated burst pressure or less than 85% of the rated burst pressure of\nthe disk. For CTC/DOT-4l and TC-4LM cylinders, the actual burst pressure of the disk shall not exceed 105%\nand shall not be less than 90% of its rated burst pressure. If the actual burst pressure at a temperature not less\nthan 60 \"F (15.6 \"C) or more than 160 \"F (71.1 \"C) is not within these limits, the entire lot of rupture disk hold-\ners shall be rejected. If the manufacturer desires to requalify the lot, he may subject four more holders selected\nas above from the same lot to the same test. If all four holders meet the requirement, the lot may be used; oth-\nerwise, the entire lot shall be rejected. Any elevated temperature determinations can be arrived at by tests con-\nducted at room temperature provided that the relation of burst pressure to different temperatures is estabHshed\nby test for the type of material used.\n6.3.3 Combined rupture disk and holder tests\nTesting of the assembled rupture disk and holder for detailed requirements specified in 6.3.1 and 6.3.2 in lieu of\nindividual tests is considered as complying with requirements of both 6.3.1 and 6.3.2.\n6.3.4 Affect of temperature on rupture disk tests\nII is recognized that the rated burst pressure of a rupture disk corresponds to only one specific design tempera-\nture within the range of 60 \"F (15.6 \"C) to 160 \"F (71.1 \"C). Note should be taken that different results will be\nobtained when rupture disks are tested at different temperatures. It is therefore necessary that the temperature\nbe specified at which the rated burst pressure applies. This combination of pressure and temperature is what is\nused to meet the performance requirements of 6.3. (Example: 3000 psig (20 685 kPa) at 60 \"F (15.6 \"C);\n3000 psig (20 685 kPa) at 160 \"F (71.1 \"C), etc.)\nRoom temperature testing may be used to qualify rupture disks designed for use at elevated temperatures.\n(Example: not exceeding 160 \"F [71.1 \"C] provided there is a correlation between room temperature and ele-\nvated temperature conditions as determined by prior testing.)\n6.4 Tests of CG-4 and CG-6 combination rupture-disk/fusible-plug pressure relief devices\n6.4.1 Lot (batch) size\nA lot (batch) of rupture-disk/fusible-plug devices shall be defined as the production, not exceeding one 10-hour\nshift, of any one rated burst pressure and any one yield temperature. Two representative assembled devices\nshall be selected at random from a lot and submitted to a performance test conducted as follows:\n6.4.1.1 Test method\nEach assembled device shall be subjected to a pressure of 70% to 75% of the rated burst pressure of the rup-\nture disk used and while under this pressure shall be immersed in a liquid bath held at a temperature not more\nthan 5 \"F (2.8 \"C) below the minimum specified yield temperature of the fusible metal for at least 10 minutes.\nThe fusible metal shall not show signs of yielding such as melting. The temperature of the bath shall then be\nraised at a rate not in excess of 1 \"F (0.6 \"C) per minute without material change in pressure. Yielding shall\noccur within 10 minutes after the maximum allowable yield temperature is reached and stabHized. Yielding shall\nbe considered as occurring when the fusible alloy starts to flow. There shall be no leakage of air or gas.\nThe rupture disk shall then be tested in accordance with the requirements of 6.3.1. The device may be re-\nmoved from the bath for this test.\n6.4.1.2 Alternate test method\nAs an alternative to tests in 6.4.1.1, the rupture disk and fusible metal may be tested separately to the require-\nments of 6.2.3 and 6.3.1 providing the design of the device will allow for the separation of the parts and the\nseparate tests.\nThis document licensed for the sole usc of the purchaser. It may not be shared with any other person or used after the expiration date\nwithout the express written permission of the CGA. Any unauthorized use, reproduction, distribution, or modification of this printed page\nwill result in a $5,000 liquidated damages fee plus loss of access to CGA publications for one year for your company.","truncated":false,"body_characters":8752}