{"operation":"document","citation":"13-0032","title":"Complete Cylinder Service, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2013-05-29","effective_on":null,"summary":"13-0032 response to Complete Cylinder Service, Inc. concerning 173.304a, 180.209.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0032.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0032.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0032","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2013/130032.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 2 9 2013\nMr. Paul Kleier, Jr.\nPresident\nComplete Cylinder Service, Inc.\n1240 Glendale Milford Road\nCincitmati, OH 45215\nReference No. 13-0032\nDear Mr. Kleier:\nThis is in response to your January 17, 2013 letter asking for clarification of the \"DT\" and\n\"S\" marking requirements for cylinders prescribed in§§ 173.304a(d)(4) and 180.213(±)(4)\nand 180.213(±)(6), respectively, ofthe Hazardous Materials Regulations (HMR; 49 CFR\nParts 171-180). You ask if the \"DT' stamp marked on a cylinder represents that a cylinder\nvalve is equipped with a dip tube or siphon tube. You also ask if an \"S\" stamp marked on a\ncylinder may be used to represent that the cylinder is equipped with a siphon tube and that it\nhas successfully completed a \"proof pressure test.\"\nUnder the HMR, the letters \"DT\" stamped on a cylinder mean that the cylinder is equipped\nwith a removable-type, fixed-length dip tube gauging device (here-in referred to as \"dip\ntube\") that may be used to verify the quantity of its contents, and that the cylinder complies\nwith specific design and hazardous material content requirements prescribed in\n§ 173 .304a( d)( 4 ). These requirements include that the cylinder: 1) must only contain\nliquefied petroleum gas with a specific gravity of 0.504 or greater at 16 oc (60 °F), 2) has a\nwater capacity of 90.72 kg (200 pounds) or more, 3) is stamped on its exterior surface and\non the exterior of the dip tube with the letters \"DT,\" and 4) is stamped on its dip tube after\nthe DT stamp with the length ofthe dip tube expressed in inches and carried out to one\ndecimal place (see§ 173.304a(d)(4)). The letter \"S\" stamped on a cylinder represents that\nthe cylinder has either successfully completed the proof pressure test prescribed in\n§ 180.209( e), or that it is a successfully requalified shell of a DOT 8 series cylinder (see\n§ 180.213(±)(4) and (f)(6)). The letter \"S\" does not represent that a cylinder is equipped\nwith a siphon tube.\nI hope this satisfies your request.\nSincerely,\nr-?'r#~~\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\n1.240 Glendale Milford Road, Cincinnati, Ohio 4521.5\nJanuary 17, 2013\nU.S. DOT\nPHMSA Office of Hazardous Materials Standards\nAttn: PHH-10\nEast Building\n1200 New Jersey Avenue, SE.\nWashington, DC 20590-0001\nTo whom it mdy~concern:\n--\nAs a cylinder retester for 30 years I have heard many different interpretations regarding the stamping of either \"S\" or \"DT\"\nimmediately following the test date on a cylinder to denote that the valve (and cylinder) contains a dip-tube or siphon\ntube. As I read section 180.213 of the CFR Title 49 specifically paragraph \"D\" it seems to me that only the described\nmarkings are permitted. Obviously someone stamping an \"S\" behind the test date would be signifying a proof pressure test\nwas performed, which would seem to eliminate the practice of stamping this same letter to denote a siphon tube. In any\ncase I would greatly appreciate an interpretation of this paragraph as it relates to this practice.\nSincerely,\nr?~\\~\nPaul Kleier Jr.\nComplete Cylinder Service\n1240 Glendale Milford Road, Cincinnati, Ohio 45215\nPAUL KLEIER, Jr.\nPresident\npaul@completecylinder.com\nThe\nPhone: 513-772-1500\nFax: 513-772~0154\nCell: 513-325~6339\nPhone: 513-772-1500\nFax: 513-772-0154\nwww.completecylinder.com","truncated":false,"body_characters":3489}