{"operation":"document","citation":"13-0176","title":"HSB Global Standards — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2013-11-19","effective_on":null,"summary":"13-0176 response to HSB Global Standards concerning 178.57.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0176.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0176.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0176","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2013/130176.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\nNOV 1 9 20tl\nMr. Oberst Mulet\nHSB Global Standards\nOne State Street\nP.O. Box 299\nHartford, CT 53403-5011\nRef. No. 13-0176\nDear Mr. Mulet:\nThis responds to your August 22, 2013 email regarding physical testing of DOT\nSpecification 4L cylinders under the Hazardous Materials Regulations (HMR; 49 CFR\nParts I 71-180). You note that for most of the DOT Specification \"300 series and 400\"\nseries cylinders, when physical testing of specimens is required, the specimen must\nconform to the following:\n\"A gauge length of8 inches with a width not over I \\'2 inches, a gauge length of2 inches with width\nnot over 1 Yz inches, or a gauge length at least 24 times thickness with a width not over 6 times\n3\nthickness (authorized when cylinder wall is not over\n/ 16 inch thick).\"\nYou fmiher note, however, that for physical testing of DOT Specification 4L cylinders\nunder§ 178.57(j)(2)(i), the criterion for the cylinder wall is \"not over\n1\n/ 16 inch thick.\" You\nask whether this value is correct or whether it should read \"not over 3 I 16 inch thick\"\nconsistent with the value for other DOT specification cylinders.\nThe criterion for the cylinder wall should read ''not over 3/ 16 inch thick.\" Under rulemaking\nHM-220B (61 FR 25940; May 23, 1996), we restructured the cylinder specification\nrequirements by consolidating repetitive requirements and implementing other formatting\nchanges. In doing so, for a DOT Specification 4L cylinder, the cylinder wall thickness\nvalue was inadvertently changed to 'd/16 inch.\" Prior to HM-220B, the value had been 'd/16\ninch\" consistent with the other DOT specifications. We thank you for bringing this matter\nto our attention. PHMSA will revise this language in a future rulemaking.\nI hope this information is helpful. If you have further questions, please contact this office.\nSincerely,\n/~0~\nRobert Benedict\nChief, Standards Development Branch\nStandards and Rulemaking Division\n-------------------\n\n<<<PAGE 2>>>\n\nber kt~deven\n§ 11'6. 51Q)Cz]J\nDrakeford, Carolyn (PHMSA)\nFrom:\nSent:\nTo:\nCc:\nSubject: Betts, Charles (PHMSA)\nFriday, August 23, 2013 10:57 AM\nDrakeford, Carolyn (PHMSA)\n1'--3 -o 11 ~\nCassidy, Duane (PHMSA)\nFW: 4BW Cylinder specification 178.57U)(2)(i) Specimens dimensions for physical testing.\n~Jinder:s\nImportance: High\nCarolyn-\nPlease log and assign to a specialist for handling.\nThanks,\nCharles\nFrom: Mulet Oberst - Hartford-HSBCT [mailto:oberst mulet@hsbct.com]\nSent: Thursday, August 22, 2013 4:57PM\nTo: cassidy, Duane (PHMSA)\nSubject: 4BW Cylinder specification 178.57(j)(2)(i) Specimens dimensions for physical testing.\nDear Mr. Cassidy:\nI hope you are doing well. I have the following question concerning paragraph 178.57(j)(2)(i) of the 49 CFR Transportation.\nFor 300 series and 400 series cylinders specifications, when required, the conditions for obtaining a specimen from a\ncylinder or sphere for the required physical testing, one of the options among others is as follows:\n\"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-\n1.12 inches, or a gauge length of at least 24 times the thickness with a width not over 6 times thickness is authorized when\na cylinder wall is not over 3/16 inch thick.\"\nWhile for 4L Cylinder Specifications the requirement reads:\n178.57(j)(2)(i)\n\"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\ninches, or a gauge length at least 24 times thickness with a width not over 6 times thickness (authorized when cylinder\nwall is not over 1/16 inch thick).\"\nMy question is: For 4L cylinder specification is the one-sixteenth (1/16) inch the correct value and not three-sixteenth\n(3/16) inch?\nI have searched the regulation and 4L is the only specification I found with this requirements and I thought it was possibly\na mistake therefore I am requesting your corroboration. Thank you in advance.\nRegards;\nOberst Mulet\nEngineer II\nHSB ·Global Standards\nONE STATE STREET\n1\n\n<<<PAGE 3>>>\n\nP.O. BOX 299\nHARTFORD, CT 06416-0299\nT: (860) 722-5528\nF: (860) 722-5705\n- HSBGiobaiStandards.com\nOberst Mulet@hsbct.com\nThe information contained in this e-mail, including any attachment(s), is intended solely for use by the named\naddressee(s). If you are not the intended recipient, or a person designated as responsible for delivering such messages to\nthe intended recipient, you are not authorized to disclose, copy, distribute or retain this message, in whole or in part, without\nwritten authorization from HSB CT. This e-mail may contain proprietary, confidential or privileged information. If you have\nreceived this message in error, please notify the sender immediately. Thank you for your cooperation.\nIMPORTANT NOTICE:\nThe information in this email (and any attachments hereto) is confidential. If you are not the intended recipient,\nyou must not use or disseminate the information. If you have received this email in error, please immediately\nnotify me by \"Reply\" command and permanently delete the original and any copies or printouts thereof.\nAlthough this email and any attachments are believed to be free of any virus or other defect that might affect any\ncomputer system into which it is received and opened, it is the responsibility of the recipient to ensure that it is\nvirus free and no responsibility is accepted by Global Standards, LLC or its subsidiaries or affiliates either jointly\nor severally, for any loss or damage arising in any way from its use.\n2","truncated":false,"body_characters":5632}