Alabama Liquefied Petroleum Gas Board — Hazardous Materials Safety Interpretation

Page 11200 New Jersey Avenue, SE Washington, DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration September 8, 2022 Mr. W. Mark Nelson Administrator Alabama Liquefied Petroleum Gas Board 777 S. Lawrence St., Suite 100 P.O. Box 1742 Montgomery, AL 36102-1742 Reference No. 22-0043 Dear Mr. Nelson: This letter is in response to your May 3, 2022, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to requalification records for the visual inspection of Department of Transportation (DOT) specification cylinders. In your letter, you state that you have a requalifying facility that is currently considering the utilization of equipment that takes a panoramic photo of data on cylinders, which have been visually inspected and batched according to the inspector’s findings as follows: • The cylinders will be batched for photos according to one of the three disposition codes: “OK-Return to Service,” “SC-Scrap,” or “RM-Return to manufacturer for repair.” • Cylinders whose data is not legible due to excessive paint will first be routed to the sandblast facility to provide for quality photos. • Photo files will be indexed according to the inspection date, inspector, and disposition codes. • All cylinders will be 20 lb. steel propane cylinders so “size information” will be the same for all, but magnetic decals can be applied for photos indicating size. • Additional information can be provided using small magnetic labels applied prior to photographing to detail such information as the “Protective Coating” (Type and Condition). For example – “Paint-Excellent.” • All information currently maintained in handwritten physical logbooks will be available in the photograph files of each cylinder that has been inspected.#

Page 2Lastly, you state that you believe that photographic records would be more precise because handwritten records often afford the opportunity for human error such as transposing numbers within a serial number or other data. You ask whether the cylinder test records—currently maintained in handwritten logbooks—may be maintained in the form of digitally indexed photographic files as described above. Provided all the information specified in § 180.215(b) for the requalification records of DOT specification cylinders is contained in the photographic files and a means of organizing and indexing them is included, a photographic system of recordkeeping as described in your letter would be acceptable under § 180.215(b) of the HMR. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, T. Glenn Foster Chief, Review and Reinvention Branch Standards and Rulemaking Division#

Page 3BA ALABAMA LIQUEFIED PETROLEUM GAS BOARD 777 S. Lawrence Street, Suite 100 TELEPHONE (334) 241-8887 FAX (334) 240-3255 Pollack P.O. BOX 1742 22-0043 AT STA MONTGOMERY, ALABAMA 36102-1742 W. MARK NELSON ADMINISTRATOR May 3, 2022 Mr. Shane Kelley Director, Standards and Rulemaking Division U.S. DOT/PHMSA (PHH-10) 1200 New Jersey Avenue, SE East Building, 2nd Floor Washington, DC 20590 Please consider this as a request for clarification and a formal written interpretation on CFR 49 180.215(b). This section of code mandates the information that must be recorded and retained related to visual requalification of cylinders, but it only refers to "test sheets" in addressing the medium. Considering the many advancements in technology, actual recording of data on paper creates tremendous inefficiency in a production environment already greatly hampered by pandemic related cylinder supply issues. We have a requalifying facility considering equipment that takes a panoramic photo of data on cylinders that have been visually inspected by an inspector and batched according to his findings as follows: • The cylinders will be batched for photos according to one of the three disposition codes "OK- Return to Service", "SC-Scrap", or "RM - Return to manufacturer for repair". • Cylinders whose data is not legible due to excessive paint will first be routed to the sandblast facility to provide for quality photos. • Photo files will be indexed according to inspection date, inspector, and disposition codes. • All cylinders will be 20 lb. steel propane cylinders so "size information" will be the same for all, but magnetic decals can be applied for photos indicating size. • Additional information can be provided using small magnetic labels applied prior to photographing to detail such information as the "Protective Coating" (Type and Condition). For example - "Paint - Excellent" All information currently maintained in handwritten physical log books will be available in the photograph files of each cylinder that has been inspected. Photographic records would actually be more precise because handwritten records often afford the opportunity of human error such as transposing numbers within a serial number or other data. Question: If all information currently maintained in handwritten physical log books will be available in the described photograph files and associated indexing, would this medium be acceptable to PHMSA? Sincerely, Mark Nelson, Administrator#

Page 4From: INFOCNTR (PHMSA) To: Dodd, Alice (PHMSA) Cc: Hazmat Interps Subject: FW: Request for Written Interpretation Date: Thursday, May 12, 2022 4:55:38 PM Attachments: scanner@lpgb.alabama.gov_20220503_104323.pdf Hi Alice, Please see the attached interpretation request. Let me know if you have any questions. Regards, -Breanna -----Original Message----- From: Nelson, Mark <Mark.Nelson@lpgb.alabama.gov> Sent: Tuesday, May 3, 2022 11:45 AM To: PHMSA HM InfoCenter <PHMSAHMInfoCenter@dot.gov> Cc: Nuffer, Thomas <Thomas.Nuffer@lpgb.alabama.gov> Subject: Request for Written Interpretation 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. Please see attached. Mark Nelson Administrator Alabama Liquefied Petroleum Gas Board (334) 353-0342 mark.nelson@lpgb.alabama.gov#