Interpretation Response #99-0128 ([Safety and Compliance & Associates, Inc.] [Mr. Mike Lopez])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Safety and Compliance & Associates, Inc.
Individual Name: Mr. Mike Lopez
Location State: AL Country: US
View the Interpretation Document
Response text:
May 27, 1999
Mr. Mike Lopez Reference No. 99-0128
Safety and Compliance
Associates, Inc.
P.O. Box 48
Trussville, Alabama 35173
Dear Mr. Lopez:
This responds to your letter, dated May 10,1999, concerning the requirements for cylinder repair and marking in the Hazardous Materials Regulations(HMR; 49 CFR Parts 171.180). Your specific questions are paraphrased and answered below.
QI: Is a company that is neither a cylinder manufacturer nor
an authorized repair facility allowed to braze, weld, or perform similar applications involving het to attach gas inlet, outlet, and/or vent fittings to the piping system of a DOT 4L cylinder?
Al: No. Section 173.34(i) of the HMR authorizes repair of a
DOT-4 series cylinder by welding or brazing to be performed only by performed only by a manufacturer of this type of DOT specification cylinder or by a repair facility approved by the Associate Administrator for Hazardous Materials Safety.
Q2: Is a company that is neither a cylinder manufacturer nor an authorized repair facility allowed to braze, weld, or perform
similar applications involving heat to any portion of the foot ring, neck ring, top ring, or top ring supports of a DOT-4 series cylinder for the purpose of attaching an identifying plate or marking plate pursuant to §173.34(c)?
A2: No. See response to Question 1 above.
Q3: What is the maximum allowable stamping depth for DOT specification cylinders?
A3: Generally, markings on cylinders must be of a size and depth that will not create harmful stress concentrations. The marking application must ensure that the wall thickness from the root of the stamping to the interior surface is greater than or equal to the minimum wall thickness as prescribed in the manufacturingspecification. The person applying the marking may need to consult with the cylinder manufacturer to determine allowable stamping depths.
I hope this information is helpful. If you have further questions,
please do not hesitate to contact this office.
Sincerely,
Thomas G. Allan
Acting Director, Office of Hazardous Materials Standards
173.34