Interpretation Response #22-0043
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
September 8, 2022
Mr. W. Mark Nelson
Alabama Liquefied Petroleum Gas Board
777 S. Lawrence St., Suite 100
P.O. Box 1742
Montgomery, AL 36102-1742
Reference No. 22-0043
Dear Mr. Nelson:
This letter is in response to your May 3, 2022, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to requalification records for the visual inspection of Department of Transportation (DOT) specification cylinders. In your letter, you state that you have a requalifying facility that is currently considering the utilization of equipment that takes a panoramic photo of data on cylinders, which have been visually inspected and batched according to the inspector’s findings as follows:
- The cylinders will be batched for photos according to one of the three disposition codes: "OK-Return to Service," "SC-Scrap," or "RM-Return to manufacturer for repair."
- Cylinders whose data is not legible due to excessive paint will first be routed to the sandblast facility to provide for quality photos.
- Photo files will be indexed according to the inspection date, inspector, and disposition codes.
- All cylinders will be 20 lb. steel propane cylinders so "size information" will be the same for all, but magnetic decals can be applied for photos indicating size.
- Additional information can be provided using small magnetic labels applied prior to photographing to detail such information as the “Protective Coating” (Type and Condition). For example – "Paint-Excellent."
- All information currently maintained in handwritten physical logbooks will be available in the photograph files of each cylinder that has been inspected.
Lastly, you state that you believe that photographic records would be more precise because handwritten records often afford the opportunity for human error such as transposing numbers within a serial number or other data. You ask whether the cylinder test records—currently maintained in handwritten logbooks—may be maintained in the form of digitally indexed photographic files as described above.
Provided all the information specified in § 180.215(b) for the requalification records of DOT specification cylinders is contained in the photographic files and a means of organizing and indexing them is included, a photographic system of recordkeeping as described in your letter would be acceptable under § 180.215(b) of the HMR.
I hope this information is helpful. Please contact us if we can be of further assistance.
T. Glenn Foster
Chief, Review and Reinvention Branch
Standards and Rulemaking Division
|Reporting and record retention requirements