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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 #19-0093

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

Interpretation Response Details

Response Publish Date:

Company Name: Sherwood Valve

Individual Name: Joseph L. Lacek II

Location State: PA Country: US

View the Interpretation Document

Response text:

October 28, 2019

Joseph L. Lacek II, P.E.
Sherwood Valve
100 Business Center Dr.
Suite 400
Pittsburgh, PA  15205

Reference No. 19-0093

Dear Mr. Lacek:

This letter is in response to your June 21, 2019, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to cylinder valves in § 173.301(a)(11). You seek clarification of the statement that cylinder valves manufactured on or after November 7, 2019, must conform to the requirements in CGA V-9, "Compressed Gas Association Standard for Compressed Cylinder Valves," Seventh Edition, 2012. You note that while CGA V-9 lists a series of tests that valves must pass, there is no mention of self-closing valves (C10 or pin style valves). You state that the International Organization for Standardization (ISO) 17879 has testing that self-closing valves must pass that is similar to the test specified in CGA V-9. Therefore, you ask if conformance with CGA V-9 as specified in § 173.301(a)(11) is required for a self-closing valve.

The answer is no. The intent of § 173.301(a)(11) is to ensure that all applicable cylinder valve types conform to requirements in CGA V-9. It was not PHMSA's intent to prevent the use of other types of valves that may not be covered in CGA V-9, such as self-closing valves used in paintball cylinders. Since self-closing valves are not covered in CGA V-9, the requirements in CGA V-9 do not apply to self-closing valves. It is recommended, but not required, that self-closing valves be designed and tested to applicable safety standards, such as ISO 17879.

I hope this information is helpful. Please contact us if we can be of further assistance.

Sincerely,

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

173.301(a)(11)

Regulation Sections

Section Subject
173.301a Additional general requirements for shipment of specification cylinders