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Interpretation Response #21-0100

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

Interpretation Response Details

Response Publish Date: 01-19-2022
Company Name: Hydro-Test Products, Inc.    Individual Name: Carlos Graca
Location state: MA    Country: US

View the Interpretation Document

Response text:

January 19, 2022

Carlos Graca
Hydro-Test Products, Inc.
85 Hudson Road
Stow, MA  01775

Reference No. 21-0100

Dear Mr. Graca:

This letter is in response to your October 27, 2021, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to recordkeeping requirements for specification cylinders. You state that the current regulations in § 180.215 and the changes made by the HM-234 final rule [85 FR 85380; 12/28/2020] outline informational requirements for the pressure test and test system verification, yet the information required to be recorded appears to be geared towards volumetric expansion testing. As an example, you note that for a proof pressure test, there are no expansion values available to be recorded. Therefore, you seek clarification regarding the necessary information that is required on a record for a proof pressure test.

We have paraphrased and answered your questions as follows:

Q1. You ask what information is required to be recorded for both the test system verification and the performance of a proof pressure test.

A1. Because a proof pressure test does not provide expansion values when verifying system accuracy or testing a cylinder, a person does not need to provide the information for "elastic and permanent expansions" or the "percent permanent expansion." Absent the expansion related data points, a person is still required to provide the remaining information outlined in § 180.215(b) as part of the daily test verification and actual test record. Moreover, CGA C-1 provides instruction associated with the proof pressure test for accuracy verification of a test system for both liquid and gas-based systems and notes a record of the verification must be made (see section 7.3 of CGA C-1). This relates back to the requalification record maintenance of § 180.215(b).

Q2. With respect to recordkeeping, you ask whether it is appropriate for PHMSA to reference a publication (e.g., CGA C-1) that does not offer any guidance on recordkeeping procedures for a proof pressure test or the accuracy verification of the test system.

A2. PHMSA disagrees with the characterization of the requalification requirements as inappropriate. The cylinder reporting and record retention requirements are found in § 180.215 and outline the data points to be included in the record. CGA C-1 supplements the reporting requirements for requalification of cylinders by providing instruction on how to properly verify test system accuracy and performing a test for requalification such that accurate information can be recorded. As provided in answer "A1," a person performing a proof pressure test is required to record all relevant information with the exception of expansion method data points.

Q3. You ask whether the new requirement to provide the manufacturing date and the gas service information is applicable for the proof pressure test.

A3. The answer is yes. As explained in the preamble of the HM-234 final rule, this information is useful for determining the eligibility of a cylinder for different requalification methods—for example—the proof pressure test in § 180.209(e) is only an option for cylinders filled with non-corrosive gas that is commercially free from corroding components. Thus, providing this information is relevant whether performing a requalification test by expansion method or by proof pressure method.

Q4. You ask whether a facility that has been approved and issued a requalifier identification number would be in violation of the HMR if the facility used the sample forms as provided in the CGA C-1 as is.

A4. The forms provided in the Appendices of the CGA C-1 pamphlet are sample forms provided to show how relevant information for cylinder requalification can be presented. Should a person choose to record data using the format of the sample forms, any missing information required by § 180.215(b) would need to be supplemented on the form or omitted as applicable.

Finally, please note that although the CGA C-1 provides sample forms for a person to utilize, these forms are not specifically required forms that must be used. A person may create a record using a format that best suits their individual needs provided all relevant data points are documented.

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


Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division

180.209(e), 180.215, 180.215(b)

Regulation Sections

Section Subject
§ 180.215 Reporting and record retention requirements