Interpretation Response #13-0110 ([Kidde-Fenwal, Inc.] [Mr. Richard Lupien])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Kidde-Fenwal, Inc.
Individual Name: Mr. Richard Lupien
Location State: MA Country: US
View the Interpretation Document
Response text:
August 29, 2013
Mr. Richard Lupien
Manager, Combustion Research Center
Kidde-Fenwal, Inc.
90 Brook Street
Holliston, MA 07146
Ref. No.: 13-0110
Dear Mr. Lupien:
This is in response to your May 16, 2013 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to pressure relief devices (PRD) on Department of Transportation 4BW-250 specification cylinders. In your letter, you state that you manufacture a fixed fire suppression system that utilizes DOT- 4BW250 cylinders filled with a dry chemical agent and pressurized with nitrogen to a pressure of 175 psig at 70 °F. Specifically, you ask if you may use a UL-rated fusible plug instead of a CG-3 fusible plug required by Compressed Gas Association (CGA) publication S-1.1.
Unless excepted, a cylinder filled with a gas and offered for transportation must be equipped with one or more pressure relief devices sized and selected as to type, location, and quantity, and tested in accordance with CGA S-1.1 (see § 173.301(f)(1)). Section 173.301(f)(5)(ii) states that a pressure relief device is not required on “a cylinder with a water capacity of less than 454 kg (1000 lbs) filled with a nonliquefied gas to a pressure of 300 psig or less at 21 °C (70 °F), except for a DOT 39 cylinder or a cylinder used for acetylene in solution.” The cylinders provided in your example do not require pressure relief devices. However, should you choose to install a PRD, it must conform to CGA publication S-1.1.
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
173.301