{"operation":"document","citation":"14-0074","title":"HSB Technical Consulting & Service (Shanghai) Co., Ltd — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2014-05-30","effective_on":null,"summary":"14-0074 response to HSB Technical Consulting & Service (Shanghai) Co., Ltd concerning 178.45.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-14-0074.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-14-0074.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-14-0074","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2014/140074.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\nMAY 0 8 2014\nMr. Ruifeng Yin\nAuthorized Inspector\nHSB Technical Consulting & Service (Shanghai) Co., Ltd.\nRoom 909, Tower A, Fareast Int'l Plaza\n319 Xianxia Road, Shanghai, 200051, China\nRef. No.: 14-0074\nDear Mr. Ruifeng Yin:\nThis is in response to your email dated April 6, 2014, requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) relating to the § 178.45(i)(2)\nrequirements for tension and Charpy impact testing of production cylinders. You request\nconfirmation of your understanding that there are two options for cylinders heat treated in a\ncontinuous furnace: 1) tests must be conducted on two tension specimens and three Charpy\nimpact specimens from one cylinder taken from a test lot based on a production period not\nexceeding 200 cylinders; or 2) tests must be conducted on two tension specimens and three\nCharpy specimens from a test ring for each four hours or less of production, provided the test\nlot based on the production period does not exceed 200 cylinders.\nYou are correct.\nIf the required specimens are obtained from a cylinder, the cylinder must be from a test lot\nbased on a production period of not more than 200 cylinders.\nIf the required specimens are obtained from a test ring, each test ring must represent a\nproduction time of four hours or less and the test lot based on the production period must not\nexceed 200 cylinders.\nI trust this information is helpful. If you have further questions, please do not hesitate to\ncontact this office.\nSincerely,\nShane C. Kelley 1\nActing International St · dards Coordinator\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nDrakeford, Carol n PHMSA)\nFrom:\nSent:\nTo:\nCc:\nSubject:\nYin Ruifeng - APAC-Remote-HSBCT <ruifeng_yin@hsbct.com>\nSunday, April 06, 2014 11:49 PM\nINFOCNTR (PHMSA); Drakeford, Carolyn (PHMSA); Lynch, Tom (PHMSA);\nWayne. Chaney@dot. gov\n*$BI\nQuestion about 178.45 (i)(2) interpretation\n~ ,·ndef:r\nIL-l PD01t-j\nDear all\nThis is DOT inspector (Mr. Ruifeng Yin) come from HSBCT. My costumer is Shijiazhuang Enric gas equipment co; ltd.\nThe question is 178.45(i)(2) said When the cylinders are heat treated in a continuous furnace, two tension specimens and\nthree Charpy impact specimens must be tested from one of the cylinders or a test ring from each four hours or less of\nproduction. However, in no case may a test lot based on this production period exceed 200 cylinders.\nMy understanding: there has two options (1) The test is required on 2 specimens and three Charpy impact specimens cut\nfrom 1 cylinder taken at random out of each lot of 200 or less.\n(2) two tension specimens and three Charpy impact specimens must be tested from a test ring from each four hours or less\nof production, in no case may a test lot based on this production period exceed 200 cylinders.\nCould you tell me my understanding is right or wrong?\nRuifeng Yin\nAuthorized Inspector\nHSB Technical Consulting & Service (Shanghai) Co., Ltd.\nl!SB Wnh;tl Slamtunf;;\nROOM 909, TOWER A, FAREAST INT'L PLAZA\n319 XIANXIA ROAD, SHANGHAI200051, CHINA\nC:86-15930159237\nF: 86-21-6235-1972\n!'10NYL.IJ§J?9!QI;>£JJ§t13J!.99r~t§,.£Qt:n\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.\n1\n\n<<<PAGE 3>>>\n\nCONFIDENTIAL\nIn a Sustainable Package Format","truncated":false,"body_characters":4101}