{"operation":"document","citation":"14-0112","title":"Hydro-Test Products, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2014-09-18","effective_on":null,"summary":"14-0112 response to Hydro-Test Products, Inc. concerning 180.205.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-14-0112.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-14-0112.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-14-0112","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2014/140112.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\naterials Safe\npeline and Hazardo\nAdministration\nSEP 1 8 2014\nMr. Tom Sauta\nHydro-Test Products, Inc.\n85 Hudson Road\nStow, MA 01775\nRef. No. 14-0112\nDear Mr. Sauta:\nThis responds to your April 15, 2014 letter requesting clarification of the cylinder pressure\ntesting requirements under § 180.205(g) of the Hazardous Materials Regulations (HMR; 49\nCFR Parts 171-180). Specifically, you request clarification of the required accuracy for the\npressure gauges used with retest equipment in relation to § 180.205(g)(3)(i).\nAccording to your letter, a representative of an approved Independent Inspection Agency has\nquestioned the accuracy of the pressure gauges used with your retest equipment and whether\nit conforms to § 180.205(g)(3)(i). The representative claims the gauges cannot be used in the\nranges you specify for purposes of HMR requalification because they do not meet the\nrequirements of section 5.3.22 of Compressed Gas Association (CGA) Pamplet\nC-1, Methods for Pressure Testing Compressed Gas Cylinders, 10\" Ed., July 2009. You\ndisagree with the claim because you believe this section confuses readability and accuracy\nrequirements and also because CGA Pamphlet C-1 is not specifically referenced for use under\nthe HMR. You request confirmation that the calibration data for your equipment that is\nprovided in your letter conforms to § 180.205(g)(3)(i) for the pressure gauges used in the\npressure test under § 180.205(g); and that CGA Pamphlet C-1 is not an enforceable reference\ndocument under the HMR.\nBased on the information provided in your letter, it is the opinion of this Office that the\naccuracy of the pressure gauges used with your retest equipment conforms to § 180.205(g),\nspecifically, § 180.205(g)(3)(i). This provision requires that each day before retesting, the\nretester must confirm that the pressure-indicating device (i.e., the pressure gauge), as part of\nthe retest equipment, is accurate within ‡1.0% of the prescribed test pressure of any cylinder\ntested that day. The pressure gauge, itself, must be certified as having an accuracy of +0.5%,\nor better, of its full range, and must permit readings of pressure from 90%-110% of the\nminimum prescribed test pressure of the cylinder to be tested. The accuracy of the pressure\nindicating device within the test system can be demonstrated at any point within 500 psig of\nthe actual test pressure for test pressures at or above 3,000 psig, or 10% of the actual test\npressure for test pressures below 3,000 psig.\nFurthermore, your understanding regarding CGA Pamphlet C-1 is correct. The document is\nnot incorporated by reference and, therefore, is not a material made part of the regulations\n\n<<<PAGE 2>>>\n\nunder the HMR and not enforceable. However, note that we have received and approved a\npetiton [P-1626] to incorporate by reference CGA Pamphlet C-1 in a future rulemaking.\nI hope this information is helpful. If you have further questions, please contact this office.\nActing Chief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\nDer Kinderen\n:\n3180.205 (g) ()i)\nPage 1 of 1\nApril 15, 2014\nCylinders\nMr. Charles E. Betts\n14-0112\nDirector, Standards and Rulemaking Division\nU.S. DOT/PHMSA (PHH-10)\n1200 New Jersey Avenue, SE East Building, 2nd Floor\nWashington, DC 20590\nRe: Request for written interpretation and clarification\nHydro-Test Products is a leading manufacturer of compressed gas cylinder re-qualification equipment since 1972. We\nhave recently been questioned by one of your licensed Independent Inspectors about the accuracy of the pressure\ngauges that we currently utilize in our cylinder retest equipment and whether they confirm to CFR Title49\n§180.205(g)(3)(i). The pressure gauges in question are dial gauges with the following attributes:\nRef#\nRange (psi)\nIncrements(psi)\nManufactured Full\nrange accuracy\nSpecific points (ps) calibrated to 0.5% accuracy*)\nA\n0-1100\n2.0\n0.5%\n100,200,350,400,500,600,700,800,900,1000\n0-1500\n2.0\n0.25%\n100,200,350,400,500,600,700,800,900,1000,1200,1400\n0-5000\n10.0\n0.25%\n500,1000,2000,3000,4000,5000\nD\n0-10,000\n20.0\n0.25%\n1000,2000,3000,4000,5000,6000,7000,8000,9000,10,000\n(*) We supply a calibration certificate showing the specific psi points of calibration and the accuracy at those points.\nThe calibration is performed utilizing a digital gauge with an accuracy of 0.05% traceable to N.I.S.T. standards.\nWe utilize the pressure gauges for the following test range(s):\nGauge Ref#\nUsable Test Range (incorporating the requirement to permit reading of 90-110% of test pressure)\nA\n111-1000 psi\n111-1350 psi\nC\n550-4500 psi\nD\n1120-10,000 psi\nThe inspector in question is stating that these gauges cannot be used in the range that we specify because of the 2009\nedition of the Compressed Gas Association pamphlet C-1 section 5.3.22. This section is inaccurate because it is\nconfusing the readability and accuracy requirements and does not take into account the calibration at specific psi\npoints. Furthermore, the CGA pamphlet C-1 is not cited as a required document under CFR Title49 §171.7 and should\nnot be used as reference by an independent inspector or an enforcement inspector during an audit of a retest facility.\nI am requesting that you review the above and confirm that our pressure gauges are in conformance with CFR Title49\n$180.205(g)(3)(i) and that you are not condoning the use or reference of the C-1 pamphlet.\nThank you for your attention to this inquiry and I would appreciate an expedited reply.\nBest regards,\nTom Sauda\nTom Sauta\nHydro-Test Products Inc.\nTel: 978-897-4647 x13\nHydro-Test Products Inc.\nHYDRO-TEST\n85 Hudson Road Stow, Massachusetis 01775\nUSA\n004GTY8F\nTel: 800-225-9488 / 978-897-4647\nFax: 978-897-1942\nDirect email: tom@hydro-test.com","truncated":false,"body_characters":5829}