Gayston Corporation — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Washington, DC 20590 1200 New Jersey Avenue, SE Safety Administration MAR 2 5 2015 Christopher A. Cornelius Gayston Corporation Director of Quality 200 Advance Drive Springboro, OH 45066 Reference No. 14-0147 Dear Dr. Cornelius: This is in response to your July 21, 2014 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the calculation of the tare weight of cylinders. Specifically, you seek an interpretation of § 178.35(c)(3)(vii) as it pertains to the process by which you report the tare weight and volumetric capacity of a specification cylinder during the manufacturing process. In your incoming letter, you propose to determine the tare weight of the cylinder prior to conducting the hydrostatic testing. This information is collected and summarized by a lot code and the highest tare weight (i.e. the heaviest part) would then be used to determine the volumetric capacity for the entire lot of cylinders. You ask if it is permissible to gather the tare weight prior to hydrostatic testing. The answer is yes. The HMR does not specify when in the manufacturing process the tare weight of the cylinder must be determined. Determining the tare weight of the cylinder prior to conducting the hydrostatic test is not prohibited. In addition, using the maximum tare weight in a specific lot as the marked tare weight is not forbidden provided that the tare weight and volumetric capacity measured under § 178.35(c)(3)(vii) are accurate and not affected by any other test conducted on the cylinder. However, caution is advised since marking the cylinder with the maximum tare weight instead of the actual weight could result in cylinder underfilling, errors during requalification, or other recordkeeping issues. I hope this satisfies your request. Sincerely, TAlenn roste T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2Andrews 178.35()(3Xvi) Dodd, Alice (PHMSA) Cylinders From: 14-0147 Sent: Ciccarone, Michael CTR (PHMSA) To: Monday, July 21, 2014 4:20 PM Hazmat Interps Subject: Attachments: FW: Interpretation of 49 CFR $ 178.35 (c) (3) (vii) Gayston - 49 CFR $ 178.35 (c) (3) (vii).pdf Shante and Alice, Please submit this for a formal letter of interpretation. Thanks, Mike From: Chris Cornelius [mailto:ccornelius@gayston.com] To: PHMSA HM InfoCenter Sent: Monday, July 21, 2014 4:10 PM Subject: Interpretation of 49 CFR § 178.35 (c) (3) (vii) To Whom It May Concern, Please find my attached letter of formal request of interpretation of 49 CFR § 178.35 (c) (3) (vii). I look forward to your decision. Thank you, GAYSTON CORPORATION Christopher A. Cornelius // Director of Quality Gayston Corporation // 200 Advanced Dr // Springboro, OH 45066 Mobile: 937.603.9411 // Office: 937.790.4576#

Page 3Gayston Corporation 200 Advanced Way Springboro, Ohio 45066-0430 July 21, 2014 US DOT PHMSA Office of Hazardous Materials Standards Attn: PHH-10 East Building 1200 New Jersey Avenue, SE Washington, DC 20590-0001 Dear Sir or Madam: Gayston Corporation (M4625) is seeking formal interpretation of 49 CFR §178.35(c) (3) (vii) as it pertains to the process by which we gather tare weight and calculate the volumetric capacity of our cylinders. Our hydrostatic testing. This information will be collected and summarized by lot code and the highest tare proposal is to move the location for gathering tare weigh to the final machining operation, prior to weight (i.e. heaviest part) will then be used to determine the volumetric capacity for the entire lot of cylinders. We will still gather individual full-weight measurements post hydrostatic testing and use the lot-specific tare weight to determine the volumetric capacity for our cylinders. Gaston Corporation feels that this will result in a method that is fair and accurate representation of our cylinders volumetric capacity as well as being a more efficient manufacturing process. Respectfully, Christopher A. Cornelius Director of Quality#