{"operation":"document","citation":"12-0231","title":"SIEMENS Industry, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2013-03-11","effective_on":null,"summary":"12-0231 response to SIEMENS Industry, Inc. concerning 173.309.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0231.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0231.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0231","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2013/120231.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\nMr. Damien Belot\nSIEMENS Industry, Inc.\nBuilding Technologies\nCPS FS Research Unit\n8 Fernwood Road\nFlorham Park, NJ 07932\nReference No. 12-0231\nDear Mr. Belot:\nThis is in response to your October 11, 2012 e-mail and subsequent telephone conversation\nwith a member of my staff requesting clarification applicable to a fire extinguisher system\nunder the Hazardous Materials Regulations (HMR; 49 CPR Parts 171-180). In your letter,\nyou describe a fire extinguisher system which uses cylinders containing inert gases such as\nArgon, Nitrogen, and Inergen+. This fire extinguishing system is installed where critical\ndevices or precious goods must not be damaged by fire. The fire extinguishing system\ncontains non-Department of Transportation (DOT) specification cylinders with pressures of\nup to 3000 psi that are equipped with a valve on which threaded bosses can receive gauges.\nWhen the boss is not used, it is covered with a protection cap. You ask what are the\ntransportation requirements under the HMR when shipping the described fire extinguishing\nsystems as a whole. You also ask whether the cylinders in the fire extinguisher systems\nwould be required to have a pressure gauge installed.\nBased on the information you provided, the system you describe cannot be transported in\nconformance with the HMR. It is the opinion of this Office that the cylinders in the fire\nsuppression system you describe are required to be specification cylinders in accordance\nwith requirements for Class 2 non-flammable gas. Because the cylinders are\nnon-specification cylinders, your company would need to apply for a special permit under\n§ 107.105 of the HMR.\nI hope this satisfies your request.\nSincerely,\n--7~U/U~~\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\n1/IJdltttJ~\n5 /'13.~oc;\n_Drakeford, Carol n PHMSA) r;,\ntti h-ers\nFrom: INFOCNTR (PHMSA) 1/)d-t r'\nSent:\nThursday, October 11, 2012 1 :33 PM In () '?::? J\nTo:\nDrakeford, Carolyn (PHMSA) I~ • o( J 1\nSubject: FW: Transportation of cylinders filled with high pressure inert gas (3000 psi)\nHi Carolyn,\nWe received the following request for a written letter of interpretation. Mr. Belot spoke with Chris Ludwa in the Hazmat\nInfo Center on 10/2/2012 regarding this matter.\nThanks,\nVictoria\nFrom: BELOT, DAMIEN (ext) [mailto:damien.belot.ext@siemens.com]\nSent: Thursday, October 11, 2012 4:59 AM\nTo: INFOCNTR (PHMSA)\nSubject: Transportation of cylinders filled with high pressure inert gas (3000 psi)\nDear Sir or Madam,\nI recently made a request through a webform and I was answered the following :\nRecently you requested assistance from the US Department of Transportation. Below is our response to your request.\nSubject\nTransportation of cylinders filled with high pressure inert gas (3000 psi)\nDiscussion Thread\nResponse Via Email (USDOT Reference Service) Good day,\n!10108/2012 03:52PM\nWe are the general information source for the Department of Transportation.\nI believe your probably spoke to someone in the Pipeline and Hazardous Materials Safety Administration Office of\nHazardous Materials Safety or the Hazardous Materials Information Center.\nPlease email these details directly to them For questions regarding hazardous materials, cylinders, scuba tanks, etc.,\nplease contact the Office ofHazardous Materials Safety (HAZMAT). Contact information is as follows:\nE-mail: infocntr@dot.gov or webform: http://www.phmsa.dot.gov/phmsa-\next/feedback/hazmatlnformationCenterF eedbackF orm.j sp\nSincerely,\nReference Services\nNational Transportation Library\nBureau of Transportation Statistics\nResearch and Innovative Technology Administration\n1\n\n<<<PAGE 3>>>\n\n!u.s. Department of Transportation\nYou will find below my request:\n10/03/2012\nDear Sir or Madam,\nFurther to a phone conversation I had yesterday with a person from the DOT, I write to you in order to receive a formal\nanswer to my question. I was told to provide as many details as I could, so I am going to be thorough. To start off, here\nis the question: when transporting a cylinder filled with gas, does the DOT require that we install a pressure gauge on it?\nThe person answered that is was not required. However, I need a written answer.\nSiemens Inc. is currently designing a new Fire Extinguishing System working with Inert Gas such as Argon, Nitrogen\nand lnergen. This system is installed where critical devices or precious goods or data must not be damaged by the fire\nitself or by the mean used to extinguish it (nuclear plants, datacenters, banks ... ). Should a fire be detected in a room,\nthe system triggers: the gas is released from the cylinder, goes through hoses and pipes until it reaches the room. As\nthe room is filled with gas, the amount of oxygen decreases and the fire smothers.\nThe gases used in this system are not flammable or toxic. They are stored in a cylinder at a pressure of 200 bar (2900\npsi, round up to 3000 psi). The cylinder is equipped with a valve on which you have threaded bosses that can receive\nactuators, pressure gauges, pressure switches, hoses ... When a boss is not used, it is covered with a protection cap. If\nthe valve opens itself during transportation or handling, the gas will slowly escape through a small hole in one of the\ncaps and whistle loudly. The cylinders are transported by semi-trailer trucks.\nIs it also possible that you provide us with the requirements that apply when transporting such cylinders? (marking,\ncolors, ... )\nYou will find attached a datasheet of the cylinder equipped the valve and- for you information- an example of an\ninstallation.\nI remain at your disposal for any question you mav have.\nKind Regards\nDamien BELOT\nSIEMENS Industry, Inc.\nBuilding Technologies\nCPS FS Research Unit\nMechanical Engineer\n8 Fernwood Road\nFlorham Park, NJ 07932\n617, rue Foumy\n78530 BUC\nTel : 00 33 1 30 84 66 89\nFax : 00 33 1 30 84 29 04\nMailto : damien.belot.ext@siemens.com\nwww.siemens.fr\nThis e-mail may contain trade secrets or privileged, undisclosed or otherwise confidential information. If you have received this e-mail in error, you are hereby notified that any\nreview, copying or distribution of it is strictly prohibited. Please inform us immediately and destroy the original transmittal. Thank you for your cooperation.\nCe courrier e!ectronique est confidentiel eta !'attention exclusive de son destinataire. Toute utilisation, divulgation ou reproduction de son contenu est interdite. En cas d'erreur\nde transmission, veuillez nous en informer immediatement, par telephone, telecopie ou messagerie. Merci d' avance.\n2","truncated":false,"body_characters":6718}