Japan Aero Pressure Co., Ltd. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 1200 New Jersey Avenue, SE Materials Safety Pipeline and Hazardous Washington, D.C. 20590 Administration JUN 2 9 2016 Mr. Takashi Hashimoto Chief Operating Officer Japan Aero Pressure Co., Ltd. 2-1-8 Kokaba Iwatsuki-ku Saitama-City Saitama 339-0072 Japan Reference No. 15-0174 Dear Mr. Hashimoto: This letter is in response to your email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the marking of cylinders. marking method under § 180.213(c). Specitically, you ask whether chemical etching is an acceptable cylinder requalification The answer is yes. Requalification markings must conform to requirements in § 180.213, including minimal wall thickness and specifications for the marking size and location. Further, each cylinder must be plainly and permanently marked on the metal of the cylinder as permitted by the applicable specification. Provided all applicable conditions are met, the HMR permit the chemical etching of requalification markings on cylinders. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, stern ester -...... T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2Stevens 180.213 Goodall, Shante CTR (PHMSA) From: 15-0174 Sent: Geller, Shelby CTR (PHMSA) To: Monday, August 17, 2015 4:41 PM Subject: Goodall, Shante CTR (PHMSA) RE: Fire extinguisher PN 473951-1 hydrostatic marking by chemical-etching (C977) Hi Shante, I was just following up on the letter of interpretation, because I have not seen it in the database. Please let me know if more information is needed from the requestor. Thanks, Shelby From: Geller, Shelby CTR (PHMSA) To: Goodall, Shante CTR (PHMSA) Sent: Thursday, August 06, 2015 2:39 PM Subject: RE: Fire extinguisher PN 473951-1 hydrostatic marking by chemical-etching (C977) Hi Shante, It looks like Takashi Hashimoto requested the letter in the attachment and email. His address is: Japan Aero Pressure Co., Ltd. 2-1-8 Kokaba Iwatsuki-ku Saitama-city Saitama I believe that Jon Davignon is the designated agent for Mr. Hashimoto. If we cannot send interpretations internationally, I would be happy to find Mr. Davignon's address in the U.S. to complete the interpretation request. Please let me know if you need any more information. Thanks, Shelby From: Goodall, Shante CTR (PHMSA) Sent: Thursday, August 06, 2015 2:30 PM To: Geller, Shelby CTR (PHMSA) Subject: RE: Fire extinguisher PN 473951-1 hydrostatic marking by chemical-etching (C977) Hi Shelby, Should this letter be address to Jon Davignon or Takashi Hashimoto, if so can you please forward the address. From: Geller, Shelby CTR (PHMSA) Sent: Tuesday, August 04, 2015 12:18 PM 1#

Page 3To: Hazmat Interps Subject: FW: Fire extinguisher PN 473951-1 hydrostatic marking by chemical-etching (C977) Dear Shante and Alice, Attached is a formal request for a letter of interpretation. Mr. Davignon spoke with Adam in the HMIC. Thanks, Shelby From: Takashi Hashimoto [mailto:t.hashimoto@japco.co.jpJ To: Cassidy, Duane (PHMSA) Sent: Tuesday, August 04, 2015 3:07 AM Cc: INFOCNTR (PHMSA) Subject: Fire extinguisher PN 473951-1 hydrostatic marking by chemical-etching (C977) Dear Mr. Duane Cassidy: Our US agent, Mr.Jon Davington called DOT for us on this matter as described below. This is a letter to request interpretation to clarify the chemical-etching on the fire extinguishers. Attached are our letter and relevant documents. We would be very thankful for your quick response. //qtell I have called the DOT center and spoke with Adam. a definitive answer. He conferred with Duane Cassidy and they did not have They indicated you should submit a letter of interpretaton to clarify the chemical etching on the fire extinguishers. You could email to the same place. infocntr@dot.gov Best Regards, Jon Davignon Marketing Manager, New Equipment Sales www.galiso.com //unqtel/ ================= Takashi Hashimoto COO Japan Aero Pressure Co., Ltd 2=============c=…#

Page 4JAPAN AERO PRESSURE CO., LTD. 2-1-8 KOKABA IWATSUKI-KU SAITAMA-CITY SAITAMA JAPCO 339-0072 JAPAN TEL +81-48-794-2521 FAX +81-48-794-3975 August 4, 2015 Mr. Duane Cassidy Chief, Pressure Vessels PHMSA Office of Hazardous Materials Standards Dear Mr. Cassidy: //Subject// Fire extinguisher PN 473951-1 hydrostatic marking by chemical-etching (C977) Ref/A/ Fire Extinguisher manufactured by Kidde Aerospace PN 473951-1 Ref /B/ CMM 26-21-70 page 1010 (attached) Ref /C/49 CFR 180.213 (attached) Ref /D/ HST (Hydrostatic test) marking made by chemical-etching at RIN C977 (JAPCO) (photo attached) // Request// This is to ask you to accept fire extinguishers marked by chemical-etching in the past for continued use. Our agent in the US, a manager of Galiso called Adam on 28/July for us on this matter but he indicated us to submit a letter of interpretation to clarify the chemical-etching on the fire extinguishers. //Background// As for Ref /A/ Fire extinguisher, JAPCO used chemical-etching for the hydrostatic test marking (See Ref /D/ photo) before the vendor specified the marking method in Ref /B/ CMM. In Jan/2013 Ref /B/ CMM was revised to specify rubber stamp and ink as the marking method, then JAPCO has followed the method. Marking method JAPCO used in the past differed from the method specified Ref /B/ CMM. JAPCO would like DOT to accept fire extinguishers marked by chemical-etching in the past for continued use. //The reason for asking DOT// The vendor expressed no concern with using chemical-etching, but they recommended us to contact DOT and ensure that DOT accepts. When JAPCO contacted DOT, on 1st July Mr. Jordan suggested we should review your web site. We reviewed but found no information was posted to solve our issue. We asked Galiso to call DOT about this and Adam indicated on 28 July that we should submit a letter. Thus this is the letter.#

Page 5JAPAN AERO PRESSURE CO., LTD. K 2-1-8 KOKABA IWATSUKI-KU JAPCO SAITAMA-CITY SAITAMA 339-0072 JAPAN TEL +81-48-794-2521 FAX +81-48-794-3975 Sincerely, Takashi Hashimoto Chief Operating Officer Japan Aero Pressure Co., Ltd. 2-1-8 Kokaba Iwatsuki-ku Saitama-city Saitama 339-0072 JAPAN Tel +81-48-794-2521 / Fax +81-48-794-3975#

Page 6KIDDE AEROSPACE & DEFENSE COMPONENT MAINTENANCE MANUAL PART NUMBER 473951 (3) Pressurize the container to 1800 psig (12411 kPa). (4) Do the hydrostatic test as specified by 49 CFR 180.205. Use the Water Jacket Volumetric Expansion Method in CGA Pamphlet C-1. Do not do the hammer test. Test persons must know the contents of CGA Pamphlet C-1 to make a correct analysis of the results. WARNING: BE CAREFUL WHEN YOU DO THE HYDROSTATIC TEST. CALCULATE THE TOTAL, PERMANENT, AND PERCENT OF PERMANENT EXPANSION OF THE WELDMENT WITH PRECISION. DISCARD THE WELDMENT IF THE WALL DIMENSION IS LESS THAN SPECIFIED IN DESCRIPTION AND OPERATION, LEADING PARTICULARS. DO NOT DISCARD THE WELDMENT IF THE WALL THICKNESS IS CORRECT. (5) The test gives the total and permanent expansion of the weldment at a specified pressure. Total expansion minus the permanent expansion is the elastic expansion. Elastic expansion at a specified pressure is a definite measure of the average thickness of the weldment wall. (6) Divide the permanent expansion by the total expansion and multiply by 100 to calculate the percent of permanent expansion. If the total permanent volumetric expansion is more than 10 percent, discard the weldment. (7) Too much permanent expansion shows that the weldment wall is too thin or was in conditions that changed its dimensions. An increase in the elastic expansion shows a decrease in the average wall thickness. WARNING: INK IS CORROSIVE TO HUMAN TISSUE. DO NOT BREATHE VAPORS. USE IN WELL-VENTILATED AREA. PUT ON CHEMICAL-RESISTANT CLOTHING, GLOVES, SPLASH GOGGLES, AND FACE SHIELD. IN CASE OF EYE OR SKIN CONTACT, FLUSH WITH WATER FOR 15 MINUTES AND SEEK MEDICAL ATTENTION. (8) Use a rubber stamp and black ink to mark the date of the hydrostatic test on the weldment (90). Let the ink become dry. (9) Apply a thin layer of acrylic lacquer over the stamped data. SUBTASK 26-21-70-750-002-A01 E. Weight Test NOTE: The item numbers in parenthesis refer to IPL Figure 1. (1) Refer to Kidde Aerospace Service Information Letter (SIL) 96-2 for recommendations for the weight check interval. The paragraphs that follow give the necessary instructions. Refer to Table 1, Leading Particulars Data for the permitted cumulative weight-loss-limit. UTC AEROSPACE SYSTEMS PROPRIETARY TESTING AND FAULT ISOLATION Subject to the EAR. See the title page for more information. 26-21-70 Page 1010 Nov 06/14.#

Page 760 220%#

Page 8§ 180.215 49 CFR Ch. I (10-1-11 Edition) ure test, the marking is as illustrat 1) For designation of the proof pre prescribed in this paragraph (d) is as . An example of the markings A1 ternal visual inspection for cylinders (5) For designation of the 5-year ex 06 x is as illustrated in paragraph (d) of this conforming to § 180.209(g), the marking 32 "g" is the month of requalification Where: placed with the letter "E" cylinder shell requalification only, the (6) For designation of DOT 8 series ""06"" is the year of requalification, and "A123" is the RIN "X" paragraphs (f)(2) through (f)(8) of this sec- represents the symbols marking is as illustrated in paragraph described in is replaced with the letter "S". (d) of this section, except that the "X" and UN cylinder shell and porous filler For designation of DOT 8 series 'om the marking requirement may b ) Upon written request. requalification, the marking is as illus- approved by the Associate Adminis- trated in paragraph (d) of this section, the requirements of §171.23(a)(4) of this (2) Exception. A cylinder subject to the letters "FS." designation of a subchapter may not be marked with a is as illustrated in paragraph (d) of this with a visual inspection, the marking markings must be at least 6.35 mm (¼ (e) Size of markings. The size of the in.) high, except RIN characters must for example the letters "AE" for acous- placed with the type of test performed, be at least 3.18 mm (⅛ in.) high. (f) Marking illustrations. Examples of tic emission or "UE" for ultrasonic ex- cylinders are illustrated as follows: DOT specification and special permit rent examination combined with a vis- (9) For designation of the eddy cur- metric expansion test, 10-year (1) For designation of the 5-year volu- ual inspection, the marking is as illus- except the "X" is replaced with the let- trated in paragraph (d) of this section, and cylinders conforming to § 180.209(f) metric expansion test for UN cylinders and (h), or 12-year volumetric expan- sion test for fire extinguishers con- [67 FR 51660, Aug. 8, 2002, as amended at 70 FR 73166, Dec. 9, 2005; 71 FR 33896, June 12, chapter and cylinders conforming to forming to §173.309(b) of this sub- Dec. 29, 2006; 75 FR 53597, Sept. 1, 2010 006; 71 FR 51128, Aug. 29, 2006; 71 FR 78635 is as illustrated in paragraph (d) of this § 180.209(e) and 180.209(g), the marking 3180215 Rupertin and record reten- umetric expansion test for cylinders (2) For designation of the 10-year vol- qualifies, repairs or rebuilds cylinders (a) Facility records. A person who re conforming to § 180.209(b), the marking where the requalification is performed: must maintain the following records is as illustrated in paragraph (d) of this placed with a five-point star. except that the "X" is re- (2) If the RIN has expired and renewal (1) Current RIN issuance letter; limits up (3) For designation of special filling is pending, a copy of the renewal re- quest; marked service pressure for cylinders excess of the (3) Copies of notifications to Asso- chapter, the marking is as illustrated conforming to $173.302a(b) of this sub- ciate Administrator required under § 107.805 of this chapter; in paragraph (d) of this section, except (4) Current copies of those portions of "X" is replaced with a plus inder requalification and marking ac- this subchapter applicable to its cyl- tivities at that location; 330#

Page 9Pipeline and Hazardous Materials Safety Admin., DOT § 180.213 BAT or 3 spadinaton DO reginal done ates be cared at tol. UN pressure that— turer of these types of cylinders. The (A) Permission is obtained from the the supervision of an independent in- must be performed under cylinder owner; (B) The minimum wall thickness is agency. Upon maintained in accordance with manu- inder: and facturing specifications for the cyl- ard containing the same specification Standard H-28 or an equivalent stand- (C) The original manufacturing test be stamped clearly and legibly with the limits. The re-threaded cylinder must (11) When the cylinder is fitted with a words "RETHREAD" on the shoulder, marked on the external surface of the tion cylinder or UN cylinder may be re- or neck. No DOT specifica- threaded more than one time without The depth of requalification markings may not be greater than specified in the applicable specification. The mark- [71 FR 33895, June 12, 2006, graving, scribing or other method that ings must be made by stamping, 20071 FR 54398, Sept. 14, 2006; 72 FR 55697, Oct. 1, produces a legible, durable mark. $ 180.213 using a pressure sensitive label. guisher (§180.209(j)) may be marked by sure (a) General. Each cylinder or UN pres- ance with this subpart with acceptable receptacle requalified in accord- date and RIN must be applied by low- (2) For a DOT 3HT cylinder, the test this results must be marked as specified in er than that prescribed at the time of stress steel stamps to a depth no great- moved. markings may not be altered or re- manufacture. Stamping on the sidewall is not authorized. inder must be plainly and permanently (b) Placement of markings. Each cyl- qualification markings must be applied (3) For a composite cylinder, permitted by the applicable specifica- marked on the metal of the cylinder as on a pressure sensitive label, securely affixed in a manner prescribed by the tion. Unless authorized by the cylinder nal manufacturer's label. Stamping of cylinder manufacturer, near the origi- specification, marking on the cylinder the composite surface is not author- ification markings must be legible (1) Requalification and required spec- inder successfully passing requalifica- (d) Requalification markings. Each cyl- as to be readily visible at all times. II- remarked on the cylinder as provided legible specification markings may be in a square pattern, between the month tion must be marked with the RIN set and year of the requalification date. fication markings may by the original specification. The first character of the RIN must ap- any portion of the upper end of the cyl- square pattern; the second in the upper pear in the upper left corner of the vided in this section. specification Requalification right; the third in the lower right; and the fourth in the lower left. Example: a metal plate and attached as provided that are illegible may be reproduced on 2006, and approved by a person who has A cylinder requalified in September by the original specification. would be may not be obliterated, except (2) Previous requalification markings the metal of the cylinder in accordance marked plainly and permanently into when the space originally provided for inder specification or on a metal plate with location requirements of the cyl-#