Hydro-Test Products, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration January 19, 2022 1200 New Jersey Avenue, SE Washington, DC 20590 Carlos Graca Hydro-Test Products, Inc. 85 Hudson Road Stow, MA 01775 Reference No. 21-0101 Dear Mr. Graca: This letter is in response to your November 2, 2021, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to recordkeeping requirements for the visual inspection used to requalify cylinders. In your email, you note that § 180.209(g) allows for an external visual inspection to be performed in lieu of a periodic hydrostatic test and requires the results to be recorded and maintained in conformance with § 180.215. However, you note that the recordkeeping requirements include reference to more information than can be provided by an external visual inspection (e.g., actual test pressure). We have paraphrased and answered your questions as follows: Q1. You ask what information must be recorded for a visual inspection performed in accordance with § 180.209(g). A1. A person who requalifies a cylinder using an external visual inspection only needs to provide information specified in § 180.215(b) relevant to an external visual inspection. Information such as expansion, test pressure, verification, or calibrated cylinder values do not need to be recorded as part of the recordkeeping requirements. Q2. You ask whether the manufacturing date and gas service must be recorded during the external visual inspection. A2. The answer is yes. See answer “A3” for Letter of Interpretation, Ref. No. 21-0100. Q3. You note a seemingly circular reference among §§ 180.209(g) and 180.215, CGA C-6, and CGA C-6.3, and ask for clarity on which regulations to follow when performing an external visual inspection of a cylinder.#

Page 2A3. Section 180.209 provides requirements for the requalification of cylinders. Paragraph (g) provides conditions that allow for an external visual inspection requalification of a cylinder that is in specialized service. CGA C-6 and CGA C-6.3 are industry developed standards for the performance of a visual inspection and have been incorporated by reference into the HMR and thus—by definition—are made part of the HMR. (See § 171.8 for the definition of incorporated by reference.) Because of reliance on visual inspections as a means to requalify these cylinders, reference is made to these standards to ensure that visual inspections are performed properly and consistently by requalifiers. Finally, reference to § 180.215 provides a reminder of the requirements for reporting and recordkeeping of requalified cylinders. Thus, all are regulations that should be followed in accordance with § 180.209(g). 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 3Baker 21-0101 From: Patrick, Eamonn (PHMSA) To: Hazmat Interps Cc: DerKinderen, Dirk (PHMSA); Foster, Glenn (PHMSA) Subject: FW: Recording Requirements Date: Tuesday, November 2, 2021 8:49:36 AM Attachments: Interpretation letter2.pdf From: Carlos Graca <Carlos@hydro-test.com> Sent: Tuesday, November 02, 2021 8:27 AM To: Patrick, Eamonn (PHMSA) <eamonn.patrick@dot.gov> Subject: RE: Recording Requirements 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. Dear sir, I do hope that you have received my previous email concerning the recording of a proof test under CFR49 section 180.215. We are also getting several questions from the cylinder re-qualification industry regarding the recording of a visual inspection when allowed to be performed in lieu of a pressure test in accordance with section 180.209(g). Attached is a request for clarification and interpretation concerning the recording requirements under CFR49, section 180.215. I would very much appreciate an expedited reply. Please contact the undersigned with any questions. Thank you and I look forward to hearing back from PHMSA on this and my previous request Carlos Graca Hydro-Test Products, Inc. 85 Hudson Rd Stow, MA USA 01775 978-897-4647 ext.14 Email: cgraca@hydro-test.com www.hydro-test.com From: Carlos Graca Sent: Wednesday, October 27, 2021 2:34 PM#

Page 4To: eamonn.patrick@dot.gov; hazmatinterps@dot.gov Subject: Recording Requirements Dear Patrick, Attached is a request for clarification and interpretation concerning the recording requirements under CFR49, section 180.215. I would very much appreciate an expedited reply. Please contact the undersigned with any questions. Thank you and I look forward to hearing back from PHMSA. Best regards, Carlos Graca Hydro-Test Products, Inc. 85 Hudson Rd Stow, MA USA 01775 978-897-4647 ext.14 Email: carlos@hydrotest.com#

Page 5Standards and Rulemaking Division Pipeline and Hazardous Materials Safety Administration, Attn: PHH-10 U.S. Department of Transportation East Building 1200 New Jersey Avenue, SE Washington, DC 20590 Re: Test record forms Dear sir, we are getting several questions from the cylinder re-qualification industry regarding the recording of a visual inspection when allowed to be performed in lieu of a pressure test in accordance with section 180.209(g). Our questions are as follows: 1) There are no expansion values, test pressures, verification or calibrated cylinder used during a visual inspection. However, section 180.209(g) does reference that “results be recorded and maintained in accordance with section 180.215.” This is impossible as 180.215 has many fields that are not applicable to a visual inspection re-qualification. What fields must be recorded? 2) Does the “manufacturing date” and “gas service” are they required to be listed? 3) As with the proof test this referenced compressed gas pamphlet(s), C-6 and C-6.3, do not show the new requirements under 180.215. They do however reference 180.215, yet the regulations in 180.209(g), states to reference those CGA pamphlets. By strictly going by the CGA pamphlets and 180.209(g) a circle of confusion is completed with no answers, as both are referring to each other. What regulations do we follow? I again ask if a pamphlet should be referenced if it shows samples that do not comply with the regulations referencing them?? I appreciate your time and quick reply to this and my previous request. Sincerely, Carlos Graca Cylinder Re-Qualification Training Manager 85 Hudson Road Stow, Massachusetts 01775 USA Tel # Tel # Tel # Tel # 800-225-9488 / 978-897-4647 Fax # Fax # Fax # Fax # 978-897-1942 Email Email Email Email: Carlos@Hydro-test.com#