{"operation":"document","citation":"20-0067","title":"Linde Gas N.A., LLC — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2020-10-01","effective_on":null,"summary":"20-0067 response to Linde Gas N.A., LLC concerning 171.1, 172.400a, 172.406, 172.407.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-20-0067.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-20-0067.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-20-0067","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/74436/200067.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nOctober 1, 2020\nKevin Funk\nShipping Tech Lead\nLinde Gas N.A., LLC\n470 West Antelope Road\nWhite City, OR 97503\nReference No. 20-0067\nDear Mr. Funk:\nThis letter is in response to your August 25, 2020, email requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to an exception for\nlabeling cylinders. Specifically, you ask for clarification on the proper use of CGA C-7-2014,\nGuide to Classification and Labeling of Compressed Gases regarding: (1) the option to use a\nreduced size label; and (2) the correct placement of a reduced size label on the cylinder (i.e., the\nshoulder or the sidewall). Lastly, you included a picture with your email demonstrating an\nexample of a cylinder with a reduced size label.\nWith respect to the Part 172, Subpart E labeling requirements, the general requirement for the\nplacement of a label is that it must be printed on or affixed to a surface (other than the bottom) of\nthe package (see § 172.406(a)(1)(i)). Further, as provided by § 172.407(c), the size requirement\nstates that the label must be at least 100 mm by 100 mm; however, if the size of the package so\nrequires, the dimensions of the label and its features may be reduced proportionally provided the\nsymbol and other elements of the label remain clearly visible.\nWith respect to the use of CGA C-7-2014, in accordance with § 172.400a, a label is not required\non a cylinder containing a Division 2.1, 2.2, or 2.3 material that is durably and legibly marked in\naccordance with CGA C-7-2014, Appendix A (IBR, see § 171.7). CGA C-7-2014, Appendix A\nrequires a basic marking consisting of a diamond-shaped figure indicating the hazard class of the\ncontained gas combined with a panel containing the DOT proper shipping name of the contained\ngas and the UN identification number. The panel must be located to the left of the diamond (see\nsection A.2, DOT/TC labels and markings). Further, CGA C-7-2014, Appendix A provides for a\nreduced size label by stating the diamond figure in the basic marking must measure at least 30\nmm (1.25 in) on each side (see section A.4, DOT/TC label dimensions and modifications).\nFinally, the basic marking (which includes the reduced size label) must be located: (a) when\nspace permits, on the shoulder of the cylinder but not covering the current test date,\nrequalification date or any other required permanent markings; or (b) on the side of the\n\n<<<PAGE 2>>>\n\ncylinder at a point approximately two thirds of the distance from the cylinder bottom to the top\nof the valve or cap (see section A.7, Additional requirement). Therefore, when conforming to\nCGA C-7-2014, the label may be reduced in size and may be located on the side of the cylinder\nwithout consideration of the size of the cylinder.\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\nFrom: INFOCNTR (PHMSA)\nTo: Hazmat Interps\nSubject: FW: REDUCED SIZE HAZARD LABELS\nDate: Wednesday, August 26, 2020 2:58:57 PM\nHello Alice,\nSee Below a Request for Letter of Interpretation.\nThanks,\nJonathon, HMIC\nFrom: Kevin Funk [mailto:Kevin.Funk@linde.com]\nSent: Tuesday, August 25, 2020 10:48 AM\nTo: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov>\nSubject: REDUCED SIZE HAZARD LABELS\nCAUTION: 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.\nHello PHMSA Expert:\nI 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.\nCould you please provide direction in support of the proper application of the C-7 system for use of reduced size labelling?\nIt 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.\nThey 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.\nIf indeed this is a viable option for them and possibly us to use as displayed please leave no stone unturned in your explanation.\nThank you\nKEVIN FUNK\nSHIPPING TECH LEAD\nLINDE GAS N.A. LLC.\n470 W. ANTELOPE RD.\nWHITE CITY, OR. 97503\nDESK 541.830.5300\nx41139\nFAX 541.830.0327\nCELL 541.951.6157\nKevin.Funk@linde.com\nwww.linde.com\nCiccarone\n20-0067\nThe 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...","truncated":false,"body_characters":5436}