Interpretation Response #05-0009 ([Fike Corporation] [Mr. Randy Pettitt])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Fike Corporation
Individual Name: Mr. Randy Pettitt
Location State: MO Country: US
View the Interpretation Document
Response text:
Mar 18, 2005
Mr. Randy Pettitt Reference No. 05-0009
Welding Specialist-Mechanical Engineering
Fike Corporation
704 South 10th Street
Blue Springs, Missouri 64013
Dear Mr. Pettitt:
This responds to your letter and subsequent telephone conversation with Cheryl Freeman, Office Hazardous Materials Technology, concerning requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to authorized materials for construction of Specification 4BW cylinders. Specifically, you asked if you are correct that § 178. 61(b)(2) contains a typographical error as it pertains to the authorized material for Specification 4BW cylinder heads.
Authorized materials for construction of Specification 4BW cylinders are specified in § 178.61(b). Section 178.61(b)(1) authorizes the use of materials listed in Table 1 of Appendix A. Material for heads are prescribed in § 178.61(b)(2), in addition to the materials listed in Table 1 of Appendix A. Low carbon steel is an authorized material of construction. Low carbon steel is a steel with a carbon content typically 0.06% to 0.13%. You are correct that, as currently written, § 178.6 1(b)(2) references § 178.6 1(a), which applies to the type, size, and service pressure of specification 4BW cylinders and not the authorized material for heads. The reference should be § 178.61 (b)(l). We will correct the authorized material requirements in a future rulemaking.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
178.61