# Sherwood Valve — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 19-0093
- **title:** Sherwood Valve — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2019-10-28
- **effective on:** Not available
- **summary:** 19-0093 response to Sherwood Valve concerning 173.301a.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-19-0093.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-19-0093.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-19-0093
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/72826/190093.pdf
**body:**

<<<PAGE 1>>>

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Avenue, SE
Washington, DC 20590
October 28, 2019
Joseph L. Lacek II, P .E.
Sherwood Valve
100 Business Center Dr.
Suite 400
Pittsburgh, PA 15205
Reference No. 19-0093
Dear Mr. Lacek:
This letter is in response to your June 21, 2019, letter requesting clarification of the Hazardous
Materials Regulations · (HMR; 49 CFR Parts 171-180) applicable to cylinder valves in
§ 173.301(a)(l 1). You seek clarification of the statement that cylinder valves manufactured on
or after November 7, 2019, must conform to the requirements in CGA V-9, "Compressed Gas
Association Standard for Compressed Cylinder Valves," Seventh Edition, 2012. You note that
while CGA V-9 lists a series of tests that valves must pass, there is no mention of self-closing
valves (ClO or pin style valves). You state that the International Organization for
Standardization (ISO) 17879 has testing that self-closing valves must pass that is similar to the
test specified in CGA V-9. Therefore, you ask if conformance with CGA V-9 as specified in
§ 173.301(a)(l 1) is required for a self-closing valve.
The answer is no. The intent of§ 173.301(a)(l 1) is to ensure that all applicable cylinder valve
types conform to requirements in CGA V-9. It was not PHMSA's intent to prevent the use of
other types of valves that may not be covered in CGA V-9, such as self-closing valves used in
paintball cylinders. Since self-closing valves are not covered in CGA V-9, the requirements in
CGA V-9 do not apply to self-closing valves. It is recommended, but not required, that self-
closing valves be designed and tested to applicable safety standards, such as ISO 17879.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and_ Rulemaking Division

<<<PAGE 2>>>

A n d.AQ, u_J--~
j /73 Joi
/ 9-0D7'3
SHER W OOD
Sherwood Valve's Position on HM-219A changes to 49 CFR 173.301 Paragraphs
(a)(ll)
The Department of Transportation has released HM-2 I 9A that outlines the changes to 49 CFR Parts 171, 172, 173,
176, 178 and 180. Upon review by Sherwood, there have been some questions that came up pertaining to the changes
made to part 173 which pertain to the addition of paragraph (a)( 11 ). Sherwood Valve is a manufacturer of cylinder
valves, and has been active in the industry for over 40 years. Sherwood Valve is a member of the Compressed Gas
Association (CGA) and participates in the development and maintenance of the standards, specifications, and technical
bulletins developed and distributed by CGA.
The questions that come up are in relation to the wording of 49 CFR 173.30 I (a)(11 ) .. ''Cylinder valves manufactured
on or after November 7, 2019 used on cylinders to transport compressed gases must conform to the requirements in
CGA V-9 .. . " Sherwood Valve is reading this that any valve installed on cylinder that are not already exempted due to
liquefied petroleum gas (LPG), must meet CGA V-9.
According to 49 CFR 171.7 the referenced revision ofCGA V-9 is the 20 12 edition. Upon review of this standard there
is no mention of valves that are considered self-closing (C 10 or pin style valves) valves within section 5 of CGA V -9.
These types of valves are basically a check type valve that incorporate an internal poppet that seals against the inside of
the valve body via a seal energized by the cylinder pressure and a spring. These valves are operated by depressing the
poppet to allow the cylinder contents to be utilized. An example of this type of valve would be found in the paint ball
industry.
Within the CGA V-9 2012 there are type tests that the valves that meet this standard must be able to pass. They are as
follows : Proof Pressure, Burst Pressure, Flow, Excessive Torque, Leak Tightness, Endurance, High Temperature, Low
Temperature, Visual Examination, and Flame Impingement. Some of these tests a self-closing type valve would be able
to pass, but some of them are impossible to complete on this type of valve. The Excessive torque test described in
section 7 .1.4 of CGA V-9 is for valves that require a turning motion to open and close the valve. Self-closing valves do
not require a turning motion to operate the valve. Another test it would not be able to meet as written would be the
endurance test as described in section 7 .1.6 of CGA V-9. This test describes how to run 2000 open and closing cycles
on a valve that requires a certain torque to shut off. Again, since self-closing valves do not require a turning motion to
close off it cannot meet this test. It is because of not meeting these tests that self-closing valves by design cannot
conform to CGA V-9.
CGA does not have a specification specifically written for self-closing valves. However, the International Organization
for Standardization (ISO) does. ISO 17879 is specifically written for a self-closing valves. ISO 17879 has type tests
that valves must pass in order to be in compliance with the standard that are very similar to CGA V -9's tests: Hydraulic
bust pressure, Internal/External Leak tightness, Endurance, and Visual examination. The tests in ISO 17879 are not
only similar to CGA V-9's but would also provide the same amount of safety to those involved with handling and using
cylinders with self-closing valves designed to ISO 17879.
It is Sherwood Valve's position that if a self-closing valve conforms to ISO 17879 it provides the same benefit as a
valve needing rotation to operate that conforms to CGA V-9. Therefore a self-closing valve that conforms to ISO 17879
would not have to meet CGA V-9 and would still be able to be used on cylinders.
Joseph L Lacek II, P.E.
Design Engineer
Sherwood Valve
100 Business Center Dr, Suite 400 • Pittsburgh, PA 15205
724-225-8000 • www.sherwoodvalve.com
- **truncated:** false
- **body characters:** 5916