{"operation":"document","citation":"13-0131","title":"Mr. Tim McLoughlin — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2013-09-24","effective_on":null,"summary":"13-0131 response to Mr. Tim McLoughlin concerning 180.205.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0131.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0131.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0131","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2013/130131.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\nSEP 2 4 2013\nMr. Tim McLoughlin\nM & M Metrology, Inc.\n272 South Military Trail\nDeerfield Beach, FL 33442\nRef. No.: 13-0131\nDear Mr. McLoughlin:\nThis is in response to your June 19, 2013 email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to the calibration and\ncertification of gauges used for pressure testing cylinders. You request clarification of the\naccuracy ofthe pressure indicating device as required under HMR § 180.205. Specifically,\nyou ask if you are correct in calibrating an 1100 psig pressure gauge to ±5.5 psig (±0.5%) of\nits full range.\nYou are correct. In accordance with§ 180.205(g)(3)(i) the pressure indicating device itself\n(the pressure gauge) must be certified as having and accuracy of ±0.5%, or better, of its full\nrange.\nSection 180.205(g)(3)(i) also provides that the pressure indicating device as part ofthe retest\napparatus must be accurate to within ±1.0% ofthe prescribed test pressure of any cylinder\nbeing tested. Since the described gauge is calibrated to ±5.5 psig, the gauge would not be\nauthorized for testing cylinders having a prescribed test pressure below 550 psig.\nThese requirements are consistent with the Compressed Gas Association Standard\nCGA C-1-2009 paragraph 5.3.2.2 which provides that the pressure indicating device shall be\nmanufactured and certified to an accuracy grade of ±0.5% or better, and the pressure\nindicating device shall permit reading of pressures to within I% of the test pressure of each\ncylinder tested.\nI trust this information is helpful. If you have fmiher questions, please do not hesitate to\ncontact this office.\n~1: ~\nDelmer Bil(!l~\nSenior Regulatory Advisor\nStandards and Rulemaking Division\n--------~~-·\n\n<<<PAGE 2>>>\n\nDrakeford, Carolyn (PHMSA)\nFrom:\nSent:\nTo:\nCc:\nSubject:\nBetts, Charles (PHMSA)\nWednesday, June 19, 2013 12:32 PM\nDrakeford, Carolyn (PHMSA)\nCassidy, Duane (PHMSA); Leary, Kevin (PHMSA)\nRE: Interpretation of CFR 49\nCarolyn-\nPlease log and assign to specialist for handling.\nThanks,\nCharles\nFrom: Cassidy, Duane (PHMSA)\nSent: Wednesday, June 19, 2013 12:30 PM\nTo: Betts, Charles (PHMSA); Leary, Kevin (PHMSA)\nSubject: Fw: Interpretation of CFR 49\nImportance: High\nPlease the interpretation request below regarding calibration of hydro equipment and, more specifically, the accuracy of\nthe gauges.\nFrom: M & M Metrology, Inc. [mailto:contactus@mmmetrology.com]\nSent: Wednesday, June 19, 2013 09:12AM Eastern Standard Time\nTo: Cassidy, Duane (PHMSA)\nSubject: FW: Interpretation of CFR 49\nFrom: M & M Metrology, Inc. [mailto:contactus@mmmetrology.com]\nSent: Wednesday, June 19, 2013 8:59AM\nTo: 'Duane.Cassidy@dot.com'\nSubject: Interpretation of CFR 49\nImportance: High\nGood Morning,\nMy name is Tim Mcloughlin and I am the Quality Assurance for M & M Metrology, Inc. We are a calibration lab in\nsouth Florida and calibrate several Hydro-Test pressure gauges for companies that service fire extinguishers. One on my\ncustomers is having an issue with an auditor from Arrowhead Industrial mostly the interpretation of49 CFR ch.1, 180.250\nsect 3(i} and CGA C-12009 para .5.3.2.2. The CFR state that \"The pressure indicating device itself, must be certified as\nhaving an accuracy of .5% or better, of its full range\" The CGA specification say \"Shall be accurate to ±1 percent of test\npressure\" and is requiring the pressure indicating device itself to 1% of reading. We are talking of a 1100 psig pressure\ngauge@ .5% is ±5.5 psig at any point of the gauge and Arrowhead is requiring 1% of reading. I understand that (ii) of the\nCFR references the 1% but that is of the entire test setup. Please clarify what the accuracy of the test indicating device\nitself would be. We have continued to calibrate the gauges to ±5.5 psig. If possible please respond as my customer are\ndue to be audited by Arrowhead in early July. I have also attached a picture of the gauge and the mfr specs are listed\nbelow. I also included a copy of the certification that we provided. Additional calibration point have been added to\naccommodate the 3rd bullet from the CGA 5.3.2.2\n- '\n- -\n1\n\n<<<PAGE 3>>>\n\nCalibrated Pressure Gauge\nCan be used in many different applications where a high quality calibrated gauge is required\nFeatures:\n• 0-11 OOpsi range x 2 psi increments\n• Manufactured to Class 2A specifications (0.5% accuracy full range)\n• 1/4\" Male NPT bottom connection\n• 6\" diameter\n• Mirrored dial face\n• Calibrated to 0.5% at the following increments: 200,350,400,500,600,700,800,900, 1000psi\n• Additional calibration points can be added (please fill in above)\n• Can be used to US DOT and Transport Canada cylinder testing specifications in a range of 111 - 1 OOOpsi\n• Internal \"True Zero\" adjustment knob\n• Includes calibration certificate\nThanks in advance for your time\nTim\n954 426-0111\n2\n\n<<<PAGE 4>>>\n\n200\n300\n100\n400\n500\n600\n510=\n2 psi sube\nBrazed\nONISIONOON\nHYDRO-TEST\nBrass socket\nDon eur\nMASS 71*13\n700\n800\nPSi\n1100\n1000\n900\n\n<<<PAGE 5>>>\n\nM\nMetrology\nGage 10: 120398-1\nManufacturer: Hydro-Test Products\nSerial Number: 120398-1\nModel Number: 140-018\nDescription: 0-1,100 psig Pressure Gauge\nM & M Metrology, Inc\n272 South Military Trail\nDeerfield Beach, FL 33442\nPh (954) 426-0111 Fax (954) 426-0522\nContactUs@mmmetrology .com\nCertificate of Calibration\nCertificate No.: 100564\nP/0 Number: Verbal Jim\nCalibration Date: 06/11/2013\nNext Due Date: 06/30/2014\nCal. Freq.: 12EOM\nCalibrated By: J.S.\nOn-Site: No\nAs Found Cond.: In Tolerance\nAs Left Cond.: In Tolerance\nPass.: Yes\nPage 1 of 1\nTemperature:\n72° F\nHumidity:\n50%\nCustomer Info:\nA.A. C. United Fire & Safety Equipment\n305 S.W. 15th Ave.\nPompano Beach, FL 33069\nComments:\nCalibration Statement:\nIt 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,\nIS09001-2008, 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\n16949 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\ntraceable 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\nmeasurement 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\nabove 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\nabove. This cerfif1cate or report shall not be reproduced except in full, without the written approval of M & M Metrology, Inc.\nCalibration Standards Used: Procedures Referenced:\nGage ID: Manufacturer Model Number Description Due Date: Procedure Name- Rev No.\n--~------------------------------------~------------------------- MMPM38861\nHeise\nHQS-2\n0-2,000 psig Pressure Module\n12/31/2014 CP36E Revision 01/01/2002- R.1\nMMPR2527\nHeise\nPTE-1 2H\nDual Display Digital Pressure Indicator\n04/30/2014\nCalibration Measurements:\nCalibration Point:\nMinimum: Nominal:\nMaximum: Before: Deviation:\nFail Before:\nComments:\n01 200\nType: Units:\n194.5 200.0\nLimited: After: Deviation:\nFail After:\n205.5 201.5 1.5\nNo\n02 300\nv psig\n294.5 300.0\nNo 201.5 1.5\nNo\n305.5 301.4 1.4\nNo\n03 400\nv psig\n394.5 400.0\nNo 301.4 1.4\nNo\n405.5 401.3 1.3\nNo\n04 500\nv psig\n494.5 500.0\nNo 401.3 1.3\nNo\n505.5 501.1 1.1\nNo\n05 600\nv psig\n594.5 600.0\nNo 501.1 1.1\nNo\n605.5 600.2 0.2\nNo\n06 800\nv psig\n794.5 800.0\nNo 600.2 0.2\nNo\n805.5 798.6 -1.4\nNo\n07 1000\nv psig\n994.5 1000.0\nNo 798.6 -1.4\nNo\n1005.5 995.2 -4.8\nNo\nv psig\nNo 995.2 -4.8\nNo\nApproved By:\nDate\nAuthorized Quality Representative\n-----\"--\" __________ \" __________ \" ____ _\n*-Unless otherwise stated in the \"Comments.\"\nM&MF-01-D-13 IIIIIIIIIIIIIUIIIIIIIIIIIII\n\n<<<PAGE 6>>>\n\n20GP\n't leak-\nansion\n; !eak-\n1 rates\nCGA 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\n5.3.2.2 Pressure indicating devic~\nThe pressure indicating device (PID) shaH be a pressure gauge or other suitable device such as a pressure\ntransducer and digital readout that:\nshall be manufactured and certified to an accuracy grade of ±0.5% or better:\nshall permit reading of pressures to within 1% of the test pressure of each cylinder tested. For analog PlDs.\ninterpolation to one half of the marked increment is permitted;\nshall permit readings of pressures from 90% to 11 0% of the test pressure of any cylinder tested;\nshall be accurate to ±1% oftest pressures: and\nshaH be recalibrated periodically in accordance with Appendix B.\nFor example, using a 10 000 psi pressure gauge with an accuracy grade of ±0.5%, the reading is accurate to\n±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\nat 3000 psi the gauge accuracy may deviate by only ±30 psi (1% of 3000 psi) while for 5000 psi the gauge may\ndeviate by as much as ±50 psi.\nNOTE-The gauge in this example satisfies the accuracy grade requirement but could not be used for test pressures !ess\nthan 5000 psi since the gauge is only accurate to ±50 psi. An accuracy of ±30 psi is required for the minimum test pressure\nat 3000 psi. A gauge with a smaller range (e.g., 5000 psi) or a better accuracy (e.g., ±0.25%) is needed.\n5.3.2.3 Pressure recording device\nThe use of a pressure recording device is not required. However, if used, the device should be compatible with\nthe maximum system pressure capability. The pressure recording device shaH be adjustable so that correlation\nwith the PID can be achieved.\n5.3.2.4 Associated plumbing\nAI! pressure valves, fittings, and connecting tubing shall be of a size and material appropriate for the pressures\nand the stresses of the test and be adequately sized and installed in a manner to prevent leakage, air entrap-\nment, or exposure to external damage. Additional pressure supply system components such as surge cham-\nbers, reservoirs, pulsation dampeners, accumulators, etc , shall be selected with consideration to pressure cy-\ncling capabilities and maximum test pressures. All pressure supply system components shaH be properly se-\nlected. installed, and maintained to ensure leak-free performance.\nCAUTION: In the design and construction of tt1e pressure system, consideration sl7all be given to the potential\nhazards associated with the containment of liquids under high pressure. The use of additional safety equipment\nsuch as relfef devices, blast shields, test cages, etc., is advisable to prevent possible injury to testing personnel\nand equipment.\n5.3.3 Timing device\nDuring testing, a timing device that is capable of accurately measuring the minimum test duration shall be used.\n5.4 Calibrated cylinder\nA calibrated cylinder ls required when performing the verification procedure for test methods where volumetric\nexpansion determinations are required. The calibrated cylinder is a derived secondary standard used to dem-\nonstrate test apparatus integrity and to confirm PlD and EID accuracy.\nA calibrated cylinder is a cylinder that has been specially prepared so that it no longer experiences permanent\nexpansion at the pressures for which it has been calibrated. The expansion readings of the cylinder shall be\nrepeatable and linear. A certification for the cylinder noting the actual pressure and expansion values for each\npressure calibration level shall be available. The original signed certification of calibration shoufd be maintained\nin a safe place and a copy shall be posted on or near the hydrostatic test console.\n\n<<<PAGE 7>>>\n\n§ 180.205\n49 CFR Ch. 1 (10-12 Edition)\nPipeline and Hazardous Materials Saf\n(i) of this section.\n(ii) Condemned in accordance with paragraph\nin accordance with the following CGA Pam-\n(1) The visual inspection must be performed\nthe retest apparatus, is accurate within *:1.0%\n(i) The pressure-indicating device, as part\nmarked service pressure may be changed upon\n(3) For DOT\nspecification cylinders,\nthe\nphlets: C-6 for steel and nickel cylinders (TBR.\ned that day. The pressure indicating device.\nthe prescribed test pressure of any cylinder te\nleas aluminum cylinders (IBR, see § 171.7 of this\nsee $ 171.7 of this subchapter): C-6.) For seam-\napproval of the Associate Administrator and in\naccordance with written procedures specified in\nsubchapter); C-6.2 for fiber reinforced composite\ns:0.5%, or better, of its full range, and must p\nself, must be certified as having an accuracy\nthe approval.\nspecial permit cylinders (IBR. see § 171.7 of this\nBAXX, 3B, 3BN, or 3T cylinder filled with gases\n(4) For a specification 3, 3А, ЗАЛ, ЗАL, ЗАХ.\ncylinders (IBR, see § 171.7 of this subchapter);\nsubchapter); C-6.3 for low pressure aluminum\nmit readings of pressure from 90-110% of t\nder to be tested. The accuracy of the pressure\nminimum prescribed test pressure of the cyl\nification due on or after December 31, 2003, the\nin other than Division 2.2, from the first requal-\nthis subchapter); and C'-13 for DOT 8 series cyl-\nC-8 for DOT 3HT cylinders (IBR. see § 171.7 of\ndemonstrated at any point within 500 psig of t\ndicating device within the test system can\nsure relief device must be at test pressure with a\nburst pressure of a CG-1, CG-1, or CG-5 pres.\ninders (IBR. see § 171.7 of this subchapter).\nments that would inhibit inspection of the cylin-\n(2) For each cylinder with a coating or attach-\nactual test pressure for test pressures at\nabove 3000 psig, or 10% of the actual test pr\ntolerance of plus zero to minus 10%. An addition-\nal 5% tolerance is allowed when a combined rup-\nremoved before performing the visual inspec.\nattachments must be\nsure for test pressures below 3000 psig\nthe retest apparatus. gives a stable reading\n(ii) The expansion indicating device, as part\nrequirement does not apply if a CG-2, CG-3 or\nture disc\nis placed inside a holder.\nThis\nCG-9 thermally activated relief device or a CG-\nmust be approved, rejected, or condemned ac-\n(3) Each cylinder subject to visual inspection\nexpansion of any cylinder tested or 0.1 cc. whic\nexpansion and is accurate to +1.0% of the to\n7 reclosing pressure valve is used on the cylin-\ncording to the criteria in the applicable CGA\nitself must have an accuracy of +0.5%, or bett\never is larger. The expansion-indicating dev\ncylinders. Without regard to any other periodic\n(d) Conditions requiring test and inspection of\nof its full scale.\nscribed in this paragraph (f. each specification\n(4) In addition to other requirements pre-\naccurate within +1.0% of the calibrated cyl\n(4) The test equipment must be verified to\nrequalification requirements, a cylinder must be\ntion prior to further use if--\ntested and inspected in acrordance with this sec.\ncylinder manufactured of aluminum alloy 6851-\nbreathing apparatus (SCUBA), self-contained.\nin self-contained underwater\nues. This may be accomplished by bringing\nder's pressure and corresponding expansion v\nrosion, cracked or abraded areas, leakage, ther-\n(1) The cylinder shows evidence of dents. cor-\nmust be inspected for sustained load cracking in:\nbreathing apparatus (SCBA), or oxygen service\ntificate for the calibrated cylinder used and v\npressure to a value shown on the calibration c\n• render it unsafe for use in transportation;\nmal damage, or any other condition that might\naccordance with Appendix C of this part at the\nifying that the resulting total expansion\nter January 1, 2007, and every five years there-\nfirst scheduled 5-year requalification period af-\nthe calibration certificate. Alternatively, es\nwithin *1.0% of the total expansion shown\nhas been damaged to an extent that may ad-\n(2) The cylinder has been in an accident and\nbration may be demonstrated by bringing the\nversely affect its lading retention capability;\nto have been over-heated; or\n(3) The cylinder shows evidence of or is known\ned, each cylinder required to be retested under\n(g) Pressure lest. (1) Unless otherwise provid-\nused and verifying that the resulting pressure\nedibration certificate for the calibrated cylinc\nthat the cylinder may be in an unsafe condition.\n(4) The Associate Administrator determines\nthis subpart must he retested by means suitable?\nder pressure. Bands and other removable ati\nfor measuring the expansion of the cylinder un-\nbration certificate. The calibrated cylinder mi\nwithin +1.0% of the pressure shown on the ca\nliquids. A cylinder previously containing a Class\n(e) Cylinders containing Class 8 (corrosive)\ntachments must be loosened or removed before\nwhow no permanent expansion. The retes\ntesting so that the cylinder is free to expand in\nmust demonstrate calibration in conformar\na Class 2 material in commerce unless the cylin-\n8 (corrosive) liquid may not be used to transport\ntor on any day that it retests cylinders. A rete\nwith this paragraph (g) to an authorized insp\ning apparatus must permit reading of pressurel\n(2) The pressure indicating device of the test\nin conformance with § 180.215(b)(4).\nor must maintain calibrated cylinder certificat\nnally, in accordance with paragraph (f) of this\n(1) Visually inspected, internally and exter-\nto within 1% of the minimum prescribed teal\npressure of each cylinder tested, except that for\ntumed for at least 30 seconds, and as long as n\n15) Minimum test pressure must be ma\nsection and the inspection is recorded as pre-\nmarked gauge divisions is acceptable. The ox\nan analog device.\ninterpolation to ½ of\nth\nscribed in $ 180.216;\naystem check may be performed at or below 9\nenary for complete expansion of the cylinder\ntion. regardless of the\n(2) Requalified in accordance with this sec-\nrequalification;\ndate of the previous\npansion-indicating device of the testing appard\ncylinder expansion to 1% of the total expansio\ntus must also permit incremental reading of th\n\" malfunction of the teat equipment, the te\nuf lent pressure prior to the retest. In the case\n(4) Decontaminated to remove all significant\n(3) Marked in accordance with § 180.213; and\nof each cylinder tested or 0.1 ce, whichever\nit 100 psig, whichever in less. This paragraph\nmay be repeated at a pressure increased by 10\nresidue or impregnation of the Class 8 material.\nlarger. Midpoint visual interpolation is permi\ndors not authorize retent of a cylinder otherw\nvided in this subpart, cach\n(f) Visual inspection. Except as otherwise pro-\nshall confirm, by using a calibrated cylinder of\n(3) Each day before retesting. the retente\nmgured to be condemned under paragraph (i)\npressure tested, it must be given an internal and\ntime a cylinder is\nthin section.\nother method authorized in writing by the Asm\nIng permons who rogualify cylindere uning !\n(if) Training materials may be uned for tra\nciate Administrator. that:\nvultumetric expansion test method.","truncated":false,"body_characters":19109}