Interpretation Response #13-0176 ([HSB Global Standards] [Mr. Oberst Mulet])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: HSB Global Standards
Individual Name: Mr. Oberst Mulet
Location State: CT Country: US
View the Interpretation Document
Response text:
November 19, 2013
Mr. Oberst Mulet
HSB Global Standards
One State Street
P.O. Box 299
Hartford, CT 53403-5011
Ref. No. 13-0176
Dear Mr. Mulet:
This responds to your August 22, 2013 email regarding physical testing of DOT Specification 4L cylinders under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You note that for most of the DOT Specification “300 series and 400” series cylinders, when physical testing of specimens is required, the specimen must conform to the following:
“A gauge length of 8 inches with a width not over 1½ inches, a gauge length of 2 inches with width not over 1½ inches, or a gauge length at least 24 times thickness with a width not over 6 times thickness (authorized when cylinder wall is not over 3/16 inch thick).”
You further note, however, that for physical testing of DOT Specification 4L cylinders under § 178.57(j)(2)(i), the criterion for the cylinder wall is “not over 1/16 inch thick.” You ask whether this value is correct or whether it should read “not over 3/16 inch thick” consistent with the value for other DOT specification cylinders.
The criterion for the cylinder wall should read “not over 3/16 inch thick.” Under rulemaking HM-220B (61 FR 25940; May 23, 1996), we restructured the cylinder specification requirements by consolidating repetitive requirements and implementing other formatting changes. In doing so, for a DOT Specification 4L cylinder, the cylinder wall thickness value was inadvertently changed to “1/16 inch.” Prior to HM-220B, the value had been “3/16 inch” consistent with the other DOT specifications. We thank you for bringing this matter to our attention. PHMSA will revise this language in a future rulemaking.
I hope this information is helpful. If you have further questions, please contact this office.
Sincerely,
Robert Benedict
Chief, Standards Development Branch
Standards and Rulemaking Division
178.57
Regulation Sections
| Section | Subject |
|---|---|
| 178.57 | Specification 4L welded insulated cylinders |