{"operation":"document","citation":"PI-73-038","title":"Manufacturers Standardization Society of the Valve Fittings Industry — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1973-12-05","effective_on":null,"summary":"PI-73-038 response to Manufacturers Standardization Society of the Valve Fittings Industry concerning 192.149.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-038.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-038.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-038","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1973/PI73038.pdf","body":"<<<PAGE 1>>>\n\nDec 5 1973\nMr. Robert V. Warrick\nManufacturers Standardization Society\nof the Valve Fittings Industry\n1815 North Fort Myer Drive\nArlington, VA 22209\nDear Mr. Warrick:\nThis is in response to your letter of October 26, 1973, and our conference on November 15\ntogether with Messrs. Greenwald, Lattan, and George, representing the Manufacturers\nStandardization Society of the Valve and Fitting Industry regarding our interpretation of\n§192.149.\nYou indicate that the interpretation of §192.149 in our August 10, 1973, letter to Mr. R.W.\nSchneider has created considerable concern among manufacturers of these products and that you\nfeel that the interpretation is in contradiction to that given to your office on November 9, 1970.\nFirst of all, from the discussion in our conference regarding the last sentence of §192.149(b), we\nfeel that the sentence should be clarified to properly interpret the need for testing of a prototype.\nA clarification of that sentence, with parenthetical insertion added, would then read:\n\"...The actual bursting strength of the fitting must be at least equal the computed bursting\nstrength of pipe of the designated material and wall thickness, as determined by as\nprototype that was tested to at least the (computed bursting) pressure required for the\npipeline to which it is being added.\"\nWe stated in the letter to Mr. Schneider that \"...in the case of bursting strength requirements for a\nparticular fitting made in accordance with certain design specifications, size, material properties,\nand manufacturing process, such a new fitting would be tested to burst. After satisfactory test,\nany number of like fittings would be expected to meet strength requirements for such a type\nfitting\" (underscoring added). This statement sets forth clearly the intent that any new type of\nfitting must have a prototype tested to burst. Any number of like fittings are then expected to\nmeet similar strength requirements.\nWe then indicated in that letter that \"If there is a change in size, material, design specifications,\nmanufacturing process, or any other thing that could affect the performance, it would be expected\nthat such a change would necessitate the testing of a new prototype.\"\nThe interpretation given to Mr. Schneider in our letter of August 10, 1973, was not in direct\ncontradiction of the interpretation given to your office on November 9, 1970, but only clarified\ndal\\192\\149\\73-12-05\n1\n\n<<<PAGE 2>>>\n\nour understanding of the words \"lines of fittings\" used in your description of the specific practices\nin your letter of November 9, 1970, as meaning \"like\" fittings of the same design \"specifications,\nsize, material properties and manufacturing process.\"\nIf you feel that this testing of the prototype fittings should be modified, you may petition this\nOffice to amend this rule. This petition should set forth the substance of the rule proposed,\nexplain the interest of the petitioner, and contain information to support the action sought. Based\nupon the information you provide, we will evaluate this information and consider regulatory\naction in this matter.\nWe trust that this has clarified this matter. If we can be of further assistance, please let us know.\nSincerely,\nCesar DeLeon\nDeputy Director\nOffice of Pipeline Safety\ndal\\192\\149\\73-12-05\n2","truncated":false,"body_characters":3303}