Interpretation Response #13-0004 ([Airgas SAFECOR] [Mr. John Anderson])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 08/21/2013

Company Name: Airgas SAFECOR

Individual Name: Mr. John Anderson

Location State: WY Country: US

View the Interpretation Document

Response text:

August 21, 2013

Mr. John Anderson
Airgas SAFECOR
P.O. Box 20067
Cheyenne, WY 82003

Ref. No.: 13-0004

Dear Mr. Anderson:

This is in response to your December 20, 2012 email and conversation with a member of my staff concerning visual inspection requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you cite a potential conflict between a letter this office issued in 2011 (Ref. No 10-0077) and Compressed Gas Association Publication C-6 Standards for Visual Inspection of Compressed Gas Cylinders (CGA C-6).  Cylinders that conform to the requirements of § 180.209(g) are exempt from the hydrostatic test by virtue of their exclusive use in certain noncorrosive gas service.  However, these cylinders must be given a complete visual inspection in accordance with CGA C-6.  In interpretation 10-0077, we stated that no measurement of the tare weight is required for the external visual inspection.  The letter went on to say that when the cylinder exhibits corrosion, the cylinder must be further examined for condemnation.

This guidance provided in 10-0077 is correct.  If corrosion is identified during the external visual inspection then the cylinder may be evaluated using the four general criteria in Section 3.2.1.1 of CGA C-6 to determine if the cylinder should be condemned.  Section 3.2.1.1, paragraph (1), in part, states that the cylinder must be condemned when the tare weight is less than 90% of the original stamped tare weight.  Additionally, even if a cylinder satisfies the tare weight criteria of 3.2.1.1 paragraph 1, it must still be further examined by measuring the wall thickness in accordance with 3.2.1.1 paragraphs (2), (3) or (4) for the types of corrosion that has been identified on the cylinder.  However, if as a result of a visual inspection the cylinder does not exhibit corrosion and it meets the requirements for exclusive use in
§ 180.209(g), the cylinder will meet the four general criteria in 3.2.1.1.  Thus verification of the tare weight is not necessary.  

I hope this information is helpful.  If you have further questions, please do not hesitate to contact this office.

Sincerely,

Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division

180.209(g)

Regulation Sections