# Western Sales and Testing of Amarillo, Inc. — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 14-0094
- **title:** Western Sales and Testing of Amarillo, Inc. — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2014-10-22
- **effective on:** Not available
- **summary:** 14-0094 response to Western Sales and Testing of Amarillo, Inc. concerning 171.8, 180.207.
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-14-0094.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-14-0094
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2014/140094.pdf
**body:**

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U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Avenue, SE
Washington, D.C. 20590
OCT 2 2 2014
Mr. Mark Griffin
Western Sales and Testing of Amarillo, Inc.
114 E. 461h, P.O. Box 2446
Amarillo, TX 79105
Ref. No. 14-0094
Dear Mr. Griffin:
This responds to your May 13, 2014letter requesting further clarification of the
requalification requirements for a seamless steel UN pressure receptacle under
§ 180.207(d)(l) ofthe Hazardous Materials Regulations (HMR; 49 CFR Parts 171 -180)
Wifn respecno guia ance offerea. ~lnJ.ettef() f interpretat ion (COIJRe ; 0. n = m37 Issued
December 13, 2013. Your questions are paraphrased and answered as follows:
Ql. Based on the PHMSA response in the above-referenced letter that "PHMSA
adopted language that required requalification 1 in accordance with ISO 6406 or
procedures approved by the Associate Administrator," is our understanding correct that
other test methods (e.g., acoustic emissions) may be used if approved by the Associate
Administrator and that the approval should be obtained through the special permit
process?
A 1. Your understanding is not entirely correct. It is correct that other test methods may
be used upon approval. The language you quote from the letter was adopted under a
final rule published June 12, 2006 (HM-220E; 71 FR 33870) and was subsequently
revised under a final rule published September 14, 2006 (HM-189Z; 54397). The latter
rule removed the language allowing alternate procedures under an approval as it was
repetitive. We already allowed for alternative test methods or requalification procedures
if a prior approval has been obtained from the Associate Administrator (see § 180.207
paragraph (d) introductory text). Further, a UN/ISO pressure receptacle must be
requalified in accordance with the relevant ISO standards that are listed in
§ 180.207. For example, UN/ISO 9809-1 , -2, and -3 pressure receptacles (e.g.,
cylinders) must be requalified in accordance with ISO 6406.
It is incorrect that an approval is obtained through the special permit process. A special
permit differs from an approval in that it is a document issued by the Associate
Administrator letting you perform a function not otherwise permitted by the HMR;
whereas an approval is written authorization to perform a function that requires prior
authorization by the Associate Administrator (see § 171 .8). The approval process is
spelled out in 49 CFR Part 107, Subpart H, and specifically, the application for Part 107
1 The requalification applies to a UN/ISO pressure receptacle.

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approval is set out in§ 107.705. Note that, if you already have a special permit for
requalification of DOT specification cylinders using ultrasonic examination (UE) and
you are in need of applying ISO 6406 for requalifi'cation of UN/ISO 9809-1, -2, and -3
pressure receptacles, then you can submit an application for revision of your UE special
permit to include the UN/ISO 9809-1, -2, and -3 cylinders to the office of Special
Permits and Approvals.
Q2. With regard to use ofthe terms UN pressure receptacle, UN cylinder, and UN tube,
is our understanding correct that the requirement for UE applies only to UN cylinders
with a tensile strength 2: 950 MPa and does not apply to UN tubes; and that actually all
of§ 180.207(d)(l) applies only to UN cylinders because ISO 6406 is limited in scope to
UN cylinders with a water capacity not exceeding 150 L?
A2. Again, your understanding is not entirely correct. It is correct that the UN cylinders
with a tensile strength 2: 950 MPa must be requalified by UE described in ISO 6406.
The UN cylinders with a tensile strength< 950 MPa may be requalified by hydrostatic
testing or UE described in ISO 6406. However, it is not correct that the
§ 180.207(d)(1) general requirement for requalification using ISO 6406 applies only to
---
..,_,-c = y -,-, Illilers. We refer you to LOI Ref. No. 13-0146 issued January 16,2014, which
states, "while ISO 6406 does not specifically address requalification of UN tubes, all of
the elements associated with the periodic requalification of seamless steel UN tubes are
addressed and would allow a proper requalification of a UN tube" and further states,
"[w]e are aware that the current ISO 6406 has a limitation of 150 liters, which is
substantially less than the maximum volume of a UN refillable seamless steel tube
(3,000 liters) ... [u]ntil we adopt a revised standard that specifically addresses the
requalification of UN refillable seamless steel tubes, the currently adopted ISO 6406
may be used to requalify UN refillable seamless steel tubes (with a [water] capacity
greater than 150 liters). A copy of the LOI Ref. No. 13-0146 is enclosed for your
review.
I hope this information is helpful. If you have further questions, please contact this office.
Sincerely,
Chief, Standards Development Branch
Standards and Rulemaking Division

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P.O. Box 2446 Amarillo, TX 79105 (806) 373-6811 Fax (806) 373-5971 114 E. 46th St.
E-MAIL TRANSMISSION
ATTN: Robert.Benedict@dot.gov
May 13,2014
U.S. DOT
PHMSA Office of Hazardous Materials Standards
U.S. Department of Transportation
Attn: PHH-1 0
1200 New Jersey Avenue, SE
Washington, D.C. 20590-0001
---
RefNo. 13-0137
Dear Mr. Benedict,
Regarding the PHMSA response ofDecember 13,2013, (Ref. No. 13-0137), to our request for
clarification of section 180.207 (d) (1) of CFR49, we submit the following request for further
amplification.
PHMSA response states, "PHMSA adopted language that required requalification in accordance
with ISO 6406 or procedures approved by the Associate Administrator."
• Are we correct in inferring that this statement means that other test methods, (i.e.,
Acoustic Emission!UT combination), may be utilized if approved by the Associate
Administrator, and that the approval should be sought through the Special Permit
process?
Additionally, we seek clarification on the specific wording of §180.207 (d) (1). We are
specifically interested in the following sentence.
• "However, UN cylinders with a tensile strength greater than or equal to 950 MPa must be
requalified by ultrasonic examination in accordance with ISO 6406."
§ 171.8 of CFR49, provides definitions for UN cylinders, UN pressure receptacles, and UN tubes
as follows.
• "UN cylinder means a transportable pressure receptacle with a water capacity not
exceeding 150L that has been marked and certified as conforming to the applicable
requirements in part 178 of this subchapter."

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• "UN pressure receptacle means a UN cylinder or tube."
• "UN tube means a seamless transportable pressure receptacle with water capacity
exceeding 150L but not more than 3,000L that has been marked and certified as
conforming to the requirements in part 178 of this subchapter."
§180.207 (d) (1) states, "Seamless steel: Each seamless steel UN pressure receptacle, including
MEGC's pressure receptacles, must be requalified in accordance with ISO 6406 (IBR, see § 171.7
of this subchapter). However, UN cylinders with a tensile strength greater than or equal to 950
MPa must be requalified by ultrasonic examination in accordance with ISO 6406."
Based upon the incorporated definitions, and the fact that ISO 6406-2005 is specifically limited
in scope to cylinders of water capacity from 0.5L up to 150L are we,
• Correct in our conclusion that the requirement for ultrasonic examination applies only to
UN cylinders with a tensile strength 2:950 MPa and does not apply to UN tubes of water
capacity greater than 150L but less than 3,000L?
_ _..__
. £w.:ther, si-nce~I£0--640o-2QQ~- is-limitea- in-seepe- to (}yl-incl.ers~ef-water -eapaeity -less~than
150L, are we correct in concluding that ISO 6406-2005 is in fact not applicable to the
requalification of pressure receptacles of water capacity greater than 150L, but less than
3,000L as far as§ 180.207 (d) regulatory requirements are concerned and/or interpreted?
Executive Vice President
Western Sales and Testing of Amarillo, Inc.
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