Interpretation Response #19-0102

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

Interpretation Response Details

Response Publish Date: 01/14/2020

Company Name: Chart Inc.

Individual Name: Bruce Sanborn

Location State: MN Country: US

View the Interpretation Document

Response text:

January 09, 2020

Bruce Sanborn
Regulatory Compliance Manager
Chart Inc.
407 Seventh Street N.W.
New Prague, MN  56071

Reference No. 19-0102

Dear Mr. Sanborn:

This letter is in response to your July 31, 2019, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the manufacture of DOT Specification 4L cylinders. You seek confirmation of your understanding that the phrase "same condition" as used in § 178.57(j)(1) means the sheet or plate material has received all plate processing operations—including heat treatment—as the material used to form the heads and the cylinder. Specifically, you ask whether tensile test samples may be taken from the flat plate that will be used to form the heads or cylinder, or whether the samples must be taken from the head or cylinder after forming.

Tensile samples must be taken from either the head or cylinder after it has been formed. In accordance with § 178.57(j)(1), "the test is required on 2 specimens selected from the material of each heat and in the same condition as that in the completed cylinder." In other words, a sample from the flat plate that will be used to form the head or the cylinder would not be in its completed form or in the condition of a completed cylinder. Therefore, the test sample must be taken from either the head or the cylinder once the cylinder has been formed.

I hope this information is helpful. Please contact us if we can be of further assistance.

Sincerely,

Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division

178.57(j)(1)

Regulation Sections