Complete Cylinder Service, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590 MAY 2 9 2013 Mr. Paul Kleier, Jr. President Complete Cylinder Service, Inc. 1240 Glendale Milford Road Cincitmati, OH 45215 Reference No. 13-0032 Dear Mr. Kleier: This is in response to your January 17, 2013 letter asking for clarification of the "DT" and "S" marking requirements for cylinders prescribed in§§ 173.304a(d)(4) and 180.213(±)(4) and 180.213(±)(6), respectively, ofthe Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You ask if the "DT' stamp marked on a cylinder represents that a cylinder valve is equipped with a dip tube or siphon tube. You also ask if an "S" stamp marked on a cylinder may be used to represent that the cylinder is equipped with a siphon tube and that it has successfully completed a "proof pressure test." Under the HMR, the letters "DT" stamped on a cylinder mean that the cylinder is equipped with a removable-type, fixed-length dip tube gauging device (here-in referred to as "dip tube") that may be used to verify the quantity of its contents, and that the cylinder complies with specific design and hazardous material content requirements prescribed in § 173 .304a( d)( 4 ). These requirements include that the cylinder: 1) must only contain liquefied petroleum gas with a specific gravity of 0.504 or greater at 16 oc (60 °F), 2) has a water capacity of 90.72 kg (200 pounds) or more, 3) is stamped on its exterior surface and on the exterior of the dip tube with the letters "DT," and 4) is stamped on its dip tube after the DT stamp with the length ofthe dip tube expressed in inches and carried out to one decimal place (see§ 173.304a(d)(4)). The letter "S" stamped on a cylinder represents that the cylinder has either successfully completed the proof pressure test prescribed in § 180.209( e), or that it is a successfully requalified shell of a DOT 8 series cylinder (see § 180.213(±)(4) and (f)(6)). The letter "S" does not represent that a cylinder is equipped with a siphon tube. I hope this satisfies your request. Sincerely, r-?'r#~~ T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 21.240 Glendale Milford Road, Cincinnati, Ohio 4521.5 January 17, 2013 U.S. DOT PHMSA Office of Hazardous Materials Standards Attn: PHH-10 East Building 1200 New Jersey Avenue, SE. Washington, DC 20590-0001 To whom it mdy~concern: -- As a cylinder retester for 30 years I have heard many different interpretations regarding the stamping of either "S" or "DT" immediately following the test date on a cylinder to denote that the valve (and cylinder) contains a dip-tube or siphon tube. As I read section 180.213 of the CFR Title 49 specifically paragraph "D" it seems to me that only the described markings are permitted. Obviously someone stamping an "S" behind the test date would be signifying a proof pressure test was performed, which would seem to eliminate the practice of stamping this same letter to denote a siphon tube. In any case I would greatly appreciate an interpretation of this paragraph as it relates to this practice. Sincerely, r?~\~ Paul Kleier Jr. Complete Cylinder Service 1240 Glendale Milford Road, Cincinnati, Ohio 45215 PAUL KLEIER, Jr. President paul@completecylinder.com The Phone: 513-772-1500 Fax: 513-772~0154 Cell: 513-325~6339 Phone: 513-772-1500 Fax: 513-772-0154 www.completecylinder.com#