(Question on shipment of Gas Cylinders.)
Q.
(1) 7.2.2.3.2 (b) states “cylinders for Class 2 may on account of their shape, orientation and securing mechanisms for transport bear labels representative of those specified in Subsection 7.3, which have been reduced in size, according to ISO 7225-2005 “Gas cylinders – Precautionary labels”, for display on the non-cylindrical part (shoulder) of such cylinders.”
According to the requireents of the DGR, minimum dimension of the label is set at 100mm. Is it permissible to reduce the size per ISO 7225-2005?

(2) 5.2.0.6 reads: “Cylinders and closed cryogenic receptacles must be filled according to the working pressures, filling ratios and provisions specified in the appropriate packing instructions of the specific substance being filled.”
Is the term “working pressure” same as “test pressure” shown on Table 200.B?
​Packing Instruction 200 in paragraph (b) lists:
​4. the minimum test pressure of the cylinders;
5. the maximum working pressure of the cylinders for compressed gases (where no value is given, the working pressure must not exceed two thirds of the test pressure) or the maximum filling ratio(s) dependent on the test pressure(s) for liquefied and dissolved gases.
From this statement, we figure working pressure is something different from test pressure.
What is meant by “minimum working pressure” mentioned in item 4?
Furthermore, in reference to item 5, Table 200.A does not show any column for working pressure. Please guide me where should I look for.

(3) 5.2.0.10 quotes: “Refillable cylinders, other than closed cryogenic receptacles, must be periodically inspected according to the provisions of 6.4.1.6 and Packing Instruction 200 or 214.”
Is it correct to take the “Test Period” figures on Table 200.A or Table 200.B as the test period mentioned in 6.4.1.6? If it says 10 years, the test must be done every ten years. Kindly clarify?
There are multiple test pressure indicated with some of the gases on Table 200.B. Kindly explain how to interpret this.

(4)We are mixed up as the Japanese Aviation Code as well as the Japanese Gas Code defines Class 2 as “Compressed Gas” whereas ICAO/IATA uses the simple term “Gases” for Class 2 substances. Please clarify the difference.  (30 Nov 18)
A.
(1) 7.2.2.3.2 (b) has provided an exception to the dimentional requirement. Yes, it is permitted to use a smaller label provided the requirements of 7,2,2,3,2 (b) are met.

(2) 5.2.0.6 Working Pressure is not the same as Test Pressure. Working Pressure must not be greater than the Test Pressure. Since a working pressure differs with any project, it cannot be treated as a fixed value therefore it is not shown in the Tables.
PI 200 (b) quotes: “Tables 200.A and 200.B provide;
4. the minimum test pressure of the cylinders;
5. the maximum working pressure of the cylinders for compressed gases (where no value is given, the working pressure must not exceed two thirds of the test pressure) or the maximum filling ratio(s) dependent on the test pressure(s) for liquefied and dissolved gases.”

The term “minimum test pressure” in item 4. means the benchmark pressure when exceeded will damage the cylinder being tested.
The filling ratio is shown on Table 200.B in the second from last column.
As stated in item 5, any working pressure must not be higher than two thirds of the applicable test pressure.
As reference, please refer to Table 6.4.A UN Specification Marking – Cylinders and look at the first two columns on the second line. You will see Working Pressure (i) 200 bar with the next column being Test Pressure (f) 300 bar. The Working Pressure is kept at two thirds of the Test Pressure.

(3) 5.2.0.10 Yes, correct. What you wrote is correct. Please refer to Table 6.4.A UN Specification Marking – Cylinders and see the last column on the third line. It says: Initial Inspection Date 2017.04 indicating the initial inspection was done in April 2017. DGR 6.4.2.7.2 (e) specifies that the date of inspection must be recorded. If the Test Period is 10 years, the next inspection will be due in April 2027.
With some of the gases on Table 200.B have multiple test pressure values indicated. This is to apply to different size cylinders. For example, take UN1022 Chlorotrifluoromethane (Refrigerant Gas R13). Test period is 10 years, and the smallest cylinder is tested at 100 bar Filling ratio 0.83, the next larger one at 120 bar Test temperature with 0.90 Filling ratio, the next larger cylinder at 190 bar Test pressure Filling ratio 1.04 and the largest cylinder is tested at 250 bar Filling ratio 1.11.

(4)Class 2 in ICAO/IATA terminology is “Gases”.
There are three types of gases from their characteristics,
1. Division 2.1 Flammable gas,
2. Divisiion 2.2 Non-flammable non-toxic gas, and
3. Division 2.3 Toxic gas.
From its physical state, the transport condition is described in 5 types, e.g.,
(a) Compressed Gas,
(b) Liquefied Gas,
(c) Refrigerated Liquefied Gas,
(d) Dissolved Gas, and
(e) Adsorbed Gas.
Please refer to DGR 3.2.1.2 (a) through (e) for definition.

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