Interpretation Response #13-0032 ([Complete Cylinder Service, Inc.] [Mr. Paul Kleier, Jr.])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Complete Cylinder Service, Inc.
Individual Name: Mr. Paul Kleier, Jr.
Location State: OH Country: US
View the Interpretation Document
Response text:
May 29, 2013
Mr. Paul Kleier, Jr.
President
Complete Cylinder Service, Inc.
1240 Glendale Milford Road
Cincinnati, OH 45215
Reference No. 13-0032
Dear Mr. Kleier:
This is in response to your January 17, 2013 letter asking for clarification of the “DT” and “S” marking requirements for cylinders prescribed in §§ 173.304a(d)(4) and 180.213(f)(4) and 180.213(f)(6), respectively, of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You ask if the “DT’ stamp marked on a cylinder represents that a cylinder valve is equipped with a dip tube or siphon tube. You also ask if an “S” stamp marked on a cylinder may be used to represent that the cylinder is equipped with a siphon tube and that it has successfully completed a “proof pressure test.”
Under the HMR, the letters “DT” stamped on a cylinder mean that the cylinder is equipped with a removable-type, fixed-length dip tube gauging device (here-in referred to as “dip tube”) that may be used to verify the quantity of its contents, and that the cylinder complies with specific design and hazardous material content requirements prescribed in § 173.304a(d)(4). These requirements include that the cylinder: 1) must only contain liquefied petroleum gas with a specific gravity of 0.504 or greater at 16 °C (60 °F), 2) has a water capacity of 90.72 kg (200 pounds) or more, 3) is stamped on its exterior surface and on the exterior of the dip tube with the letters “DT,” and 4) is stamped on its dip tube after the DT stamp with the length of the dip tube expressed in inches and carried out to one decimal place (see § 173.304a(d)(4)). The letter “S” stamped on a cylinder represents that the cylinder has either successfully completed the proof pressure test prescribed in § 180.209(e), or that it is a successfully requalified shell of a DOT 8 series cylinder (see § 180.213(f)(4) and (f)(6)). The letter “S” does not represent that a cylinder is equipped with a siphon tube.
I hope this satisfies your request.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
173.304a(d)(4), 180.213(f)(4), 180.213(f)(6)