Interpretation on Rings

11/25/14 – You may or may not be aware of the flap surrounding some vessels manufactured by Tytal with rings that include a “gap” at the bottom (ostensibly for drainage). This was questioned and brought to PHMSA’s attention. After some investigation, it was concluded that this design is, in fact, A-OK, and NOT in violation of the statement in 178.345-7(d) that the reinforcement must be “continuous”. How can this be? Good question! PHMSA states in their interpretation here, that the verbiage is quite clear that “reinforcement” must be continuous. This does NOT necessarily mean that the ring itself must be continuous. How does a ring that is not continuous provide reinforcement that IS continuous? I hesitate to offer any opinion on this, other than to state that it involves much eye-rolling.