{"operation":"document","citation":"19-0120","title":"Johnson Controls — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2019-12-19","effective_on":null,"summary":"19-0120 response to Johnson Controls concerning 178.36.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-19-0120.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-19-0120.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-19-0120","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/73076/190120.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nDEC 1 9 2019\nPeterGayon\nManufacturing Engineer\nJohnson Controls\nOne Stanton Street\nMarinette, WI 54143\nReference No. 19-0120\nDear Mr. Gayon:\nThis letter is in response to your October 10, 2019, email requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to leakage tests\nperformed on DOT 3A cylinders. Specifically, you ask whether it is permissible to use cameras\nto detect and closely examine for indications ofleakage as required by§ 178.36(m)(l).\nThe answer is yes. Section 178.36(m) specifies that all spun cylinders and plugged cylinders\nmust be tested for leakage by gas or air pressure. A video camera may be used to perform the\nrequired examination provided that all areas can be viewed in a manner equivalent to that which\nwould be expected if viewed directly by a person.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSince. rely, ,. / . /i /\n~k,t· ~\nt,,D:$~ /:ren\nChief, S <lards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\n~()\n/9 -0/26\nDodd, Alice (PHMSA)\nFrom:\nSent:\nTo:\nSubject:\nINFOCNTR (PHMSA)\nThursday, October 10, 2019 4:43 PM\nHazmat Interps\nFW: 178.36.m.1 Leakage Test\nHello Alice and lkeya,\nPlease see below for letter of interpretation request. The requester spoke with me in the HMIC. Breanna and I both\nlooked through all available guidance we could find and were unable to find anything that would address this question\nso Peter decided to write in for a LOI.\nPlease contact our office with any questions.\nThank you,\nKathryn, HMIC\nFrom: Peter Brian Gayon [mailto:peter.gayon@jci.com]\nSent: Thursday, October 10, 2019 11:35 AM\nTo: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov>\nSubject: 178.36.m.1 Leakage Test\nGood Morning,\n178.36.m.1\n(1) Pressure, approximately the same as but no less than service pressure, must be applied to one side of the\nfinished bottom over an area of at least ½6 of the total area of the bottom but not less than ¾ inch in diameter,\nincluding the closure, for at least 1 minute, during which time the other side of the bottom exposed to pressure\nmust be covered with water and closely examined for indications of leakage. Except as provided in paragraph (n) of\nthis section, a cylinder that is leaking must be rejected.\nInterpretation and compliance question,\nTraditionally our process consists of a person physically observing for bubbles and has been concerning as far as safety\nof the employee. With technology on our side we can now use cameras to detect and closely examine for indications of\nbubbles and leakage. This is much more reliable than a person and removes human errors.\nQuestion; although methodology of examination is not called out in the standard, will this method meet compliance?\nPeter Gayon\nManufacturing Engineer\nBuilding Technologies and Solutions\nJohnson Controls\n+17157357411 ext84106\npeter.gayon@jci.com\nJohnson Controls\nOne Stanton Street\nMarinette, WI 54143\n1\n\n<<<PAGE 3>>>\n\nUSA\nTH IS MESSAGE MAY CONTAIN INFORMATION THAT IS PRIVILEGED AND CONFIDENTIAL. The information contained in , or attached to, this\nmessage is intended solely for the use of the specific person(s) named above . If you are not the intended recipient then you have received this\nco111111unication in error and are prohibited from review, retrans111 ission , taking any action in reliance upon , sharing the content of, disse111inating or\ncopying this message and any of the attach111ents in any way. If you have received this co111111unication in error, please contact the sender immediately\nand promptly delete this message from all types of media and devices. Th ank you\n2","truncated":false,"body_characters":3792}