Linde Gas N.A., LLC — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 October 1, 2020 Kevin Funk Shipping Tech Lead Linde Gas N.A., LLC 470 West Antelope Road White City, OR 97503 Reference No. 20-0067 Dear Mr. Funk: This letter is in response to your August 25, 2020, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to an exception for labeling cylinders. Specifically, you ask for clarification on the proper use of CGA C-7-2014, Guide to Classification and Labeling of Compressed Gases regarding: (1) the option to use a reduced size label; and (2) the correct placement of a reduced size label on the cylinder (i.e., the shoulder or the sidewall). Lastly, you included a picture with your email demonstrating an example of a cylinder with a reduced size label. With respect to the Part 172, Subpart E labeling requirements, the general requirement for the placement of a label is that it must be printed on or affixed to a surface (other than the bottom) of the package (see § 172.406(a)(1)(i)). Further, as provided by § 172.407(c), the size requirement states that the label must be at least 100 mm by 100 mm; however, if the size of the package so requires, the dimensions of the label and its features may be reduced proportionally provided the symbol and other elements of the label remain clearly visible. With respect to the use of CGA C-7-2014, in accordance with § 172.400a, a label is not required on a cylinder containing a Division 2.1, 2.2, or 2.3 material that is durably and legibly marked in accordance with CGA C-7-2014, Appendix A (IBR, see § 171.7). CGA C-7-2014, Appendix A requires a basic marking consisting of a diamond-shaped figure indicating the hazard class of the contained gas combined with a panel containing the DOT proper shipping name of the contained gas and the UN identification number. The panel must be located to the left of the diamond (see section A.2, DOT/TC labels and markings). Further, CGA C-7-2014, Appendix A provides for a reduced size label by stating the diamond figure in the basic marking must measure at least 30 mm (1.25 in) on each side (see section A.4, DOT/TC label dimensions and modifications). Finally, the basic marking (which includes the reduced size label) must be located: (a) when space permits, on the shoulder of the cylinder but not covering the current test date, requalification date or any other required permanent markings; or (b) on the side of the#

Page 2cylinder at a point approximately two thirds of the distance from the cylinder bottom to the top of the valve or cap (see section A.7, Additional requirement). Therefore, when conforming to CGA C-7-2014, the label may be reduced in size and may be located on the side of the cylinder without consideration of the size of the cylinder. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Dirk Der Kinderen Chief, Standards Development Branch Standards and Rulemaking Division#

Page 3From: INFOCNTR (PHMSA) To: Hazmat Interps Subject: FW: REDUCED SIZE HAZARD LABELS Date: Wednesday, August 26, 2020 2:58:57 PM Hello Alice, See Below a Request for Letter of Interpretation. Thanks, Jonathon, HMIC From: Kevin Funk [mailto:Kevin.Funk@linde.com] Sent: Tuesday, August 25, 2020 10:48 AM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Subject: REDUCED SIZE HAZARD LABELS CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe. Hello PHMSA Expert: I have enclosed a photo of a cylinder we purchased from one of our vendors recently. We were surprised and encouraged to see the use of reduced size labels on the sidewall of a cylinder that could easily support the use of standard 4 x 4 diamonds (square-on-point) as their hazard class label. Could you please provide direction in support of the proper application of the C-7 system for use of reduced size labelling? It is/was my understanding that reduced size labels can only be used as a “shoulder label” applied to the non-cylindrical portion of a cylinder and not the bottom. They may also be applied to the sidewall of a cylinder that is not of sufficient size to support the application of a standard size 4 x 4 diamond. If indeed this is a viable option for them and possibly us to use as displayed please leave no stone unturned in your explanation. Thank you KEVIN FUNK SHIPPING TECH LEAD LINDE GAS N.A. LLC. 470 W. ANTELOPE RD. WHITE CITY, OR. 97503 DESK 541.830.5300 x41139 FAX 541.830.0327 CELL 541.951.6157 Kevin.Funk@linde.com www.linde.com Ciccarone 20-0067 The information contained in this email and any attachments may be confidential and is provided solely for the use of the intended recipient(s). If you are not the intended recipient, you are hereby notified that any disclosure, distribution, or use of this e-mail, its attachments or any information contained therein is unauthorized and prohibited. If you have received this in error, please contact the sender immediately and delete this e-mail and any attachments. No responsibility is accepted for any virus or defect that might arise from opening this e-mail or attachments, whether or not it has been checked by anti-virus software...#