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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 #12-0170 ([Sandler, Travis & Rosenberg, P.A.] [Mr. Mark Ludwikowski])

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

Interpretation Response Details

Response Publish Date:

Company Name: Sandler, Travis & Rosenberg, P.A.

Individual Name: Mr. Mark Ludwikowski

Location State: DC Country: US

View the Interpretation Document

Response text:

This is in response to your August 7, 2012 letter requesting clarification of the term "lot" as it pertains to the testing of rupture disks in accordance with Compressed Gas Association (CGA) publication S-1.1. Specifically you ask for confirmation of the appropriate lot size for the purposes of testing and subsequent shipment of rupture disks in accordance with the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180).

Section 6.3.1 of CGA S-1.1 (Rupture disk burst pressure measurement) requires testing of at least 2 samples from each lot (no more than 3,000) of rupture disks. Section 6.3.2 requires testing of at least 2 samples from each lot (no more than 3,000) of rupture disk holders which are assembled with rupture disks. Section 6.3.3 provides that testing of the rupture disk holders which are assembled with rupture disks will satisfy the testing requirements of both 6.3.1 and 6.3.2, so long as the specific tests specified in those two sections are successful.

For the purposes of testing rupture disk devices in accordance with CGA S-1.1, a lot is considered to be not more than 3000 disks or rupture disk holders. So long as tests are performed in samples from each lot of not more than 3,000 rupture disks and rupture disk holders, any number of these items may be packaged together for shipment and called a "lot".

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, 173.304a, 178.75

Regulation Sections

Section Subject
173.301 General requirements for shipment of compressed gases and other hazardous materials in cylinders, UN pressure receptacles and spherical pressure vessels
173.304a Additional requirements for shipment of liquefied compressed gases in specification cylinders