Mr. Tim McLoughlin — 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 SEP 2 4 2013 Mr. Tim McLoughlin M & M Metrology, Inc. 272 South Military Trail Deerfield Beach, FL 33442 Ref. No.: 13-0131 Dear Mr. McLoughlin: This is in response to your June 19, 2013 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the calibration and certification of gauges used for pressure testing cylinders. You request clarification of the accuracy ofthe pressure indicating device as required under HMR § 180.205. Specifically, you ask if you are correct in calibrating an 1100 psig pressure gauge to ±5.5 psig (±0.5%) of its full range. You are correct. In accordance with§ 180.205(g)(3)(i) the pressure indicating device itself (the pressure gauge) must be certified as having and accuracy of ±0.5%, or better, of its full range. Section 180.205(g)(3)(i) also provides that the pressure indicating device as part ofthe retest apparatus must be accurate to within ±1.0% ofthe prescribed test pressure of any cylinder being tested. Since the described gauge is calibrated to ±5.5 psig, the gauge would not be authorized for testing cylinders having a prescribed test pressure below 550 psig. These requirements are consistent with the Compressed Gas Association Standard CGA C-1-2009 paragraph 5.3.2.2 which provides that the pressure indicating device shall be manufactured and certified to an accuracy grade of ±0.5% or better, and the pressure indicating device shall permit reading of pressures to within I% of the test pressure of each cylinder tested. I trust this information is helpful. If you have fmiher questions, please do not hesitate to contact this office. ~1: ~ Delmer Bil(!l~ Senior Regulatory Advisor Standards and Rulemaking Division --------~~-·#

Page 2Drakeford, Carolyn (PHMSA) From: Sent: To: Cc: Subject: Betts, Charles (PHMSA) Wednesday, June 19, 2013 12:32 PM Drakeford, Carolyn (PHMSA) Cassidy, Duane (PHMSA); Leary, Kevin (PHMSA) RE: Interpretation of CFR 49 Carolyn- Please log and assign to specialist for handling. Thanks, Charles From: Cassidy, Duane (PHMSA) Sent: Wednesday, June 19, 2013 12:30 PM To: Betts, Charles (PHMSA); Leary, Kevin (PHMSA) Subject: Fw: Interpretation of CFR 49 Importance: High Please the interpretation request below regarding calibration of hydro equipment and, more specifically, the accuracy of the gauges. From: M & M Metrology, Inc. [mailto:contactus@mmmetrology.com] Sent: Wednesday, June 19, 2013 09:12AM Eastern Standard Time To: Cassidy, Duane (PHMSA) Subject: FW: Interpretation of CFR 49 From: M & M Metrology, Inc. [mailto:contactus@mmmetrology.com] Sent: Wednesday, June 19, 2013 8:59AM To: 'Duane.Cassidy@dot.com' Subject: Interpretation of CFR 49 Importance: High Good Morning, My name is Tim Mcloughlin and I am the Quality Assurance for M & M Metrology, Inc. We are a calibration lab in south Florida and calibrate several Hydro-Test pressure gauges for companies that service fire extinguishers. One on my customers is having an issue with an auditor from Arrowhead Industrial mostly the interpretation of49 CFR ch.1, 180.250 sect 3(i} and CGA C-12009 para .5.3.2.2. The CFR state that "The pressure indicating device itself, must be certified as having an accuracy of .5% or better, of its full range" The CGA specification say "Shall be accurate to ±1 percent of test pressure" and is requiring the pressure indicating device itself to 1% of reading. We are talking of a 1100 psig pressure gauge@ .5% is ±5.5 psig at any point of the gauge and Arrowhead is requiring 1% of reading. I understand that (ii) of the CFR references the 1% but that is of the entire test setup. Please clarify what the accuracy of the test indicating device itself would be. We have continued to calibrate the gauges to ±5.5 psig. If possible please respond as my customer are due to be audited by Arrowhead in early July. I have also attached a picture of the gauge and the mfr specs are listed below. I also included a copy of the certification that we provided. Additional calibration point have been added to accommodate the 3rd bullet from the CGA 5.3.2.2 - ' - - 1#

Page 3Calibrated Pressure Gauge Can be used in many different applications where a high quality calibrated gauge is required Features: • 0-11 OOpsi range x 2 psi increments • Manufactured to Class 2A specifications (0.5% accuracy full range) • 1/4" Male NPT bottom connection • 6" diameter • Mirrored dial face • Calibrated to 0.5% at the following increments: 200,350,400,500,600,700,800,900, 1000psi • Additional calibration points can be added (please fill in above) • Can be used to US DOT and Transport Canada cylinder testing specifications in a range of 111 - 1 OOOpsi • Internal "True Zero" adjustment knob • Includes calibration certificate Thanks in advance for your time Tim 954 426-0111 2#

Page 4200 300 100 400 500 600 510= 2 psi sube Brazed ONISIONOON HYDRO-TEST Brass socket Don eur MASS 71*13 700 800 PSi 1100 1000 900#

Page 5M Metrology Gage 10: 120398-1 Manufacturer: Hydro-Test Products Serial Number: 120398-1 Model Number: 140-018 Description: 0-1,100 psig Pressure Gauge M & M Metrology, Inc 272 South Military Trail Deerfield Beach, FL 33442 Ph (954) 426-0111 Fax (954) 426-0522 ContactUs@mmmetrology .com Certificate of Calibration Certificate No.: 100564 P/0 Number: Verbal Jim Calibration Date: 06/11/2013 Next Due Date: 06/30/2014 Cal. Freq.: 12EOM Calibrated By: J.S. On-Site: No As Found Cond.: In Tolerance As Left Cond.: In Tolerance Pass.: Yes Page 1 of 1 Temperature: 72° F Humidity: 50% Customer Info: A.A. C. United Fire & Safety Equipment 305 S.W. 15th Ave. Pompano Beach, FL 33069 Comments: Calibration Statement: It is hereby certified that the above described gauge has been calibrated in compliance with ISO/IEC 17025:2005, ANSI/NCSL Z540-1 :1994, ISO 10012-2003, ISO 9001:2000, IS09001-2008, ISO!TS 16949:2002, AS9100 Rev C Section 1, AS9100 Rev. C Clause 7.6, IS09001/9002:1994, AS9100 Rev, C section 2, Clause 4.11, Mii-Std-45662A, ISO!TS 16949 Rev 2 Clause 7.6, 21CFR820.72 and 21CFR58.63 FDA Quality System, United Technologies PW-QA 6077J and theM & M Metrology Quality Program. All standards used are traceable to the National Institute of Standards & Technology. All calibration records are on file for review at M & M Metrology, Inc. upon your request. The Collective uncertainty of the measurement standards shall not exceed 25% of the acceptable tolerance for each characteristic of the MT&E being calibrated or verified unless otherwise stated (TUR4:1). The above listed instrument passed all calibration points listed below unless otherwise specified. The results listed on this certificate or report are relevant only to the instrument described above. This cerfif1cate or report shall not be reproduced except in full, without the written approval of M & M Metrology, Inc. Calibration Standards Used: Procedures Referenced: Gage ID: Manufacturer Model Number Description Due Date: Procedure Name- Rev No. --~------------------------------------~------------------------- MMPM38861 Heise HQS-2 0-2,000 psig Pressure Module 12/31/2014 CP36E Revision 01/01/2002- R.1 MMPR2527 Heise PTE-1 2H Dual Display Digital Pressure Indicator 04/30/2014 Calibration Measurements: Calibration Point: Minimum: Nominal: Maximum: Before: Deviation: Fail Before: Comments: 01 200 Type: Units: 194.5 200.0 Limited: After: Deviation: Fail After: 205.5 201.5 1.5 No 02 300 v psig 294.5 300.0 No 201.5 1.5 No 305.5 301.4 1.4 No 03 400 v psig 394.5 400.0 No 301.4 1.4 No 405.5 401.3 1.3 No 04 500 v psig 494.5 500.0 No 401.3 1.3 No 505.5 501.1 1.1 No 05 600 v psig 594.5 600.0 No 501.1 1.1 No 605.5 600.2 0.2 No 06 800 v psig 794.5 800.0 No 600.2 0.2 No 805.5 798.6 -1.4 No 07 1000 v psig 994.5 1000.0 No 798.6 -1.4 No 1005.5 995.2 -4.8 No v psig No 995.2 -4.8 No Approved By: Date Authorized Quality Representative -----"--" __________ " __________ " ____ _ *-Unless otherwise stated in the "Comments." M&MF-01-D-13 IIIIIIIIIIIIIUIIIIIIIIIIIII#

Page 620GP 't leak- ansion ; !eak- 1 rates CGA C-1-2009 ________ C:::::'~o!!!M_,_PR!.01E"'-'s""s::!:E""D'-'G""'A'""s""'A"-"='s::<.:so""'c"'I:..:.AT""'I""O.:.::N~IN'""'c,_._. ___________ PAGE 11 5.3.2.2 Pressure indicating devic~ The pressure indicating device (PID) shaH be a pressure gauge or other suitable device such as a pressure transducer and digital readout that: shall be manufactured and certified to an accuracy grade of ±0.5% or better: shall permit reading of pressures to within 1% of the test pressure of each cylinder tested. For analog PlDs. interpolation to one half of the marked increment is permitted; shall permit readings of pressures from 90% to 11 0% of the test pressure of any cylinder tested; shall be accurate to ±1% oftest pressures: and shaH be recalibrated periodically in accordance with Appendix B. For example, using a 10 000 psi pressure gauge with an accuracy grade of ±0.5%, the reading is accurate to ±50 psi (0.5% x 10 000 psi) at any point on the pressure gauge. For a test pressure range of 3000 psi to 5000 psi at 3000 psi the gauge accuracy may deviate by only ±30 psi (1% of 3000 psi) while for 5000 psi the gauge may deviate by as much as ±50 psi. NOTE-The gauge in this example satisfies the accuracy grade requirement but could not be used for test pressures !ess than 5000 psi since the gauge is only accurate to ±50 psi. An accuracy of ±30 psi is required for the minimum test pressure at 3000 psi. A gauge with a smaller range (e.g., 5000 psi) or a better accuracy (e.g., ±0.25%) is needed. 5.3.2.3 Pressure recording device The use of a pressure recording device is not required. However, if used, the device should be compatible with the maximum system pressure capability. The pressure recording device shaH be adjustable so that correlation with the PID can be achieved. 5.3.2.4 Associated plumbing AI! pressure valves, fittings, and connecting tubing shall be of a size and material appropriate for the pressures and the stresses of the test and be adequately sized and installed in a manner to prevent leakage, air entrap- ment, or exposure to external damage. Additional pressure supply system components such as surge cham- bers, reservoirs, pulsation dampeners, accumulators, etc , shall be selected with consideration to pressure cy- cling capabilities and maximum test pressures. All pressure supply system components shaH be properly se- lected. installed, and maintained to ensure leak-free performance. CAUTION: In the design and construction of tt1e pressure system, consideration sl7all be given to the potential hazards associated with the containment of liquids under high pressure. The use of additional safety equipment such as relfef devices, blast shields, test cages, etc., is advisable to prevent possible injury to testing personnel and equipment. 5.3.3 Timing device During testing, a timing device that is capable of accurately measuring the minimum test duration shall be used. 5.4 Calibrated cylinder A calibrated cylinder ls required when performing the verification procedure for test methods where volumetric expansion determinations are required. The calibrated cylinder is a derived secondary standard used to dem- onstrate test apparatus integrity and to confirm PlD and EID accuracy. A calibrated cylinder is a cylinder that has been specially prepared so that it no longer experiences permanent expansion at the pressures for which it has been calibrated. The expansion readings of the cylinder shall be repeatable and linear. A certification for the cylinder noting the actual pressure and expansion values for each pressure calibration level shall be available. The original signed certification of calibration shoufd be maintained in a safe place and a copy shall be posted on or near the hydrostatic test console.#

Page 7§ 180.205 49 CFR Ch. 1 (10-12 Edition) Pipeline and Hazardous Materials Saf (i) of this section. (ii) Condemned in accordance with paragraph in accordance with the following CGA Pam- (1) The visual inspection must be performed the retest apparatus, is accurate within *:1.0% (i) The pressure-indicating device, as part marked service pressure may be changed upon (3) For DOT specification cylinders, the phlets: C-6 for steel and nickel cylinders (TBR. ed that day. The pressure indicating device. the prescribed test pressure of any cylinder te leas aluminum cylinders (IBR, see § 171.7 of this see $ 171.7 of this subchapter): C-6.) For seam- approval of the Associate Administrator and in accordance with written procedures specified in subchapter); C-6.2 for fiber reinforced composite s:0.5%, or better, of its full range, and must p self, must be certified as having an accuracy the approval. special permit cylinders (IBR. see § 171.7 of this BAXX, 3B, 3BN, or 3T cylinder filled with gases (4) For a specification 3, 3А, ЗАЛ, ЗАL, ЗАХ. cylinders (IBR, see § 171.7 of this subchapter); subchapter); C-6.3 for low pressure aluminum mit readings of pressure from 90-110% of t der to be tested. The accuracy of the pressure minimum prescribed test pressure of the cyl ification due on or after December 31, 2003, the in other than Division 2.2, from the first requal- this subchapter); and C'-13 for DOT 8 series cyl- C-8 for DOT 3HT cylinders (IBR. see § 171.7 of demonstrated at any point within 500 psig of t dicating device within the test system can sure relief device must be at test pressure with a burst pressure of a CG-1, CG-1, or CG-5 pres. inders (IBR. see § 171.7 of this subchapter). ments that would inhibit inspection of the cylin- (2) For each cylinder with a coating or attach- actual test pressure for test pressures at above 3000 psig, or 10% of the actual test pr tolerance of plus zero to minus 10%. An addition- al 5% tolerance is allowed when a combined rup- removed before performing the visual inspec. attachments must be sure for test pressures below 3000 psig the retest apparatus. gives a stable reading (ii) The expansion indicating device, as part requirement does not apply if a CG-2, CG-3 or ture disc is placed inside a holder. This CG-9 thermally activated relief device or a CG- must be approved, rejected, or condemned ac- (3) Each cylinder subject to visual inspection expansion of any cylinder tested or 0.1 cc. whic expansion and is accurate to +1.0% of the to 7 reclosing pressure valve is used on the cylin- cording to the criteria in the applicable CGA itself must have an accuracy of +0.5%, or bett ever is larger. The expansion-indicating dev cylinders. Without regard to any other periodic (d) Conditions requiring test and inspection of of its full scale. scribed in this paragraph (f. each specification (4) In addition to other requirements pre- accurate within +1.0% of the calibrated cyl (4) The test equipment must be verified to requalification requirements, a cylinder must be tion prior to further use if-- tested and inspected in acrordance with this sec. cylinder manufactured of aluminum alloy 6851- breathing apparatus (SCUBA), self-contained. in self-contained underwater ues. This may be accomplished by bringing der's pressure and corresponding expansion v rosion, cracked or abraded areas, leakage, ther- (1) The cylinder shows evidence of dents. cor- must be inspected for sustained load cracking in: breathing apparatus (SCBA), or oxygen service tificate for the calibrated cylinder used and v pressure to a value shown on the calibration c • render it unsafe for use in transportation; mal damage, or any other condition that might accordance with Appendix C of this part at the ifying that the resulting total expansion ter January 1, 2007, and every five years there- first scheduled 5-year requalification period af- the calibration certificate. Alternatively, es within *1.0% of the total expansion shown has been damaged to an extent that may ad- (2) The cylinder has been in an accident and bration may be demonstrated by bringing the versely affect its lading retention capability; to have been over-heated; or (3) The cylinder shows evidence of or is known ed, each cylinder required to be retested under (g) Pressure lest. (1) Unless otherwise provid- used and verifying that the resulting pressure edibration certificate for the calibrated cylinc that the cylinder may be in an unsafe condition. (4) The Associate Administrator determines this subpart must he retested by means suitable? der pressure. Bands and other removable ati for measuring the expansion of the cylinder un- bration certificate. The calibrated cylinder mi within +1.0% of the pressure shown on the ca liquids. A cylinder previously containing a Class (e) Cylinders containing Class 8 (corrosive) tachments must be loosened or removed before whow no permanent expansion. The retes testing so that the cylinder is free to expand in must demonstrate calibration in conformar a Class 2 material in commerce unless the cylin- 8 (corrosive) liquid may not be used to transport tor on any day that it retests cylinders. A rete with this paragraph (g) to an authorized insp ing apparatus must permit reading of pressurel (2) The pressure indicating device of the test in conformance with § 180.215(b)(4). or must maintain calibrated cylinder certificat nally, in accordance with paragraph (f) of this (1) Visually inspected, internally and exter- to within 1% of the minimum prescribed teal pressure of each cylinder tested, except that for tumed for at least 30 seconds, and as long as n 15) Minimum test pressure must be ma section and the inspection is recorded as pre- marked gauge divisions is acceptable. The ox an analog device. interpolation to ½ of th scribed in $ 180.216; aystem check may be performed at or below 9 enary for complete expansion of the cylinder tion. regardless of the (2) Requalified in accordance with this sec- requalification; date of the previous pansion-indicating device of the testing appard cylinder expansion to 1% of the total expansio tus must also permit incremental reading of th " malfunction of the teat equipment, the te uf lent pressure prior to the retest. In the case (4) Decontaminated to remove all significant (3) Marked in accordance with § 180.213; and of each cylinder tested or 0.1 ce, whichever it 100 psig, whichever in less. This paragraph may be repeated at a pressure increased by 10 residue or impregnation of the Class 8 material. larger. Midpoint visual interpolation is permi dors not authorize retent of a cylinder otherw vided in this subpart, cach (f) Visual inspection. Except as otherwise pro- shall confirm, by using a calibrated cylinder of (3) Each day before retesting. the retente mgured to be condemned under paragraph (i) pressure tested, it must be given an internal and time a cylinder is thin section. other method authorized in writing by the Asm Ing permons who rogualify cylindere uning ! (if) Training materials may be uned for tra ciate Administrator. that: vultumetric expansion test method.#