Johnson Controls — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 DEC 1 9 2019 PeterGayon Manufacturing Engineer Johnson Controls One Stanton Street Marinette, WI 54143 Reference No. 19-0120 Dear Mr. Gayon: This letter is in response to your October 10, 2019, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to leakage tests performed on DOT 3A cylinders. Specifically, you ask whether it is permissible to use cameras to detect and closely examine for indications ofleakage as required by§ 178.36(m)(l). The answer is yes. Section 178.36(m) specifies that all spun cylinders and plugged cylinders must be tested for leakage by gas or air pressure. A video camera may be used to perform the required examination provided that all areas can be viewed in a manner equivalent to that which would be expected if viewed directly by a person. I hope this information is helpful. Please contact us if we can be of further assistance. Since. rely, ,. / . /i / ~k,t· ~ t,,D:$~ /:ren Chief, S <lards Development Branch Standards and Rulemaking Division#

Page 2~() /9 -0/26 Dodd, Alice (PHMSA) From: Sent: To: Subject: INFOCNTR (PHMSA) Thursday, October 10, 2019 4:43 PM Hazmat Interps FW: 178.36.m.1 Leakage Test Hello Alice and lkeya, Please see below for letter of interpretation request. The requester spoke with me in the HMIC. Breanna and I both looked through all available guidance we could find and were unable to find anything that would address this question so Peter decided to write in for a LOI. Please contact our office with any questions. Thank you, Kathryn, HMIC From: Peter Brian Gayon [mailto:peter.gayon@jci.com] Sent: Thursday, October 10, 2019 11:35 AM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Subject: 178.36.m.1 Leakage Test Good Morning, 178.36.m.1 (1) Pressure, approximately the same as but no less than service pressure, must be applied to one side of the finished bottom over an area of at least ½6 of the total area of the bottom but not less than ¾ inch in diameter, including the closure, for at least 1 minute, during which time the other side of the bottom exposed to pressure must be covered with water and closely examined for indications of leakage. Except as provided in paragraph (n) of this section, a cylinder that is leaking must be rejected. Interpretation and compliance question, Traditionally our process consists of a person physically observing for bubbles and has been concerning as far as safety of the employee. With technology on our side we can now use cameras to detect and closely examine for indications of bubbles and leakage. This is much more reliable than a person and removes human errors. Question; although methodology of examination is not called out in the standard, will this method meet compliance? Peter Gayon Manufacturing Engineer Building Technologies and Solutions Johnson Controls +17157357411 ext84106 peter.gayon@jci.com Johnson Controls One Stanton Street Marinette, WI 54143 1#

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