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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #12-0065 ([Chart Inc.] [Mr. Steve Therneau])

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

Interpretation Response Details

Response Publish Date:

Company Name: Chart Inc.

Individual Name: Mr. Steve Therneau

Location State: GA Country: US

View the Interpretation Document

Response text:

May 21, 2012

 

 

Mr. Steve Therneau
Chart Inc.
1300 Airport Drive
Ball Ground, GA 30107

Reference No.: 12-0065

Dear Mr. Therneau:

This responds to your February 27, 2012 letter requesting further clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the repair of Department of Transportation (DOT) 4 series specification cylinders. You request that the Pipeline and Hazardous Materials Safety Administration (PHMSA) reconsider a previously-issued letter of interpretation to you dated February 23, 2012 [Ref. No. 11-0237].

In your current letter, you state that it is your understanding that if the inner vessel of a DOT-4 series cylinder has not been compromised and repairs have only been completed on the outer vessel, § 180.211(c)(2)(i) is not applicable and there is no requirement to test the cylinder in accordance with the specifications under which the cylinder was originally manufactured.

As previously stated, your understanding with regard to cylinder repair is incorrect. The term "repair" is defined in § 180.203 as a procedure for correction of a rejected cylinder that may involve welding. A repair is not limited to the correction of a rejected cylinder that has had only its inner vessel compromised. Therefore, DOT-4 series cylinders requiring repair, as defined in § 180.203, must be done in accordance with § 180.211. In addition, DOT 4L cylinders must meet additional requirements for repair specified in § 180.211(c) including being pressure-tested in accordance with the specifications under which the cylinder was originally manufactured. DOT 4L cylinders which undergo procedures that are not defined as a repair in § 180.203 are not subject to the requirements of § 180.211(c) including the requirement to be pressure-tested in accordance with the specifications under which the cylinder was originally manufactured.
If a DOT-4 series cylinder requires repair as defined in § 180.203 and that cylinder is designed so that it is not possible to safely pressure test the cylinder in accordance with the specification with which the cylinder was originally manufactured, you may request a special permit to except the cylinder from the requirement to be subjected to the pressure tests specified in § 180.211(c) and (e). Your application should be directed to the Approvals and Permits Division and should include specific and detailed information concerning the rationale for excepting the cylinder from the pressure test requirements. The procedures for applying for a special permit are found in 49 CFR Part 107, Subpart B. You may also obtain this information at our website at http://www.phmsa.dot.gov/hazmat/regs/sp-a.

Sincerely,

 

T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

180.211, 180.203

Regulation Sections

Section Subject
180.203 Definitions
180.211 Repair, rebuilding and reheat treatment of DOT-4 series specification cylinders