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 initial 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.

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.

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 D.O.T. 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.

Additionally, did you know PERC offers FREE online Cylinder Requalification Training? Go to PERC's new Online Learning Center at https://training.propane.com. 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.