{"operation":"document","citation":"20-0029","title":"Johnson Controls — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2020-07-30","effective_on":null,"summary":"20-0029 response to Johnson Controls concerning 178.71.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-20-0029.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-20-0029.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-20-0029","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/74166/200029.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nJuly 30, 2020\nOliver Sánchez Muñoz\nR&D Engineer\nJohnson Controls\nJosep Ros i ros, Naves 23. P.I. La Clota.\n08740 Sant Andreu de la Barca, Spain\nReference No. 20-0029\nDear Mr. Muñoz:\nThis letter is in response to your April 1, 2020, email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to United Nations (UN)\ncylinders. You state that you intend to use higher pressure rated UN cylinders for fire\nextinguishing systems that typically have used lower pressure rated UN cylinders. Specifically,\nyou ask about the applicability of specification and testing requirements, including ISO 10297,\nfor valve accessories, such as pressure gauges and switches.\nPlease note, PHMSA recently published a final rule, HM-215O [85 FR 27810], which\nincorporated by reference (IBR) the newest versions of various international hazardous materials\nstandards to include ISO 10297:2014. All valves subject to the requirements of ISO 10297:2014\nhad an effective date of May 11, 2020, with a delayed compliance date of May 10, 2021.\nWe have paraphrased and answered your questions as follows:\nQ1. You ask whether service equipment, such as pressure gauges and pressure switches, are\nsubject to the requirement to withstand 1.5 times the test pressure of the receptacle as\nspecified for in § 178.71(d)(1).\nA1. The answer is yes. Section 178.71(d)(1) requires that equipment subject to pressure must be\ndesigned and constructed to withstand at least 1.5 times the test pressure of the\nreceptacle.\nQ2. You ask whether service equipment, as specified in § 178.71(d)(1), meets the design and\nconstruction requirement to withstand 1.5 times the test pressure of the pressure\nreceptacle if permanent deformation is observed, but the equipment does not burst and no\ncomponents are ejected during testing.\nA2. The answer is no. If permanent deformation occurs on the valve during the test, this is\nconsidered a failure for the pressure receptacle’s service equipment. In accordance with\nISO 10297:2014, cylinder valves must be capable of withstanding a hydraulic pressure\n\n<<<PAGE 2>>>\n\ntest of 1.5 times the test pressure of the cylinder for 2 minutes without permanent\ndeformation (emphasis added), leak, or rupture.\nQ3. You ask what type of documentation would be sufficient to demonstrate that a valve\nand its accessories meet the design and construction (e.g., burst pressure) requirements\nin § 178.71(d). Specifically, you ask whether a vendor’s safety data sheet that\ndemonstrates that a valve and its accessories meet specification for burst pressure is\nacceptable documentation demonstrating compliance.\nA3. If a valve manufacturer or a third-party testing lab can certify the valve and its accessories\ncomply with ISO 10297:2014 and the valve is appropriately marked to demonstrate\ncompliance, then that is sufficient.\nQ4. You ask whether there are requirements to test at a given sampling rate at 1.5 times the test\npressure even if a burst test cannot be implemented as part of the manufacturing process\nfor the valve and its accessories. Further, you ask how a sampling rate would be\nestablished to meet the requirement.\nA4. The answer is no, there is no specified sampling rate. In accordance with ISO 10297:2006, a\nminimum number of test samples are required, but this is dependent on the number of\nvariant types to be tested. In ISO 10297:2014, the number of test samples for testing a\nvalve was clarified to include, pressure gauges or pressure indicators (see\nISO 10297:2014, Section 6.3). However, no sampling rate is specified in either edition;\nthe valve manufacturer selects a sampling rate that sufficiently indicates achievement of\nthe design and construction standard.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nDirk Der Kinderen\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\nREGULATION INTERPRETATION REQUEST\nBACKGROUND:\nWe are seeking interpretation of DOT requirements for compliance to transport pressurized UN\nISO USA refillable seamless steel containers.\nThe purpose is to use higher rated cylinders for system configurations that are typically served\nwith lower rated cylinders.\nContainer assemblies of interest include valve assemblies that incorporate accessories, i.e.\npressure gauges and pressure switches that are transported under pressure. Container assemblies\nincorporate burst discs to prevent excessive build-up that are rated to suit the original lower rated\ncylinders.\nTypically accessories are sourced from vendors who state burst pressure of accessories in their\ndata sheets.\nPARAGRAPH OF DOT REGULATION FOR WHICH INTERPRETATION IS SOUGHT:\nDOT regulation established in CFR 49, Section 178.71(d) states:\n“Except for pressure relief devices, UN pressure receptacle equipment, including valves, piping,\nfittings, and other equipment subjected to pressure must be designed and constructed to\nwithstand at least 1.5 times the test pressure of the pressure receptacle”\nQUESTION 1:\nDoes equipment referred to in CFR 49 Section 178.71(d) comply the requirement if when tested\nat 1.5 times the test pressure of the pressure receptacle the equipment does not burst and no\nparts are ejected but permanent deformation is observed?\nQUESTION 2:\nAre data sheets from vendors showing the value of burst pressure enough to document\ncompliance with this requirement? If not, what type of documentation would be enough?\nQUESTION 3:\nConsidering that burst test cannot be implemented as part of the manufacturing process, is there\nany requirement to test a given sampling rate at 1.5 times the test pressure of the pressure\nreceptacle? If yes how the sampling rate is established to meet the requirement?","truncated":false,"body_characters":5900}