{"operation":"document","citation":"17-0056","title":"FIBA Technologies, Inc — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2017-11-14","effective_on":null,"summary":"17-0056 response to FIBA Technologies, Inc concerning 180.212.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-17-0056.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-17-0056.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-17-0056","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/56191/170056.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nChris Adams\nManager, Regulatory Affairs\nFIBA Technologies, Inc.\n53 Ayer Road\nLittleton, MA 01406\nReference No. 17-0056\nDear Mr. Adams:\n1bis letter is in response to your May 25, 2017, letter requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the repair of\nseamless DOT 3-series specification cylinders. You describe a scenario in which a DOT\n3AAX specification cylinder was not equipped with external neck threads at the time of\nmanufacture. You ask if the cylinder may be threaded with external threads and be\nconsidered a \"re-threaded\" repair under the provisions of§ 180.212(b)(2), and therefore not\nrequire prior approval. 1\nThe answer is no. The provisions of§ 180.212(b)(2) apply only to cylinders already\nmachined with threads. If a person wishes to machine external threads on a cylinder\noriginally manufactured without external threads, the work must be done in accordance with\n§ 180.212(a), which requires an approval under Part 107, Subpart H.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nirk D · nderen\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nDodd, Alice (PHMSA)\nFrom:\nSent:\nTo:\nSubject:\nAttachments:\nINFOCNTR (PHMSA)\nFriday, May 26, 2017 3:23 PM\nHazmat Interps\nFW: FIBA Request for Letter of Interpretation Regarding 49 CFR 180.212(b)(2)\nFIBA Request for Letter of Interpretation Regarding 49 CFR 180.212(b)(2) - Re-\nthreading.pdf\nHi Shante/Alice,\nPlease submit this as a letter of interpretation. Mr. Adam's full contact information is in the attachment.\nPlease let me know if you have any questions.\nThanks,\nJordan\nFrom: Chris Adams [mailto:ChrisAdams@fibatech.com]\nSent: Thursday, May 25, 2017 2:56 PM\nTo: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov>\nSubject: FIBA Request for Letter of Interpretation Regarding 49 CFR 180.212(b)(2)\nTo Whom It May Concern:\nPlease find attached correspondence from FIBA Technologies, Inc. regarding a question for which we are seeking a letter\nof interpretation from the U.S. DOT. Can you please confirm receipt of this letter? Please don't hesitate to contact me if\nyou have any questions. Thank you.\nChristopher R. Adams\nManager, Regulatory Affairs\nFIBA Technologies, Inc.\n1\n\n<<<PAGE 3>>>\n\nQUALITY PRODUCTS·SERVICE\nFIBA TECHNOLOGIES, INC.\n53 Ayer Road\nLittleton, MA 01406 USA\nTEL(508)887-7100\nhttp://www.fibatech.com\nMay 25, 2017\nE-Mail\nATTN: Hazardous Materials Infomrntion Center\ninfocntr@dot.gov\nSUBJECT: Letter of Interpretation\nREF: 49 CFR § l 80.212(b )(2)\nTo Whom It May Concern:\nIn accordance with 49 CFR § 105.20(2), I am writing to you seeking guidance regarding the above referenced\ncitation from Title 49 of the Code of Federal Regulations. 49 CFR § 180.212 (see Exhibit A) relates to Repair\nof seamless DOT 3-series specification cylinders and seamless UN pressure receptacles. 49 CFR § 180.212(b)\nrelates to Repairs not requiring prior approval. Finally, 49 CFR § 180.212(b)(2) relates to the External re-\nthreading of DOT JAX, 3AAX or 3T specification cylinders (a.k.a. tubes). It is this specific citation, 49 CFR §\n180.212(b )(2), for which we seek an interpretation.\nWhile it is a relatively unusual occurrence, there are older, 3AAX specification cylinders (see photo # 1 in\nExhibit B) that by their design at time of manufacture were not equipped with external neck threads. The vast\nmajority of these cylinders were manufactured in the 1960's. The method of securing these tubes to a\nsemitrailer was by using a combination of a flange without threads, a pair of indentations in the wall of the tube\nneck (see photo # 2 in Exhibit B), and two (2) set screws that are threaded through the mounting flange in a\nradial direction and tightened against the tube neck to prevent rotation. This method has mostly been\nabandoned by tube trailer manufacturers, owners and operators in favor of a threaded tube neck, a threaded\nflange and anti-rotation pins, which will provide a more secure connection.\nFor this reason, customers of FIBA Technologies, Inc. (FIBA) are asking FIBA to machine threads to the OD\nsurface of the tube necks that have not had tlu·eads applied since the day they were manufactured. We feel that\nit is appropriate to do this under the regulations found in 49 CFR § l 80.212(b )(2) despite it being a threading\nprocess, rather than a re-threading process. We are confident that the machining of threads to these cylinders\nwill not increase risk to safety or property. In fact, it will reduce risk.\nSERVING THE INDUSTRY SINCE 1958\n\n<<<PAGE 4>>>\n\nQUALITY PRODUCTS-SERVICE\nFIBA TECHNOLOGIES, INC.\n53 Ayer Road\nLittleton, MA 01406 USA\nTEL(S08)887-7100\nhttp://www.fibatech.com\nFIBA Technologies, Inc.\nInterpretation Request Pertaining to 49 CFR § 180.212(b )(2)\nFIBA is not asking for any deviation from the requirements of 49 CFR § 180.2 I 2(b)(2). We consider the\naddition of the threads to be a repair of a seamless DOT 3-series specification cylinder. We expect that, like\nFIBA, only a cylinder manufacturer of these types of cylinders can perform the threading. The repair work\nshall be performed under the supervision of an independent inspection agency and, upon completion of the\nthreading, the threads will be gauged in accordance with Federal Standard H-28 or an equivalent standard\ncontaining the same specification limits. Finally, the threaded cylinder will be stamped clearly and legibly with\nthe words \"RETHREAD\" on the shoulder, top head, or neck. Given these conditions, FIBA is not seeking a\nspecial permit, as it is not appropriate to do so.\nGiven the above information, FIBA seeks from the DOT a letter of interpretation that confirms that this\nthreading of old tubes (as described above) originally manufactured without threads is equivalent to re-\nthreading old tubes that were originally manufactured with threads. Phrased as a question, we ask the DOT to\nrespond to the following:\nQ. Does the U.S. DOT agree that machining external threads on DOT 3-series specification cylinders (tubes)\nthat were not threaded at time of manufacture is a repair process provided the threading is performed in\naccordance with the regulations found in 49 CFR § l 80.2 l 2(b )(2)?\nThank you in advance for your attention to this matter. Please do not hesitate to contact me if you have any\nquestions or need any additional information.\nSincerely yours,\nr':c->~ I~\n~~.:ams\nManager, Regulatory Affairs\nFIBA Technologies, Inc.\nSERVING THE INDUSTRY SINCE 1958\n\n<<<PAGE 5>>>\n\n£Tu\nQUALITY PRODUCTS·SERVICE\nFIBA TECHNOLOGIES, INC.\n53 Ayer Road\nLittleton, MA 01406 USA\nTEL(508)887-7100\nhttp://www.fibatech.com\nEXHIBIT A\n49 CFR § l 80.212(b )(2)\n§180.212 Repair of seamless DOT 3-series specification cylin-\ners an seamless UN pressure receptacles. (a) General re·\nqulrements for repair of DOT 3-series cylinders and UN pressure\nreceptacles. (1) No person may repair a DOT 3·series cylinder or a\nseamless UN pressure receptacle unless-\n(i) The repair facility holds an approval issued under the provisions\nin §107.805 of this chapter; and\n(ii) Except as provided in paragraph {b) of this section, the repair\nand the inspection Is performed under the provisions of an\napproval issued under subpart H of Part 107 of this chapter\nand conform to the applicable cyllnder specification or ISO\nstar1dard coritai r ~ed in part 178 of this chapter.\n(2) The person performing the repair must prepare a report contain·\ning, at a minimum, H1e results prescribed in §180.215.\n(b) Repairs not requiring prior approval. Approval Is 11ot required\nfor the following specific repairs:\n(1) The removal and replacement of a neck ring or foot ring on a\nDOT 3A, 3AA or 38 cylinder or a UN pressure receptacle that does\nnot affect a pressure part of the cylincler when the repair is performed ~\nby a repair facility or a cylinder manufacturer of these types of cylin·\nders. The repair may be made by welding or brazing in conformance\nwith the original specification. After removal and before replacement,\nthe cylinder must be visually inspected and any defective cylinder\nmust be rejected . The heat treatment. testing and inspection of the\nrepair must be performed under the supervision of an Inspector and\nmust be performed in accordance with the original specification.\n(2) . External re-threading of DOT 3AX, 3AAX or 3T specification\ncylinders or a UN pressure receptacle mounted in a MEGC; or the\ninternal re-threading of a DOT-3 series cylinder or a seamless UN\npressure receptacle when performed by a cylinder manufacturer of\nthese types of cylinders. The repair work must be performed under the\nsupervision of an independent inspection agency. Upon completion\nof the re-threading, the threads must be gauged in accordance with\nFederal Standard H-28 or an equivalent standard containing the same\nspecification limits. The re· threaded cylinder must be stamped clearly\nand legibly with t11e words \"RETHREAD\" on the shoulder, top head.\nor neck. No DOT specification cylinder or UN cylinder may be re-\nthreaded more than one time without approval of the Associate Admin-\nistrator.\nSERVING THE INDUSTRY SINCE 1958\n\n<<<PAGE 6>>>\n\n~\nQU ALITV PRODUCTS·SERVICE\nFIBA TECHNOLOGIES, INC.\n53 Ayer Road\nLittleton, MA 01406 USA\nTEL(508)887-7100\nhttp://www.fibatech.com\nEXHIBIT B\nPHOTOS OF 3AAX CYLINDERS\nWITHOUT EXTERNAL NECK THREADS\n1] ICC/DOT Specification 3AAX 2] Tube Secured by Set Screws\nSERVING THE INDUSTRY SINCE 1958","truncated":false,"body_characters":9579}