Interpretation Response #19-0109
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Worthington Cylinder Corporation
Individual Name: Shane Decker
Location State: OH Country: US
View the Interpretation Document
Response text:
February 19, 2020
Shane Decker
Worthington Cylinder Corporation
200 Old Wilson Bridge Road
Columbus, OH 43085
Reference No. 19-0109
Dear Mr. Decker:
This letter is in response to your August 28, 2019, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to closure instructions for cylinders. Your questions are paraphrased and answered below:
Q1. You ask whether cylinders are covered by the closure requirements in § 178.2(c)(1)(i)(B).
A1. The answer is yes. Cylinders are considered a package under the HMR and therefore could be subject to the closure requirements in § 178.2(c)(1)(i)(B). However, the Pipeline and Hazardous Materials Safety Administration (PHMSA) recognizes that closure instructions may not be necessary for certain types of cylinders, such as cylinders with self-closing valves.
Q2. You ask whether a cylinder valve is considered a form of closure under the HMR.
A2. The answer is yes. PHMSA considers the valve on a cylinder to be a form of closure under § 178.2(c)(1)(i)(B) of the HMR.
Q3. You state that the valves on your cylinders are marked with the words "open" and "close" along with the arrows indicating direction. You ask whether this information meets the closure requirements in § 178.2(c)(1)(i)(B) of the HMR.
A3. The answer is yes. It is the opinion of this Office that the markings you describe would be consistent with the closure requirements in § 178.2(c)(1)(i)(B) of the HMR. However, if the valve is removed or replaced at any stage then proper instructions for valve instillation must be obtained from the manufacturer or owner of the cylinder.
Additionally, closure instructions must provide for a consistent and repeatable means of closure that is sufficient to ensure the packaging is closed in the same manner as it was tested.
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
178.2(c)(1)(i)(B)
Regulation Sections
| Section | Subject |
|---|---|
| 178.2 | Applicability and responsibility |