HSB Global Standards — 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 NOV 1 9 20tl Mr. Oberst Mulet HSB Global Standards One State Street P.O. Box 299 Hartford, CT 53403-5011 Ref. No. 13-0176 Dear Mr. Mulet: This responds to your August 22, 2013 email regarding physical testing of DOT Specification 4L cylinders under the Hazardous Materials Regulations (HMR; 49 CFR Parts I 71-180). You note that for most of the DOT Specification "300 series and 400" series cylinders, when physical testing of specimens is required, the specimen must conform to the following: "A gauge length of8 inches with a width not over I \'2 inches, a gauge length of2 inches with width not over 1 Yz inches, or a gauge length at least 24 times thickness with a width not over 6 times 3 thickness (authorized when cylinder wall is not over / 16 inch thick)." You fmiher note, however, that for physical testing of DOT Specification 4L cylinders under§ 178.57(j)(2)(i), the criterion for the cylinder wall is "not over 1 / 16 inch thick." You ask whether this value is correct or whether it should read "not over 3 I 16 inch thick" consistent with the value for other DOT specification cylinders. The criterion for the cylinder wall should read ''not over 3/ 16 inch thick." Under rulemaking HM-220B (61 FR 25940; May 23, 1996), we restructured the cylinder specification requirements by consolidating repetitive requirements and implementing other formatting changes. In doing so, for a DOT Specification 4L cylinder, the cylinder wall thickness value was inadvertently changed to 'd/16 inch." Prior to HM-220B, the value had been 'd/16 inch" consistent with the other DOT specifications. We thank you for bringing this matter to our attention. PHMSA will revise this language in a future rulemaking. I hope this information is helpful. If you have further questions, please contact this office. Sincerely, /~0~ Robert Benedict Chief, Standards Development Branch Standards and Rulemaking Division -------------------#

Page 2ber kt~deven § 11'6. 51Q)Cz]J Drakeford, Carolyn (PHMSA) From: Sent: To: Cc: Subject: Betts, Charles (PHMSA) Friday, August 23, 2013 10:57 AM Drakeford, Carolyn (PHMSA) 1'--3 -o 11 ~ Cassidy, Duane (PHMSA) FW: 4BW Cylinder specification 178.57U)(2)(i) Specimens dimensions for physical testing. ~Jinder:s Importance: High Carolyn- Please log and assign to a specialist for handling. Thanks, Charles From: Mulet Oberst - Hartford-HSBCT [mailto:oberst mulet@hsbct.com] Sent: Thursday, August 22, 2013 4:57PM To: cassidy, Duane (PHMSA) Subject: 4BW Cylinder specification 178.57(j)(2)(i) Specimens dimensions for physical testing. Dear Mr. Cassidy: I hope you are doing well. I have the following question concerning paragraph 178.57(j)(2)(i) of the 49 CFR Transportation. For 300 series and 400 series cylinders specifications, when required, the conditions for obtaining a specimen from a cylinder or sphere for the required physical testing, one of the options among others is as follows: "A gauge length of 8 inches with a width of not over 1-1.12 inches, a gauge length of 2 inches with a width of not over 1- 1.12 inches, or a gauge length of at least 24 times the thickness with a width not over 6 times thickness is authorized when a cylinder wall is not over 3/16 inch thick." While for 4L Cylinder Specifications the requirement reads: 178.57(j)(2)(i) "A gauge length of 8 inches with a width not over 1-1.12 inches, a gauge length of 2 inches with width not over 1-1.12 inches, or a gauge length at least 24 times thickness with a width not over 6 times thickness (authorized when cylinder wall is not over 1/16 inch thick)." My question is: For 4L cylinder specification is the one-sixteenth (1/16) inch the correct value and not three-sixteenth (3/16) inch? I have searched the regulation and 4L is the only specification I found with this requirements and I thought it was possibly a mistake therefore I am requesting your corroboration. Thank you in advance. Regards; Oberst Mulet Engineer II HSB ·Global Standards ONE STATE STREET 1#

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