Interpretation Response #19-0051
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
October 15, 2019
CT Engineer II
The Hartford Steam Boiler Inspection and Insurance Co.
1 State Street
P.O. Box 5024
Hartford, CT 06102-5024
Reference No. 19-0051
Dear Mr. Mulet:
This letter is in response to your April 16, 2019, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to DOT 3AL seamless aluminum cylinders. Specifically, you ask whether the words "significant change" as used in § 178.46(c)(6) means an increase or decrease of the given criteria or just an increase in water capacity or base thickness, or the number of openings.
Section 178.46(c)(6) defines "significant change" applicable to DOT 3AL seamless aluminum cylinders as a 10% or greater change in cylinder wall thickness, service pressure, or diameter; a 30% or greater change in water capacity or base thickness; any change in material; over 100% increase in size of openings; or any change in the number of openings. The word "change" in the above paragraph means either an increase or decrease, meaning a "30% or greater change in water capacity" could be a 30% increase or a 30% decrease. Any of the above conditions would result in the change being considered significant for the purposes of § 178.46(c)(6).
I hope this information is helpful. Please contact us if we can be of further assistance.
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
|§ 178.46||Specification 3AL seamless aluminum cylinders|