{"operation":"document","citation":"25-0004","title":"Bancroft Hinchey Ltd. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2025-06-24","effective_on":null,"summary":"25-0004 response to Bancroft Hinchey Ltd. concerning 180.205, 180.209.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-25-0004.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-25-0004.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-25-0004","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2025-06/250004.pdf","body":"<<<PAGE 1>>>\n\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nJune 24, 2025\nKevin Turner\nTraining & Assurance Manager\nBancroft Hinchey Ltd.\nUnit 7A, Hartley Business Park\nSelborne Road\nAlton, Hampshire, GU343HD\nReference No. 25-0004\nDear Mr. Turner:\nThis letter is in response to your January 10, 2025 email requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to pressure\ntests and system checks performed on cylinders. You state that the pressure test\nrequirement in § 180.205(g) of the HMR permitting a “system check” to be performed at\na pressure up to 90% of test pressure conflicts with instruction offered in the Compressed\nGas Association (CGA) publication, C-1, “Methods for Pressure Testing Compressed\nGas Cylinders,” which is incorporated by reference in § 180.205(g). Specifically, CGA\nC-1 provides instruction for a cylinder to be pressurized to less than 90% of the minimum\ntest pressure. You provide an example of a DOT 3AA cylinder with a service pressure of\n1800 psi, which is pressurized during a system check to 2700 psi1 (i.e., exactly 90% of\nthe minimum required test pressure). Specifically, you ask, would pressurizing the\ncylinder to 90% of the test pressure rather than below be considered a “system check”\ninstead of a test?\nYes. Based on the example you provided, it is the opinion of this Office that what you\ndescribe would be considered a system check. While § 180.205 requires pressure testing\nin accordance with CGA C-1, § 180.205(g) allows a system check to be performed at or\nbelow 90% of test pressure. Section 180.205(g) does not require adhering to CGA C-1\nwhich prescribes a system check below 90% of test pressure. However, because any\npressurization that exceeds 90% would be considered a test, performing a system check at\n1 Table 1 to paragraph (a) of § 180.209 – DOT 3AA cylinders must have a minimum test pressure of 5/3 times service pressure,\nexcept non-corrosive service (see § 180.209(g)). As such, 1800 psi x 5/3 = 3000 psi.\n\n<<<PAGE 2>>>\n\npressures below 90% is more conservative as it ensures that a cylinder is not\ninadvertently pressurized over 90% of test pressure (e.g., due to minor gauge tolerance\ndifferences).\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<<<PAGE 3>>>\n\nCasey\n25-0004\nFrom: INFOCNTR (PHMSA)\nTo: Dodd, Alice (PHMSA)\nCc: Hazmat Interps\nSubject: FW: 49CFR - Interpretation request - Hydrostatic Testing - Maximum System Check Pressure\nDate: Friday, January 10, 2025 4:54:07 PM\nAttachments: image001.png\nHello Alice,\nSee the attached interpretation request. Let us know if you need anything else.\nBest, Aminah\nFrom: Kevin Turner - Bancroft <kevin.turner@bancroft.co.uk>\nSent: Friday, January 10, 2025 9:25 AM\nTo: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov>\nSubject: 49CFR - Interpretation request - Hydrostatic Testing - Maximum System Check Pressure\nYou don't often get email from kevin.turner@bancroft.co.uk. Learn why this is important\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.\nGood afternoon\nPlease can we have a clarification on a conflict between the information presented in\n§180.205(g)(5):\n“A system check may be performed at or below 90% of test pressure prior to the retest…..”\nAnd the information presented in CGA C-1 2016 (5.7 – Cylinder retesting):\n“When conducting water jacket testing it is highly recommended that the cylinder be\npressurized in the water jacket to a pressure less than 90% of its test pressure before\nconducting a volumetric expansion test…….If a cylinder is pressurised below 90% of\nminimum test pressure….. this does not count as a test….”\nThe apparent conflict is “at or below”, vs “below”\nSo as an example, does pressurising a DOT-3AA 1800 cylinder to exactly 2700 psi count as a\nsystem check, or a test?\nMany thanks\n\n<<<PAGE 4>>>\n\nThis e-mail message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential\nand privileged information or otherwise protected by law. Any unauthorized review, use, disclosure or distribution is\nprohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the\noriginal message. Any applicable rights to privilege have not been waived.","truncated":false,"body_characters":4614}