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.