Interpretation Response #99-0277 ([Thunderbird Cylinder, Inc.] [Mr. Fred A. Nachman])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Thunderbird Cylinder, Inc.
Individual Name: Mr. Fred A. Nachman
Location State: AZ Country: US
View the Interpretation Document
Response text:
November 24, 1999
Mr. Fred A. Nachman Ref. No. 99-0277
President, Thunderbird Cylinder, Inc.
4209 E. University Drive
Phoenix, AZ 85034-7315
Dear Mr. Nachman:
This is in response to your letter dated October 7, 1999, requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR 171-180). Specifically, you ask whether the depth measurement of a gouge, dig or cut in a DOT specification acetylene cylinder is measured from the original wall of the cylinder or from the top to the bottom of the gouge, dig or cut itself. You enclosed a sketch depicting a gouge in the center of a dent.
The HMR do not currently provide for a measurement when a gouge is inside of a dent, as depicted in your sketch. Section l73.34 (e) (18)of the HMR prescribes that a DOT specification acetylene cylinder must be requalified in accordance with the Compressed Gas Association (CGA)Pamphlet C-13.
Based on the criteria contained in the pamphlet, two measurements must be taken. The dent is evaluated according to the criteria prescribed in paragraph 4.6.4 and the depth is measured as represented by A on my enclosure. The gouge is evaluated according to the criteria prescribed in paragraph 4.6.4 and the depth is measured as represented by B. If either measurement does not meet the tolerances specified in CGA Pamphlet C-13, the cylinder must be condemned.
I hope this information is helpful. Should you have further questions, please contact us.
Sincerely
Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.34