Interpretation Response #99-0040 ([Department of California Highway] [Mr. Paul Horgan])

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

Interpretation Response Details

Response Publish Date: 03/02/1999

Company Name: Department of California Highway

Individual Name: Mr. Paul Horgan

Location State: CA Country: US

View the Interpretation Document

Response text:

MAR 2, 1999

Mr. Paul Horgan                           Ref. No. 99-0040

Department of California Highway

P.O. Box 942898

Sacramento, CA 94298

This is in reference to our conversation on February 3, 1999, concerning the proper orientation for loading certain DOT 4L cylinders which are being used in oxygen, refrigerated liquid service. The requirements in 49 CFR 173.316(c) and 177.840(a)(1) specify that DOT 4L cylinders must be loaded (on a motor vehicle) in an upright position.

The cylinders in question were designed and constructed to be used and transported with the longitudinal axis of the cylinders positioned, horizontally. Because of the unique design of these DOT 4L cylinders, the vapor space is along the longitudinal axis of the cylinder. Therefore, it is this office's determination that these cylinders are "upright" when they are transported in a horizontal position, as the safety relief devices are in communication with the vapor space of the cylinder. This type of positioning enables the pressure relief devices to function and protect the cylinder in a safe manner as intended. Accordingly, we find that the transportation of these cylinders in a horizontal position conforms with the requirements in §§ 173.316(c) and 177.804(a)(1). We proposed a revision to § 177.804(a)(1) in a recent notice of proposed rulemaking (RSPA 98-3684 HM-220; October 30, 1998).

I hope this information is helpful.  If we can be of further assistance, please contact this office.

Sincerely,

Hattie L. Mitchell

Chief Regulatory Review and Reinvention

Office of Hazardous Materials Standards

177.840

Regulation Sections