Interpretation Response #13-0075 ([Western International Gas & Cylinders] [Dr. Wesley D. Scott])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Western International Gas & Cylinders
Individual Name: Dr. Wesley D. Scott
Location State: TX Country: US
View the Interpretation Document
Response text:
May 15, 2012
Dr. Wesley D. Scott
Western International Gas & Cylinders
P.O. Box 668, 7173 Highway 159 East
Bellville, Texas 77418
Ref No.: 13-0075
Dear Dr. Scott:
This is a response to your April 4, 2013 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 100-185) with regard to UN pressure receptacles. Specifically, you request clarification of the “H” marking required by § 173.301b(f) and the filling of steel UN pressure receptacles.
In your email you note that § 173.301b(f) requires that a steel UN pressure receptacle bearing an “H” mark be used for hydrogen bearing gases. You indicate that based on information provided at Compressed Gas Association (CGA) meetings and discussions with Mark Toughiry of PHMSA’s Engineering and Research Division, the intent of this section is not to limit pressure receptacles bearing an “H” marking exclusively to hydrogen bearing or embrittling gas service. You request confirmation that pressure receptacles bearing the “H” mark are suitable for use for all gases in which a steel cylinder is specified as acceptable.
It is the opinion of this office that pressure receptacles bearing the “H” mark may be filled with hydrogen bearing gases, embrittling gases, or any other gases for which a steel pressure receptacle is indicated as appropriate. For hydrogen bearing and embrittling gases for which Special Provision N89 is listed in column 7 of the Hazardous Materials Table (HMT) in
§ 172.101 and when a steel UN pressure receptacle is used, that pressure receptacle must bear the “H” mark.
I hope this information is helpful. If you have any more questions, please do not hesitate to contact this office.
Sincerely,
Robert Benedict
Chief, Standards Development
Standards and Rulemaking Division
173.301b, 172.101