{"operation":"document","citation":"14-0124","title":"HSB Global Standards, 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":null,"summary":"14-0124 response to HSB Global Standards, Inc. concerning 178.57.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-14-0124.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-14-0124.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-14-0124","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2014/140124.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\nOCT 2 2 2014\nMr. Oberst Mulet\nEngineer II\nHSB Global Standards, Inc.\nOne State Street\nP.O. Box 299\nHartford, CT 06416-0299\nRef. No.: 14-0124\nThis responds to your June 23, 2014 letter requesting clarification ofthe Hazardous Materials\nRegulations (HMR; 49 CFR Parts 171-180) applicable to specification 4L welded insulated\ncylinders. Specifically, in your letter you cite § 178.57(h), which states that:\n(h) Openings in cylinder. Openings in cylinders must conform to the following:\n(1) Openings are permitted in heads only. They must be circular and may not exceed 3\ninches in diameter or one third of the cylinder diameter, whichever is less. Each\nopening in the cylinder must be provided with a fitting, boss or pad, either integral\nwith, or securely attached to, the cylinder body by fusion welding. Attachments to a\nfitting, boss or pad may be made by welding, brazing, mechanical attachment, or\nthreading.\n(2) Threads must comply with the following:\n(i) (ii) Threads must be clean-cut, even, without checks and cut to gauge.\nTaper threads to be of a length not less than that specified for NPT.\n(iii) Straight threads must have at least 4 engaged threads, tight fit and calculated\nshear strength at least 1 0 times the test pressure of the cylinder. Gaskets, which\nprevent leakage and are inert to the hazardous material, are required.\nIn your letter, you ask whether the opening diameter is defined as the opening diameter made\nto the cylinder body before being provided with a fitting or boss? Or, is the opening defined\nas the inside diameter of the fitting or boss after attached to the cylinder body by fusion\nwelding?\n\n<<<PAGE 2>>>\n\nAs provided in§ 178.57(h) of the HMR, the limit on the opening size described in\nparagraph (h) is the opening on the cylinder head, before a fitting, boss, or pad is applied.\nFurthermore, an opening that is not a proper size could affect the stresses in the cylinder head.\nI trust this satisfies your inquiry. Please contact us if we can be of further assistance.\nSincerely,\n------7/~~~\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n2\n\n<<<PAGE 3>>>\n\n1'\\. ' c'tels\n\\ 'l§.<S1\nc_i \\, ~~~e.rs\nDodd, Alice (PHMSA)\nFrom:\nSent:\nTo:\nSubject: lL\\-0\\Q~\nINFOCNTR (PH MSA)\nMonday, June 23, 2014 3:5 5 PM\nHazmat Interps\nF W: 178.57 Specification 4L welded insulated cylinders, opening size definition.\nThis caller requested we submit this e-mail for a formal letter of interpretation. I previously spoke with this caller in the\nHMIC and received guidance from Cheryl Freeman regarding this issue. Thanks, Victoria\nFrom: Mulet Oberst - Hartford-HSBCT [mailto:oberst mulet@hsbct.com]\nSent: Wednesday, June 11, 2014 8:00AM\nTo: INFOCNTR (PHMSA)\nSubject: 178.57 Specification 4L welded insulated cylinders, opening size definition.\nDear PHMSA representative:\nI have the following question pertaining to opening size definition in 178.57 Specification for 4L welded cylinders. In\nparagraph 178.57(h) of the 49 CFR Transportation, it refers to openings that are permitted in heads only. This paragraph\nprovides t h_e_m.ax.i.mum_o p_e.ning_\n.cham.e.te.r ..size re q' Ji r.e.men.t..o.f_su ch openings-a n.d i.t..aJso....s.ta.tes t h<~.t -eaGh o p€ n i ng - mY.st -\nbe provided with a fitting, boss or pad, either integral with, or secure ly attached to, the cylinder body by fusion welding.\nIt is not clear as to what is considered to be the opening size. Is the opening diameter defined as the opening diameter\nmade to the cylinder body before being provided with a fitting or boss? Or is the opening defined as the inside diameter\nof the fitting or boss after attached to the cylinder body by fusion welding? I appreciate your reply on this matter. Thank\nyou .\nRegards;\nOberst Mulet\nEngineer II\n~J SB 'f\"Ciobnl St;md<tl'th;\nONE STATE STREET\nP.O. BOX 299\nHARTFORD, CT 06416-0299\nT: (860) 722-5528\nF: (860) 722-5705\nHSBGiobaiStandards.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\nto the intended recipient, you are not authorized to disclose, copy, distribute or retain this message, in whole or in part,\nwithout written authorization from HSB CT This e-mail may contain proprietary, confidential or privileged information. If\nyou have received this message in error, please notify the sender immediately. Thank you for your cooperation .\nIMPORTANT NOTICE:\nThe info rmation in thi s emai l (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\nA lthough this email and any attachments are believed to be free of any virus or other defect that might affect\nany computer system into which it is received and opened, it is the responsibi lity of the recipient to ensure that\n1\n\n<<<PAGE 4>>>\n\nit is virus free and no responsibi lity is accepted by Global Standards, LLC or its subsidiaries or affi liates either\njointly or severally, for any loss or damage arising in any way from its use.\n2","truncated":false,"body_characters":5470}