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)