{"operation":"document","citation":"21-0066","title":"Robert L. Beck — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2021-09-14","effective_on":null,"summary":"21-0066 concerning 180.215.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-21-0066.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-21-0066.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-21-0066","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/75891/210066.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nSeptember 14, 2021\nMr. Robert L. Beck\n10898 Osceola Mills Street\nLas Vegas, NV 89141\nReference No. 21-0066\nDear Mr. Beck:\nThis letter is in response to your June 17, 2021, email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to test system component\ncalibration requirements in Compressed Gas Association (CGA) Pamphlet C-1, “Methods for\nPressure Testing Compressed Gas Cylinders.”\nWe have paraphrased and answered your questions as follows:\nQ1. You ask whether the master gauge in the computer system must be of the same or greater\naccuracy as the pressure indicating device (PID).\nA1. The answer is yes. CGA C-1 states that a master gauge is a PID that is used as a\ncalibration standard and has an accuracy grade equal to or better than the requirement for\nthe PID to be checked.\nQ2. You ask whether the scale used as an expansion indicating device (EID) requires daily\nverification.\nA2. The answer is yes. CGA C-1 states that the verification of the accuracy of these devices\nshall be accomplished daily in conjunction with the total test system verification.\nQ3. You ask whether the weights for the EID require annual recalibration.\nA3. The answer is no. CGA C-1 does not specify whether the weights for the EID system\nrecalibration require annual recalibration; however, it states that recertification may be\nperformed by the cylinder manufacturer or the requalification facility following the\ndevice manufacturer’s guidelines for recalibration.\n\n<<<PAGE 2>>>\n\nQ4. You ask whether the verification of the EID must be documented.\nA4. CGA-1 does not contain specific recordkeeping requirements for EID recalibration.\nHowever, please note that the daily accuracy verification of the requalification system\nmust be documented each day requalifications are performed in accordance with\n§ 180.215(b)(1). Separately, each requalifier must retain the most recent certificate of\ncalibration for the EID, in accordance with § 180.215(b)(4).\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\nLarson\n21-0066\nFrom: Foster, Glenn (PHMSA)\nTo: Date: Dodd, Alice (PHMSA); Hillman, Kenetha CTR (PHMSA)\nSubject: FW: Interpretation\nThursday, June 17, 2021 7:57:20 AM\nAlice and Kenetha,\nPlease have the below checked in as a LOI and assigned to the next Specialist in the rotation.\nThanks,\nGlenn\n-----Original Message-----\nFrom: ROBERT BECK <beck415@msn.com>\nSent: Thursday, June 17, 2021 7:44 AM\nTo: Foster, Glenn (PHMSA) <Glenn.Foster@dot.gov>\nSubject: Interpretation\nCAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or\nopen attachments unless you recognize the sender and know the content is safe.\nHi Glenn,\nI would like a written response to the following:\nIn CGA C-1 referring to the master gage, it is stated that the master gage shall be of equal or better percent accuracy\nthan the pid. For an analog gage it’s quite simple. However, the pressure transducers in the computer hydro test\nstations are typically +\\- 0.1%. So my question is does the master gage in the computer system need to be the same\nor greater accuracy?\nIn the section for the eid (expansion indicating device) does the scale require verification daily, do the weights need\nto be calibrated annually and does the verification need to be documented?\nAnswers to these above will remove any ambiguity. Thanking you in advance.\nBest regards,\nBob Beck\n(702) 757-5143\nSent from my iPhone","truncated":false,"body_characters":3772}