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Important DOT Cylinder Requalification Changes

Updated: Jan 19, 2021

Through an oversight in 2016, the U.S. Department of Transportation (DOT)’s Pipeline and Hazardous Materials Safety Administration (PHMSA) inadvertently changed 49 CFR 180.209(e). The change reduced the DOT cylinder requalification period following hydrostatic testing, also known as volumetric expansion testing, from 12 years to 10 years. This change did not appear in the 2015 proposed federal rule changes and was not addressed in any form when the change ended up in the 2016 final rule.

The National Propane Gas Association (NPGA) made PHMSA aware of this error and aggressively petitioned through regulatory and Congressional channels for this error to be corrected for the last several years.

In 2017, NPGA did secure temporary relief through an Enforcement Discretion Memorandum from the PHMSA, which permitted either the 10 year or 12-year requalification periods, while PHMSA further investigated the issue.

On October 30, 2020, the PHMSA adopted a final rule to “officially” return the cylinder requalification by hydrostatic testing to 12 years. The interval for external visual requalification will remain at 5 years.

NPGA has created a downloadable and printable DOT Cylinder Requalification Fact Sheet to further highlight and compare the changes.

Regulatory Relief: See What You Can Use Instead of Costly CGA Pamphlets Now

On a similar note, 49 C.F.R. 180.209(g) requires that the requalification of cylinders by the external visual inspection method is performed in accordance with C.G.A. Pamphlet C-6 or C.G.A. Pamphlet C-6.3.  There was confusion about whether facilities performing external visual inspections must purchase an edition of the applicable C.G.A. pamphlet or is it permissible to use alternative training material that includes the same information on inspection, condemnation, rejection, and requalification? NPGA requested a Letter of Interpretation from D.O.T. to get clarification on what is permissible under regulation. The U.S. DOT PHMSA Letter of Interpretation clarifies that facilities performing a visual inspection to requalify cylinders must have the information in the referenced materials; however the regulation does not require facilities to purchase the information from a particular organization like the Compressed Gas Association (C.G.A.). By utilizing PERC Cylinder Requalification materials, the industry could satisfy the regulatory requirement and will not be required to purchase the C.G.A. Pamphlets C-6 or C-6.3. since PERC’s cylinder requalification materials contain similar information.

How Do I Get PERC Cylinder Requalification Materials?

  1. Download. The FREE downloadable training program digital bundle includes a 128 page cylinder requalification training manual, 162 slide power point with embedded videos. Click here to download bundle.

  2. Order. You can purchase a printed hard copy training manual with or without a USB with PowerPoint through Propane Service Corporation (PSC). Call PSC at (800)392-0023 to order. Additionally, did you know PERC offers FREE online Cylinder Requalification Training? Go to PERC's new Online Learning Center at Register to use the online training center for first time users or login for returning users. Click on Safety & Technical Training and then select Cylinder Requalification Training.

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