{"operation":"document","citation":"13-0014","title":"Mr. Jason Spence — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2013-02-14","effective_on":null,"summary":"13-0014 concerning 180.215.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0014.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0014.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0014","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2013/130014.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\nFEB 1 4 2013\nMr. Jason Spence\n9474 N. Stonebrook Drive\nTucson, AZ 85743\nRefNo.: 13-0014\nDear Mr. Spence:\nThis is a response to your November 30, 2012 email requesting clarification of the\napplicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 1 00-185) with\nregard to recordkeeping requirements for requalification of cylinders. Specifically, you ask\nwhat the term \"actual dimensions\" refers to with respect to the requalification records for\ncylinders specified in § 180.215(b ).\nIn accordance with § 180.215(b ), requalification records must be kept for examination of\nDOT specification cylinders by the person who performs the cylinder requalification. These\nrequalification records include information about the cylinder such as the \"actual\ndimensions\" of the cylinders. Although the HMR does not define \"actual dimensions\", the\nterm as used in§ 180.215(b), refers to the outside diameter and the length of the cylinder in\ninches. Although it is not incorporated by reference in the HMR, this interpretation is\nconsistent with the practices found in CGA pamphlet CGA C-1.\nI hope this information is helpful. If you have any more questions, please do not hesitate to\ncontact this office.\nSincerely,\nRobert Benedict\nChief, Standards Development\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nDrakeford, Carolyn (PHMSA)\nFrom: INFOCNTR (PHMSA)\nSent:\nTo:\nSubject: Friday, January 11, 2013 2:50 PM\nDrakeford, Carolyn (PHMSA)\nFW: CFR Clarification/Letter of Interpretation\nHi Carolyn,\nWe received the following request for a formal letter of interpretation.\nThanks,\nVictoria\nFrom: Jason Spence [mailto:nitchnitchy@gmail.com]\nSent: Friday, January 11, 2013 10:56 AM\nTo: INFOCNTR (PHMSA)\nSubject: CFR Clarification/Letter of Interpretation\nI require some clarification and a letter of interpretation on CPR 49 Parts 180-185. It states in two sections\n180.215 & 180.217(see below)\nthat actual dimensions are required. What dimension does DOT want? How does DOT use these dimensions for\ncylinder identification. I've been in contact with several cylinder manufacturers and gotten several different\ndefinitions. Some say Length by Width, some say gas capacity, some say Length by Radius, some say Height by\nDiameter, some say Height by Circumference and some say water capacity.\n§ 180.215 Reporting and record retention requirements.\n(a) Facility records. A person who requalifies, repairs or rebuilds cylinders must maintain the following records\nwhere the requalification is performed:\n( 1) Current RIN issuance letter;\n(2) Ifthe RIN has expired and renewal is pending, a copy of the renewal request;\n(3) Copies of notifications to Associate Administrator required under§ 107.805 of this chapter;\n(4) Current copies of those portions of this subchapter applicable to its cylinder requalification and marking\nactivities at that location;\n(5) Current copies of all special permits governing exemption cylinders requalified or marked by the requalifier at\nthat location; and\n(6) The information contained in each applicable CGA or ASTM standard incorporated by reference in§ 171.7 of\nthis subchapter applicable to the requalifier's activities. This information must be the same as contained in the\nedition incorporated by reference in § 171.7 of this subchapter.\n(b) Requalification records. Daily records of visual inspection, pressure test, and ultrasonic examination if\npermitted under a special permit, as applicable, must be maintained by the person who performs the\nrequalification until either the expiration of the requalification period or until the cylinder is again requalified,\nwhichever\noccurs first. A single date may be used for each test sheet, provided each test on the sheet was conducted on that\ndate. Ditto marks or a solid vertical line may be used to indicate repetition of the preceding entry for the\nfollowing entries only: date; actual dimensions; manufacturer's name or symbol, if present; owner's name or\nsymbol, if\npresent; and test operator. Blank spaces may not be used to indicate repetition of a prior entry. The records must\ninclude the following information:\n1\n\n<<<PAGE 3>>>\n\n(1) Calibration test records. For each test to demonstrate calibration, the date; serial number of the calibrated\ncylinder; calibration test pressure; total, elastic and permanent expansions; and legible identification of test\noperator. The test operator must be able to demonstrate that the results of the daily calibration verification\ncorrespond to the hydrostatic tests performed on that day. The daily verification of calibration(s) may be recorded\non the same sheets as, and with, test records for that date.\n(2) Pressure test and visual inspection records. The date of requalification; serial number; DOT specification or\nspecial permit number; marked pressure; actual dimensions; manufacturer's name or symbol; owner's name or\nsymbol, if present; result of visual inspection; actual test pressure; total, elastic and permanent expansions;\npercent\npermanent expansion; disposition, with reason for any repeated test, rejection or condemnation; and legible\nidentification of test operator. For each cylinder marked pursuant to § 173 .302a(b )( 5) of this subchapter, the test\nsheet must indicate the method by which any average or maximum wall stress was computed. Records must be\nkept for all completed, as well as unsuccessful tests. The entry for a second test after a failure to hold test\npressure must indicate the date of the earlier test.\nThanks\nJason Spence\n(520)343-1103\nNitchNitchy@gmail.com\n2","truncated":false,"body_characters":5682}