{"operation":"document","citation":"22-0043","title":"Alabama Liquefied Petroleum Gas Board — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2022-09-08","effective_on":null,"summary":"22-0043 response to Alabama Liquefied Petroleum Gas Board concerning 180.215.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-22-0043.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-22-0043.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-22-0043","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/76776/220043.pdf","body":"<<<PAGE 1>>>\n\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nSeptember 8, 2022\nMr. W. Mark Nelson\nAdministrator\nAlabama Liquefied Petroleum Gas Board\n777 S. Lawrence St., Suite 100\nP.O. Box 1742\nMontgomery, AL 36102-1742\nReference No. 22-0043\nDear Mr. Nelson:\nThis letter is in response to your May 3, 2022, letter requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to requalification records for\nthe visual inspection of Department of Transportation (DOT) specification cylinders. In your\nletter, you state that you have a requalifying facility that is currently considering the utilization of\nequipment that takes a panoramic photo of data on cylinders, which have been visually inspected\nand batched according to the inspector’s findings as follows:\n• The cylinders will be batched for photos according to one of the three disposition codes:\n“OK-Return to Service,” “SC-Scrap,” or “RM-Return to manufacturer for repair.”\n• Cylinders whose data is not legible due to excessive paint will first be routed to the\nsandblast facility to provide for quality photos.\n• Photo files will be indexed according to the inspection date, inspector, and disposition\ncodes.\n• All cylinders will be 20 lb. steel propane cylinders so “size information” will be the same\nfor all, but magnetic decals can be applied for photos indicating size.\n• Additional information can be provided using small magnetic labels applied prior to\nphotographing to detail such information as the “Protective Coating” (Type and\nCondition). For example – “Paint-Excellent.”\n• All information currently maintained in handwritten physical logbooks will be available\nin the photograph files of each cylinder that has been inspected.\n\n<<<PAGE 2>>>\n\nLastly, you state that you believe that photographic records would be more precise because\nhandwritten records often afford the opportunity for human error such as transposing numbers\nwithin a serial number or other data. You ask whether the cylinder test records—currently\nmaintained in handwritten logbooks—may be maintained in the form of digitally indexed\nphotographic files as described above.\nProvided all the information specified in § 180.215(b) for the requalification records of DOT\nspecification cylinders is contained in the photographic files and a means of organizing and\nindexing them is included, a photographic system of recordkeeping as described in your letter\nwould be acceptable under § 180.215(b) of the HMR.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nT. Glenn Foster\nChief, Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\nBA\nALABAMA LIQUEFIED PETROLEUM GAS BOARD\n777 S. Lawrence Street, Suite 100\nTELEPHONE (334) 241-8887\nFAX (334) 240-3255\nPollack\nP.O. BOX 1742\n22-0043\nAT\nSTA\nMONTGOMERY, ALABAMA 36102-1742\nW. MARK NELSON\nADMINISTRATOR\nMay 3, 2022\nMr. Shane Kelley\nDirector, Standards and Rulemaking Division\nU.S. DOT/PHMSA (PHH-10)\n1200 New Jersey Avenue, SE East Building, 2nd Floor\nWashington, DC 20590\nPlease consider this as a request for clarification and a formal written interpretation on CFR 49\n180.215(b). This section of code mandates the information that must be recorded and retained related\nto visual requalification of cylinders, but it only refers to \"test sheets\" in addressing the medium.\nConsidering the many advancements in technology, actual recording of data on paper creates\ntremendous inefficiency in a production environment already greatly hampered by pandemic related\ncylinder supply issues. We have a requalifying facility considering equipment that takes a panoramic\nphoto of data on cylinders that have been visually inspected by an inspector and batched according to\nhis findings as follows:\n• The cylinders will be batched for photos according to one of the three disposition codes \"OK-\nReturn to Service\", \"SC-Scrap\", or \"RM - Return to manufacturer for repair\".\n• Cylinders whose data is not legible due to excessive paint will first be routed to the sandblast\nfacility to provide for quality photos.\n• Photo files will be indexed according to inspection date, inspector, and disposition codes.\n• All cylinders will be 20 lb. steel propane cylinders so \"size information\" will be the same for all,\nbut magnetic decals can be applied for photos indicating size.\n• Additional information can be provided using small magnetic labels applied prior to\nphotographing to detail such information as the \"Protective Coating\" (Type and Condition). For\nexample - \"Paint - Excellent\"\nAll information currently maintained in handwritten physical log books will be available in the\nphotograph files of each cylinder that has been inspected.\nPhotographic records would actually be more precise because handwritten records often afford\nthe opportunity of human error such as transposing numbers within a serial number or other\ndata.\nQuestion: If all information currently maintained in handwritten physical log books will be\navailable in the described photograph files and associated indexing, would this medium be\nacceptable to PHMSA?\nSincerely,\nMark Nelson, Administrator\n\n<<<PAGE 4>>>\n\nFrom: INFOCNTR (PHMSA)\nTo: Dodd, Alice (PHMSA)\nCc: Hazmat Interps\nSubject: FW: Request for Written Interpretation\nDate: Thursday, May 12, 2022 4:55:38 PM\nAttachments: scanner@lpgb.alabama.gov_20220503_104323.pdf\nHi Alice,\nPlease see the attached interpretation request.\nLet me know if you have any questions.\nRegards,\n-Breanna\n-----Original Message-----\nFrom: Nelson, Mark <Mark.Nelson@lpgb.alabama.gov>\nSent: Tuesday, May 3, 2022 11:45 AM\nTo: PHMSA HM InfoCenter <PHMSAHMInfoCenter@dot.gov>\nCc: Nuffer, Thomas <Thomas.Nuffer@lpgb.alabama.gov>\nSubject: Request for Written 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.\nPlease see attached.\nMark Nelson\nAdministrator\nAlabama Liquefied Petroleum Gas Board\n(334) 353-0342\nmark.nelson@lpgb.alabama.gov","truncated":false,"body_characters":6178}