Two Texas Investigators from U.S. DOT's Pipeline Hazardous Materials Administration shared the top compliance issues they are finding in the Southwest including Texas at the 2021 TPGA Convention. Check the issues out below: • PVIK inspections/markings up-to-date on CTs/180.407&415 • Security Plan/review it annually/172.800 • Moving ASME tanks/173.315(j) • Filling cylinder that is out of test/173.301 • Written emergency shut down procedures/177.840(l) • Remote Shut-off/177.840(O) • Documenting monthly hose inspection/piping/180.416(d) • DOT registration/carry in truck/107.620/107.608 • Train hazmat employees—172.700 / Driver Training • Maintain cargo tank birth certificates/180.417 • Cylinder requalification RIN compliance with requirements in 49 CFR 180.205/180.209/180.215 including not having RIN Approval letter or cylinder requalification training guides (either the CGA's or PERC's cylinder requalification book). U.S. DOT wanted TPGA to share a copy of the presentation with those that attended and couldn't attend. Download the presentation for further details on the above.
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