Guidanceguidance
14-0123
Guerrilla Air/ Tiberius Arms — Hazardous Materials Safety Interpretation
Current as of source date Government source
RegulusPipeline researchRegulusPipeline research14-0123
Page 1of Transportation U.S. Department 1200 New Jersey Avenue, SE Washington, D.C. 20590 Pipeline and Hazardous Materials Safety Administration NOV D 3 2014 Mr. Gio Islas Guerrilla Air/Tiberius Arms 2717 West Ferguson Road Fort Wayne, IN 46809 Reference No. 14-0123 Dear Mr. Islas: This is in response to your recent e-mail to the Pipeline and Hazardous Materials Safety Administration (PHMSA) Hazardous Materials Information Center requesting clarification on how to properly handle and fill United Nations (UN) International Organization for Standardization (ISO) Standard 11119-2 carbon fiber composite cylinders with a steel liner under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if PHMSA can explain the handling and filling requirements this cylinder must comply with under the HMR. You state your company imports these ISO cylinders into the United States and some of your customers use them when scuba diving. You also state some of your customers reported they have difficulty getting these cylinders refilled because some workers at refill facilities state they are not familiar with these cylinders. In addition, you state your customers report cylinder refillers state they will refill your customers' cylinders only if they are marked with a Department of Transportation Special Permit (DOT-SP) or Competent Authority (CA) number. Further, you included a photograph of the following markings on a UN ISO Standard 11119-2 carbon fiber cylinder: 0.625x 18UNF TW AMS BB01058 PW310 PH465BAR 0.95 KG 1.10L 0029 USA/M0812 IA18 • ISO11119-2 B B 2011/12 Canada SU 10070 Equivalency [Obscured text] icate A cylinder designed and constructed in conformance with the applicable requirements prescribed in 49 CFR 178.70, 178.71 (a) and 178.71(1) for an ISO Standard 11119-2 is a UN standard fibre-reinforced, composite gas cylinder with a load sharing metal liner. Cylinders that are fully in conformance with ISO 11119-2 do not require a DOT-SP or CA Approval. To certify that these cylinders are an authorized UN standard packaging, manufacturers mark them in conformance with § 178.71(p), (g), and (r). The mark you provided complies with#
Page 2this requirement, except we note that it does not appear to include the "UW" mark prescribed in §§ 173.301b(g), 178.71(1)(2) and (P)(18) for composite cylinders certified to ISO-11119-2 intended for underwater use. Customers who intend to use these types of cylinders for underwater use should be made aware of this requirement. An ISO Standard 11119-2 cylinder that varies from this design is not an authorized packaging in the United States until its variations are reviewed and approved by PHMSA's Associate Administrator for Hazardous Materials Safety in the form of a DOT-SP or CA. The cylinder must be marked with the DOT-SP or CA number if the DOT-SP or CA requires that it be marked with that number; otherwise, the marking of that number is not required. In addition, the HMR require ISO Standard 11119-2 cylinders to be refilled in conformance with §§ 173.301, 173.301b, 173.304b; and periodically retested in conformance with § 180.205. I hope this satisfies your request. Sincerely, T. Glenn Foster Chiet, Regulatory Review and Reinvention Branch Standards and Rulemaking Division 2#
Page 3amonsor Dodd, Alice (PHMSA) pecification to resome necestac From: INFOCNTR (PHMSA) #14-0123 Sent: Friday, June 20, 2014 4:12 PM To: Hazmat Interps Subject: FW: Guerrilla Air System Attachments: 68-45K ISO11119-2.png I spoke with this caller, and he would like this letter submitted as a formal letter of interpretation. Thanks, Victoria From: Gio [mailto:gislas@tiberiusarms.com] Sent: Friday, June 20, 2014 2:20 PM To: INFOCNTR (PHMSA) Subject: RE: Guerrilla Air System Cc: 'guns'; 'Info'; 'Dianne Jugan' Hello, My name is Gio with Guerrilla Air / Tiberius Arms. As of right now we are an importer of UN ISO certified Carbon Fiber tanks in the United States for the past 2 years. Every once in a while we have customer with our UN tanks and they are not able to get their tank fill since the shop/field is not familiar with UN certifications. Most paintball shops, or scuba shops cannot fill a tank if they do not see a DOT number. To avoid this issues and educate shops I require your help. Is it possible if you can write a letter stating the status, and procedures in handling a UN certified tank? It is a UN ISO11119-2 Third party DOT approval number is M0812 See attached image for reference. Please advise and let me know if you have any questions or require additional information. Thank You GIO ISLAS 2717 W Ferguson Road T: 260-478-2500 x 252 Fort Wayne, IN 46809 F:260-572-2210 SKYPE: gio.islas24 From: Dianne Jugan [mailto:djugan@y-kiki.com] To: Gio Islas Sent: Thursday, June 05, 2014 3:09 PM 1#
Page 4Co: guns; Info Subject: Re: Guerrilla Air System I will need a letter from your contact at DOT addressed to me stating that I can fill this tank. Do not send links to a bunch of different websites. I will retest and fill these tanks only if I get a letter from DOT. Thank you, Mark Jugan On Thu, Jun 5, 2014 at 9:36 AM, Gio Islas <gislas@tiberiusarms.com> wrote: Augie, I haven't heard back from Mark. Mark feel free to call me for any questions. 260-478-2500 x252 Thank You GIO ISLAS ETO 2717 W Ferguson Road Fort Wayne, IN 46809 T: 260-478-2500x252 F:260-572-2210 SKYPE: gio.islas24 From: guns [mailto:guns@cruxsystems.com] Sent: Thursday, June 05, 2014 10:28 AM 2#
Page 5To: "Gio Islas'; info@y-kiki.com Subject: RE: Guerrilla Air System Hi All, Has there been any update on this? Thanks, Augie From: Gio Islas [mailto: gislas@tiberiusarms.com] Sent: Thursday, May 29, 2014 11:30 AM To: info@y-kiki.com Subject: RE: Guerrilla Air System Cc: guns@cruxsystems.com Mark, Please let me know your contact at the Department of Transportation. We would really like to help this customer of ours. Information below is sufficient, and not sure why your contact at the DOT is not complying. I called the DOT of transportation and by referencing UN ISO 11119.2, he knew right away of what I was talking about. For more information he provided the following links. http://www.gpo.gov/fdsys/granule/CPR-2011-title49-vol3/CFR-2011-title49-vol3-sec178-71 Under section 178.71 it states the following. http://www.gpo.gov/fdsys/pkg/CFR-2011-title49-vol3/pdf/CFR-2011-title49-vol3-sec178-71.pdf More documentation. 3#
Page 6http://www.gpo.gov/fdsys/pkg/CFR-2011-title49-vol3/pdf/CFR-2011-title49-vo13-sec178-70.pdf As you can see our tanks have the correct markings, specifications and proper approval. caine shopted thousands of these types of tanks into the US since 2012, and with the proper information or Please advise your thoughts. Thank You GIO ISLAS 2717 W Ferguson Road Fort Wayne, IN 46809 T: 260-478-2500 x 252 F:260-572-2210 SKYPE: gio.islas24 From: Gio Islas [mailto:gislas@tiberiusarms.com] To: info@y-kiki.com' Sent: Friday, May 23, 2014 5:08 PM Cc: 'guns@cruxsystems.com' Subject: Guerrilla Air System Hello Mark, 4#
Page 7"The Guerrilla Air/AMS cylinders are qualify to be filled. Our manufacture DOT approved number is M0812 Sources: http://www.phmsa.dot.gov/portal/site/PHMSA/menuitem.920aaa011db032e5ea19d71708558a0c/? vgnextoid=4 a38272cb3eae010VgnVCM1000008055a8c0RCRD&vgnextchannel-4a38272cb3eae010VgnVCM1000008055 a8c0RCRD&as_q=M0812+ http://www.amsys.com.tw/images_share/dot/DOT-640.jpg After speaking to a representative over at the Department of Transportation, an ISO tank can be tested and be qualified as well. Sources he gave me: http://www.ecfr.gov/cgi-bin/text- idx?c=ecfr&SID=2f9049c3006d245186655fc1d43a61c9&rgn=div8&view-text&node=49:3.1.1.1.3.3.1.4&idno =49 http://phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Files/ISO11119_2DOTCFFC.pdf You will see the UN ISO 11119-2 mark on the tank If you have any additional questions, please feel free to contact the DOT. https://ntl.custhelp.com/app/answers/detail/a_id/22/kw/DOT%20cylinder/session/L3RpbWUvMTM1NzkzMzg xNy9zaWQvbjFpX0oyZ2w%3D Please advise and let me know if you have any questions. 5#
Page 8Thank You GIO ISLAS 2717 W Ferguson Road Fort Wayne, IN 46809 T: 260-478-2500 x 252 F:260-572-2210 SKYPE: gio.islas24#
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