{"operation":"document","citation":"23-0041","title":"United Testing Services — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2024-05-02","effective_on":null,"summary":"23-0041 response to United Testing Services concerning 178.65.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-23-0041.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-23-0041.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-23-0041","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2024-05/230041.pdf","body":"<<>>\n\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nMay 2, 2024\nAnthony Roston\nUnited Testing Services\nChabot Collision Building\n20736 Lake Chabot Rd.\nCastro Valley CA 94546-5406\nReference No. 23-0041\nDear Mr. Roston:\nThis letter is in response to your April 20, 2023, email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to Department of\nTransportation (DOT) specification 39 (DOT 39) non-reusable (non-refillable) cylinders. You\nask for additional clarification of the requirements in § 178.65 which state that “[b]razed seams\nmust be assembled with proper fit to ensure complete penetration of the brazing material\nthroughout the brazed joint.” Specifically, you ask whether radiographic and photographic\nimages that you provided of a DOT 39 cylinder were representative of a weld with “complete\npenetration” and whether a cylinder weld with voids could still be in compliance with § 178.65.\nAs stated in an earlier letter of interpretation we issued and that you cited (Reference No. 21-\n0097), PHMSA cannot determine whether a violation of § 178.65 exists based solely on\nphotographic evidence. While the criteria provided in the HMR are not specific to the presence\nof voids in welds, § 178.65(c)(2) specifies that for seams:\n• Brazing is not authorized on aluminum cylinders;\n• Brazing material must have a melting point of not lower than 1,000 °F;\n• Brazed seams must be assembled with proper fit to ensure complete penetration of the\nbrazing material throughout the brazed joint;\n• Minimum width of brazed joints must be at least four (4) times the thickness of the shell\nwall; and\n• Brazed seams must have a design strength equal to or greater than 1.5 times the minimum\nstrength of the shell wall.\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<<>>\n\nCasey\n23-0041\nFrom: Foster, Glenn (PHMSA)\nTo: Dodd, Alice (PHMSA)\nSubject: FW: 19-F-00183 (CPSC), RP120140 (D.O.T.), 21-0097 (D.O.T.), 20180519-A9E35-2147387862 (CPSC) - Request\nfor Letter of Interpretation (D.O.T.), and Recall Action (C.P.S.C. and D.O.T. - Handheld torch products\nDate: Friday, April 21, 2023 11:53:54 AM\nAttachments: 230420 UTS reporting_braze_defect_voids_NRT_Cylinders-CPSC_DOT.pdf\nAlice,\nPlease have the attached checked in and assigned to a Specialist as a new request for a LOI.\nThanks,\nGlenn\nFrom: Anthony Roston \nSent: Thursday, April 20, 2023 3:03 PM\nTo: Egray@cpsc.gov; Jsmith@cpsc.gov; MSchoem@cpsc.gov; section15@cpsc.gov;\njenny.mclaughlin@hc-sc.gc.ca; Ttopka@cpsc.gov; dlarue@cpsc.gov; asuchy@cpsc.gov;\nKsuper@cpsc.gov\nCc: Foster, Glenn (PHMSA) ; Hillman, Kenetha CTR (PHMSA)\n; Pollack, Arthur (PHMSA) ;\nandrew@eastbaylaw.com\nSubject: 19-F-00183 (CPSC), RP120140 (D.O.T.), 21-0097 (D.O.T.), 20180519-A9E35-2147387862\n(CPSC) - Request for Letter of Interpretation (D.O.T.), and Recall Action (C.P.S.C. and D.O.T. -\nHandheld torch products\nCAUTION: This email originated from outside of the Department of Transportation (DOT). Do\nnot click on links or open attachments unless you recognize the sender and know the content\nis safe.\nDear Mr. Gray, Mr. Foster, and\nNotice Recipients:\nPlease see attached letter request sent to CPSC and to the D.O.T.\nSincerely,\nAnthony Roston\nUnited Testing Services\nCastro Valley, CA\n925-872-1850\n\n<<>>\n\nMr. Eric T. Gray, Compliance\nOfficer, CPSC\nMr. T. Glenn Foster, Regulatory\nReview, U.S. DOT, Pipeline and\nHazardous Materials\nUnited Testing Services LLC\nChabot Collision Building\n20736 Lake Chabot Rd.\nCastro Valley CA 94546-5406\nTel. 916-416-5904\nunitedtestingservicesllc@gmail.com\nReference:\n1. CPSC Report No.\n20180519-A9E35-2147387862\n2. CPSC Recall file RP120140\n3. FOIA request 19-F-00183\nApril 20, 2023\nDear Mr. Gray and/or CPSC Person of Interest,\nDear Mr. Foster and/or D.O.T. Person of Interest:\nWe are submitting a reporting of a defect with the BernzOmatic and Worthington\nbrand handheld torches, which are sometimes sold under several other names (i.e.\nSears, Lenox, etc.). The manufacturer is Worthington Cylinder Corporation in Ohio.\nTheir counsel, last in touch with Mr. Gray in re RP120140, is Mr. Richard Ergo, of\nWalnut Creek, California. This reporting may extend to the recall, RP120140. Mr.\nFoster, of the D.O.T. Pipeline and Hazardous Materials division, issued a letter of\ninterpretation regarding the defect on 6/23/22. We will therefore begin by asking Mr.\nFoster to issue a further letter of interpretation to resolve a difference of terminology\nregarding the words “complete penetration” as they related to the defect described\nbelow. We will also ask both the D.O.T. and the C.P.S.C. to initiate a recall of the\nproduct due to the defects stated.\nThe subject fuel cylinders have failed many times at the neck area, also called the\n“main valve housing,” shown in the photo provided by Worthington’s engineer, Steve\nGentry several years ago:\nPage 1 of 9\n\n<<>>\n\nWorthington Cylinder Corporation took x-ray and scan images of the two failed cylinders\nshown in the photo above in 2018. Both cylinders contained the large voids and gaps shown\non Worthington’s images:\nPage 2 of 9\n\n<<>>\n\nJPV-1\nJPV-2\n• Peralta cylinder, large voids\n*voids do not go 360° around as stated\nby Dr. Pfaendtner.\nBailey_Avonix_CyLVideo.mp4.\nCynder 2 alonment system\n0 | m 1 2\nIS +IE\n19 - 1 mi Rosinan\n247,95 deg\n2-Axs Rotasor\nKBV-1\n(braze compound is\nminimal, void quite\nlarge)\nBailey_Avonix_CyLVideo.mp4.\nCinder 2 agent myster\nKBV-2\n*voids do not go 360°\naround as stated by Dr.\nPfaendtner\nPage 3 of 9\n\n<<>>\n\nWorthington’s engineer then obtained one random cylinder from Lowes Home Improvement\nand took images of the brazing compound. Those images also showed the presence of large\nvoids as shown here:\nPage 4 of 9\n\n<<>>\n\nWe have also personally spoken with five of the victims of cylinders which failed at the neck\nas shown in the photo above: (1) Kurtis M. Bailey, Bailey v. Worthington, 1\"17-cv-7548-\nPGR (Northern District of Illinois; (2) Jason Peralta, Peralta v. Bernzomatic/Worthington,\n2:17-cv-3195-JJT (Arizona); (3) Andrew Shalaby, Shalaby v. Bernzomatic, 3:11-cv-00068-\nAJB (S. Dist. CA); (4) Murray Shadbolt (Canada); and Jacob Avery (Massachusetts). The\ninjury victims all reported failure of the cylinder at the neck without application of any\nunusual or unforeseeable forces. The manufacturer filed expert witness reports that in\nessence stated that the injury victims were lying about the manner with which they used the\ntorches, and that the victims had to have exerted a very strong amount of force. Their expert\nperformed duplication tests to try to show the types of forces they had to have subjected the\ncylinders to, and took videos and photographs, such as shown here:\n(Photos courtesy of Worthington and its experts.)\nPage 5 of 9\n\n<<>>\n\nWorthington’s engineer stated that he tested six non-defective cylinders. He struck five of\nthem on a solid sharp edge of a workbench as hard as he could, but could not get them to\nfail. He then created a raised edge as shown above, and struck it as hard as he could to cause\none cylinder, the sixth tested, to fail as shown. He also stated that the torches in the two\ncases he was assigned to, Bailey and Peralta, could not have possibly failed under the use\ndescribed by Mr. Bailey and Peralta, because such a failure would be impossible if they were\nnot defective. Mr. Bailey and Peralta have given sworn statements that the cylinders did\nindeed fail under normal use and without application of any such forces. Mr. Shalaby also\nstated that he was just using his torch in a normal manner, without application of any such\nforces, and it failed at the neck as well. All of the victims suffered severe permanent burn\ninjuries. Other victims, whose families filed cases in different states, have died from their\ninjuries.\nMr. Foster (DOT), your letter of interpretation responded to the above-shown photos of the\nvoids in the brazing compound. You correctly disclosed the following:\n“You ask whether the photos and videos linked in your letter illustrate a\nbrazed seam of a DOT 39 cylinder that does not meet the requirements set\nforth in § 178.65(c)(2)(iii). Under § 178.65(c)(2)(iii), \"Brazed seams must be\nassembled with proper fit to ensure complete penetration of the brazing\nmaterial throughout the brazed joint.\"\nHowever, Worthington’s Attorney Mr. Ergo, who corresponded with Mr. Gray regarding\nCPSC recall file RP120140, provided Worthington’s interpretation as follows:\n“‘Complete penetration’ does not mean the absence of voids. Rather, it\nmeans that the brazing material (copper metal in this case), when\nliquefied in the brazing furnace, flows throughout the entire joint”.\nThis definition appears to be inconsistent with that of the D.O.T. as well as inconsistent with\nthe interpretation of educational institutions, such as these:\n“Effects of Capillary Attraction and Wetting on Brazing Capillary\nattraction makes leak-tight joints a simple proposition for brazing. In a\nproperly designed joint, the molten filler metal is normally drawn\ncompletely through the joint area without any voids or gaps, and brazed\njoints remain liquid- and gas-tight under heavy pressures, even when the\nPage 6 of 9\n\n<<>>\n\njoint is subjected to shock or vibrational types of loading.”1\nVoids or porosity - an incomplete flow of brazing filler metal which can\ndecrease joint strength and allow leakage-often caused by improper\ncleaning, incorrect joint clearance, insufficient filler metal, entrapped gas\nor thermal expansion.2\nThe latter interpretations appear to be the same as provided by Metallurgist Dr. Robert\nAnderson in the Shalaby matter on June 25, 2008, which is attached, and states:\n“The brazing materials have large voids in the bulk and smaller voids in the\ninterface between the cylinder walls and the center valve housing as shown in\nMicrophotographs 6, 7, and 8. The brazing on the outer surface of the cylinder\nis undercut in all three cylinders rather than forming a meniscus. The\nundercutting is a sign of lack of wetting and penetration of the brazing\nmaterial with the cylinder and valve[...] The Bernzomatic one pound MAPP\ngas cylinder is manufactured per Federal specification published in 49 CFR\n178.65 (D.O.T. 39). The specification for non-reusable (non- refillable)\ncylinders slates \"brazed seams must be assembled with proper fit to ensure\ncomplete penetration of the razing material throughout the brazed joint.\" The\nbrazed joints shown in microphotographs 6, 7, and 8 lack complete\npenetration. For these three cylinders that were examined to be offered on the\nmarket clearly establishes the failure of Bernzomatic inspection and quality\ncontrol procedures. The MAPP gas torch and cylinder is unsafe and\nunreasonably dangerous as designed and manufactured.”\nIn addition, we discovered a defect of over-pressurization of the cylinders from\nWorthington’s Engineer’s documents produced. One specification document is dated “5-19-\n06\" and identified as “WCW000376.” The second specification document is dated 5/14/13\nand was originally produced with the identification number “WCW000083,” but also hsa\nidentification number “WCW000374\". A version of the same document, with a revision\nhistory showing the date “3-20-18,” is identified as “WCW000377. The specification\ndocuments specify the working pressure, test pressure, pressure relief valve discharge\n1Source 7/16/21:\nhttps://www.asminternational.org/documents/10192/1849770/06955G\n_\nChapter\n_\n2.pdf\n2Source:\nhttps://blog.lucasmilhaupt.com/en-us/about/blog/inspecting-brazed-joints\nPage 7 of 9\n\n<<>>\n\npressure, relief valve reseal pressure, and cylinder burst pressure. The specification\ndocuments reflect facial defects in the specifications themselves, to wit:\nWCW000376 WCW000374 WCW000377\n5/19/06 5/14/13 5/14/13\nMinimum Burst\nPressure\n260 PSIG\n(7-14-08 was\n900 PSIG)\n750 PSIG 750 PSIG\nWorking Pressure 260 PSIG 260 PSIG 260 PSIG\nTest Pressure 325 PSIG 325 PSIG 325 PSIG\nRelief Valve Start\nTo Discharge\n260 PSIG\n(7-14-08 was\n380-480 PSIG)\n360-520 PSIG 360-520 PSIG\nRelief Valve Reseal 260 PSIG 260 PSIG 260 PSIG\nThe specification documents reflect that the minimum cylinder burst pressure specification\nwas as low as 260 PSIG on one document, while that figure was lower than the “test”\npressure, facially evidencing a defect. (See WCW000376.) The same document shows the\ntest pressure at 325 PSIG, which is higher than the “minimum burst pressure.” On\nWCW000474, the pressure relief valve specification was 360-520 PSIG, as compared to the\nmuch lower 260 PSIG shown on WCW000376.\nWorthington’s engineer, Dr. Thomas Eagar, declared that the relief valve specification\nwas 360-480 PSI, which is not shown on any of Worthington’s specification documents.\nThe defective specifications are on the specification sheets themselves. On a report\nprepared by Worthington’s Dr. Eagar, he reveals the following:\nThere have been over-pressurization failures in the past but not with such\nviolent energy releases. In each prior over-pressurization, the PRV released as\nintended, performing its intended safety function.\nHe was referring to a cylinder that was over-pressurized, and failed with the neck (main\nvalve housing) having ripped a full 360 degrees around, causing shrapnel to lodge in the\nneck of one Mrs. Astrid Marmont, killing her.\nBased on the above information, we ask that Mr. Foster provide a new letter of\ninterpretation, advising whether Worthington’s definition of complete wetting and\npenetration quoted above is the correct interpretation, or whether Dr. Anderson’s\ninterpretation quoted above, which appears consistent with ASM International’s\ninterpretation also quoted above, is the correct interpretation. Specifically, do voids in the\nbrazing compound of the subject cylinder, as shown in Worthington’s x-ray and scan photos\nPage 8 of 9\n\n<<>>\n\nabove, evidence a failure of compliance with the D.O.T.’s requirement for “complete wetting\nand penetration”?\nMr. Gray, or otherwise, CPSC, and also Mr. Foster, or otherwise the D.O.T., we also\nrequest that CPSC and D.O.T. require a full recall of the subject cylinders due to the voids\nand failures noted. To aid in this process, we have now collected several of the defective and\nfailed cylinders, including the ones involved in Bailey, Peralta, and Shadbolt (Canada). The\nremaining defective and failed cylinders are believed to be in possession of Worthington’s\ncounsel, Mr. Ergo, and there are quite a few.\nSincerely,\nAnthony J. Roston & Manuel Marieiro,\nUnited Testing Services, LLC\nPage 9 of 9\n\n<<>>\n\nCase: 1:16-cv-07548 Document #: 704-2 Filed: 07/02/22 Page 1 of 6 PageID #:7454 Case: 1:16-cv-07548 Document #: 713-3 Filed: 08/11/22 Page 1 of 6 PageID #:7572\nRNA Consulting, Incorporated\nSpecializing in forensic materials engineering and sciences\nRobert N. Anderson, Ph.d~ P.E., President\nZ7820 SaddJo Coun\nLos Ahos HHh. CA\n94622-1810 USA\nBus:- 65()..949---1092\nFar. 650-949.5641\nemail; robettNA@aol.com\nJune 25, 2008\nMark D. Epstein\nAlborg, Veiluva & Epstein LLP\n200 Pringle A venue, Suite 410\nWalnut Creek, CA 94596-7380\nRe: Shalaby v. Irwin, et al.\nDear Mr. Epstein:\nAt your request, I have examined the 4/21/06 incident where Mr. Andrew Shalaby was\ninjured while using a 16 oz cylinder Bernzomatic MAPP gas torch. MAPP gas is a\ntrademark of the Dow Chemical Co. and is composed of extremely flammable\nmethylacetylene-propadiene-propane. ·\nIt is my understanding that Mr. Shataby was in the process of igniting logs in a fire pit,\nusing a TS4000 torch head and Bernzomatic MG9 MAPP gas cylinder when the cylinder\nvented and he was burned. In the incident, the center valve housing, attached to the\ncanister by brazing material, ruptured.\nMaterials Reviewed:\nI have reviewed the following documents:\nL Deposition of Michael Ridley, Senior engineering manager, Irwin Industrial Tool\nCo., taken 11/13/07. ·\n2. Deposition of Steven T. Gentry, Quality Control Department Worthington\nCylinder Corp., ll/14/07. ·\n3. Deposition of Andrew W. Shalaby volume I and II, Plaintiff, l 0/24/07 and\n10/25/07.\n4. Deposition of Warren L. Ratliff, Jr., Park ranger supervisor, Campland, 4/17/07.\n5. Deposition of Randy T. Stephens, Ranger at Carnpland, 4/17/07.\n6. Deposition of Joe Russo, Paramedic, 4/18/07.\n7. Miscellaneous manufacturing drawings of torch parts.\n8. Health & Safety Laboratory report 2006/121.\n9. Bernzomatic instruction manuals 9600 l, 97090\n10. Bernzomatic catalog.\n1 L Investigative Report with reference to interview of Anne Carrol and David Borger\nby Howard Felder 10/6/07.\n12. Consumer Product Safety Commission Release# 78-088.\n13. Transcribed statement of Andrew Shalaby by Joe Tancredy, 6/1/06\n14. Material Safety Data Sheet for MAPP Gas.\n15. Supplemental Response to Request for Production ofDocmnents (Set No. One).\n16. Worthington Industries Expert Witness Disclosures.\nEpstein_ Shalaby_ RNAteport.doc - 1 -\n\n<<>>\n\nCase: 1:16-cv-07548 Document #: 704-2 Filed: 07/02/22 Page 2 of 6 PageID #:7455 Case: 1:16-cv-07548 Document #: 713-3 Filed: 08/11/22 Page 2 of 6 PageID #:7573\n17. Third-Party Defendant/Cross Claimant Western Industries, List of Expert\nWitnesses.\n18. Disclosure of Experts by Defendants, Bemzomatic.\n19. Protective Order.\n20. Defendants' Initial Disclosures.\n21. Drawing 304432.\n22. MAPP gas cylinder specifications.\nAnalysis:\nThe failure of the Bemzomatic MAPP gas torch Mr. Shalaby was using appears to be at\nthe collar or threaded area between the center valve housing and the cylinder. The center\nvalve housing is fastened to the cylinder by a copper-nickel brazing material. The Rangers\nin the park that examined the gas torch confirm that the fuilure was in that location.\n• Park Ranger Supervisor Warren Ratliff, in his deposition, comments were that there\n\"appeared to be a crack in the cylinder at the bottom thread level of the cylinder\" page\n25, lines 21-25; page 26, lines 24-25.\n• Ranger Randy Stephens comments on the f!!Vure in his deposition on page 42, linesl5-\n25; page 43, lines 1-ll; page 73, lines 9-25; page 74lines 1-15.\n• Also, the recollection of Andrew Shalaby in his transcribed statement to Joe Tancredy\non 61!/06.\nMr. Shalaby was using the torch to ignite firewood in a frre pit and his torch would have\nbeen partially inverted in that situation. Health & Safety Laboratory report 2006/121\n(report included in test results CD) determined that the torch orientation was important\nand confmned that when the cylinder was inverted, explosion could occur. The directions\ndo indicate \"Use upright to prevent flare-ups or flashes\" caused by the liquid entering the\ntorch. However, this orientation is impossible in some situations.\nCPSC Release # 78-088 issued a notice of a recall for fuel cylinders from another\nmanufacture (Cleanweld Products) that separated \"where the threaded connector meets the\ncylinder\". A flaw in this area is very serious.\nA review of other MAPP gas torch failures involving lawsuits filed since January 2002\nand supplied by the Defendant in their Supplemental response to request for production of\ndocuments (Set One) had listed ?lawsuits identified below.\n1. Thomas Segrest, Jr. v. Bemzomatic. (Date of injury 2/9/04)\n2. Richard Gleen v. Newell Operating Co. (Date of injury l/3/06)\n3. Andrew Gelzer v. Therrnadyne (Date of injury 2/13/04)\n4. Melvin Wilfredo Bonilla Carranza v. Bemzomatic. (Date of injury 6/13/05)\n5. Ross Pelz v. Worthington Industries. (Date ofinjury 5/29/05)\n6. Mark Loewes v. Worthington Industries. (Date of injury 3/27 /05)\n7. Timothy Welch v. Newell Rubberrnaid (Date of injury 7/3/06)\nThe Glenn v. Newall is a Ventura California case in which a Bemzomatic cylinder failed\nat the braze material (Photographs 1, 2).\nIn addition, I have reviewed photographs for a Minnesota case called Venderlinde v. Ace\nHardware Corp., where a \"Turbo Torch\" failed in the braze material between the center\nEpstein_ Shalaby_RNAreport.doc -2-\n\n<<>>\n\nCase: 1:16-cv-07548 Document #: 704-2 Filed: 07/02/22 Page 3 of 6 PageID #:7456 Case: 1:16-cv-07548 Document #: 713-3 Filed: 08/11/22 Page 3 of 6 PageID #:7574\nvalve housing and the cylinder. There are two Lenox cylinders (John Barrett v. Lenox and\nLemaralejo) that also failed in the same location.\nTests Conducted:\nl. Metallography of the brazing material in MAPP gas cylinders.\n2. Microhardness of the brazing material in MAPP gas cylinders.\n3. Energy Dispersive Spectrum (EDS) ofMAPP brazing material.\n4. Metallography of corrosion test of the MAPP brazing material.\n5. Metallography ofbrazing material in MAPP PRO gas cylinder.\n6. Microhardnes of the brazing material in MAPP PRO gas cylinders.\n7. EDS of brazing material in MAPP PRO gas cylinders.\nTest data are contained in a compact disc (CD) included with this report.\nThe braze material is a copper nickel alloy. The composition was determined to be\napproximately 61 %(atomic) Cu and 39% Ni by Energy Dispersive X ray. This is 63%\nCu by weight and the specifications 011 Drawing 32600-23 call for a maximum of 60% by\nweight Cu. It is possible that the brazing material is off specificatio11s.\nSteven Gentry in his depositipn (page 89, line 7) states that the brazing temperature is\nbetween 2000 and 2100 degrees Fahrenheit, which is 1093- 1149 degrees centigrade.\nAccording to the Cu-Ni phase diagram (See Figure 1) from the reference \"Hansen,\nConstitution of Binary Alloys\", that temperature is too low to melt the brazing alloy .\n. It should be noted that the brazing material used in the Bemzomatic MAPP PRO cylinders\nhas been changed to all copper without the addition of nickel. Metallography of the MAPP\nPRO brazing material is shown on the CD.\nConclusions/Findings:\nBased on the facts of failure in the brazed area, I have exarni!led three exemplar MAPP\ngas cyli11ders, (W1 OG57E, Wl1 G 152W and W8G230E), with respect to the Cu-Ni braze\nbetween the center valve housing and the cylinder. Microhardness testing of the brazing\nmetal gave values of23 HRC for WlOG57E; 33 HRC for Wl1Gl52W, and 97 HRB for\nW8G230E.\nThe cylinders have been sectioned in half and four sections have been cut from each\ncylinder to show a portion of the neck piece and cylinder wall and the brazing material\nbetween. These sections have been mounted in plastic and polished and photographically\ndocumented. Representative examples of the microphotographs from each cylinder are\nshown in Photographs 3, 4, and 5. The brazing materials have latge voids in the bulk\nand smaller voids in the interface between the cylinder walls and the center valve housing\nas shown in Microphotographs 6, 7, and 8. The brazing on the outer surface of the\ncylinder is undercut in all three cylinders rather than forming a meniscus. The\nundercutting is a sign of lack of wetting and penetration of the brazing material with the\ncylinder and valve. A good meniscus shows that wetting has occurred. The brazing defects\nshown in photographs 3-8 reduce the strength of the joint and make it more likely that the\nvalve will partially separate from the cylinder and release gas when the torch is used as\nintended.\nEpstein_Shalaby_RNAreport.doc -3-\n\n<<>>\n\nCase: 1:16-cv-07548 Document #: 704-2 Filed: 07/02/22 Page 4 of 6 PageID #:7457 Case: 1:16-cv-07548 Document #: 713-3 Filed: 08/11/22 Page 4 of 6 PageID #:7575\nThe outside surface of the btazing material that is undercut represents a lack of wetting\nand penetration of the brazing material with the cylinder and valve housing. This flaw is\nsufficient to reject the cylinder. This flaw should have been picked up by the manufacturer\nwith a simple visual iuspection of the cylinders.\nThe Bernzomatic one pound MAPP gas cylinder is manufactured per Federal specification\npublished in 49 CFR 178.65 (D.O. T. 39). The specification for non-reusable (non-\nrefillable) cylinders states \"brazed seams must be assembled with proper fit to ensure\ncomplete penetration of the razing material throughout the brazed joint.\" The brazed joints\nshown in microphotographs 6, 7, and 8 lack complete penetration.\nCorrosion tests show that the brazing material is strongly cathodic to the cylinder and\nvalve and will cause the steel to corrode· in a suitable moist atmosphere. The interior walls,\nof the sectioned cylinders, also showed signs of corrosion. See Photograph 9, Interior\nView of Cylinder WlOG57E Showing Corrosion.\nIn my opinion, the braze material between the center valve housing and the cylinder is the\nweak element in the a.Ssembly, and subject to failure when the torch is attached to the\ncylinder. The brazing material bas voids and lacks sufficient fusion to the cylinder wall\nand valve housing to resist stresses placed on it when used in a normal manner. This\nproblein with the brazing material is due to a combination of poor cleaning of the brazing\narea, contamination of the brazing material and improper process parameters such as\nfurnace temperature and time. For these three cylinders that were examined to be offered\non the market clearly establishes the failure of Bernzomatic iuspection and quality control\nprocedures.\nThe MAPP gas torch and cylinder is unsafe and unreasonably dangerous as designed and\nmanufactured.\nPlease call me if you have any questions.\nSincerely,\n~~~\nRobert N. Anderson, Ph.D., P.E.\nEpstein_ Shalaby _RNAreport.doc -4-\n\n<<>>\n\nCase: 1:16-cv-07548 Document #: 704-2 Filed: 07/02/22 Page 5 of 6 PageID #:7458 Case: 1:16-cv-07548 Document #: 713-3 Filed: 08/11/22 Page 5 of 6 PageID #:7576\nPhpto 3: W10G57E. @ 13X. Valvehpusipge>,tJth~Jppand.cylioder on\nJhe.bPtlotn with brazing material inbetw~.e.n.\n' . ' .\n· Epstein_Shalaby_RNAreport.doc -8-","truncated":false,"body_characters":25952}