Chart Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 JA N n 9 2020 Bruce Sanborn Regulatory Compliance Manager Chart Inc. 407 Seventh Street N.W. New Prague, MN 56071 Reference No. 19-0102 Dear Mr. Sanborn: This letter is in response to your July 31, 2019, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CPR Parts 171-180) applicable to the manufacture of DOT Specification 4 L cylinders. You seek confirmation of your understanding that the phrase "same condition" as used in§ 178.57(j)(l) means the sheet or plate material has received all plate processing operations-inciuding heat treatment-as the material used to form the heads and the cylinder. Specifically, you ask whether tensile test samples may be taken from the flat plate that will be used to form the heads or cylinder, or whether the samples must be taken from the head or cylinder after forming. Tensile samples must be taken from either the head or cylinder after it has been formed. In accordance with§ 178.570)(1), "the test is required on 2 specimens selected from the material of each heat and in the same condition as that in the completed cylinder." In other words, a sample from the flat plate that will be used to form the head or the cylinder would not be in its completed form or in the condition of a completed cylinder. Therefore, the test sample must be taken from either the head or the cylinder once the cylinder has been formed. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, ,..-~ -., ,v· -1.,, _ , /~/ : ~ -/ ~ ,,. t D'' e . ren ctf, Stan ards Development Branch Standards and Rulemaking Division#

Page 2C/uirtinc. Disti-ilmtion & Storrurc 407 Seventh Street N .W. New Prague, MN 56071-1000 Phone: 952.758.4484 Fax: 952.758.8255 www.charr-ind.com Mr. Shane Kelley Director, Standards and Rulemaking Division US DOT/ PHMSA (PHH-10) 1200 New Jersey Ave, SE East Building, 2nd Floor Washington, DC 20590 July 31 , 2019 Mr. Kelley, Request for interpretation related to the manufacture of DOT 4L liquid cylinders per 49 CFR 178.57. 49 CFR 178.570)(1) indicates the tensile test samples must be selected from material of each heat number and in the same condition as that in the completed cylinder. Chart's understanding of "same condition" is that the sheet / plate material has received all plate processing operations, including heat treatment, as the material that will be used to form the heads and the cylinder. Can the tensile test samples can be taken from the flat plate that will be used to form the heads or cylinder, or must the samples be taken from the head or cylinder after forming? Sincerely, -/J~,0_/4~ Bruce Sanborn Regulatory Compliance Manager#