Annual Driver Review

At least every 12 months, a motor carrier must review the driving record of each driver, including compliance with Federal Motor Carrier Safety Regulations and Hazardous Materials Regulations.

This review is a three-part process. First, have the driver certify the previous 12 months of driving violations. Then, check his or her records, including the appropriate state motor vehicle record (MVR), for any violations. Finally, as the carrier, you certify whether or not the driver is qualified to continue driving.

I bring this up because I find that many people are not:

  1. Doing reviews before the date they did them the year before
  2. Doing the three-step process or
  3. Keeping the reviews for the required three-year retention period.

DOT Audits Going On Around You
Two members have told me recently about inspectors from the Pipeline & Hazardous Materials Safety Administration (PHMSA) coming in to review either their cylinder filling operations or their cylinder requalification. Two items are common to both exit interviews: not properly marking condemned cylinders and not recording them on any paperwork. A third item was not conducting the hammer test on cylinders going for ten years between requalification.

Let me give you a very helpful hint. Teach your people to use the words “cylinders in process” for all the cylinders that you throw into an out-of-service pile. Call them scrap cylinders only after the DOT specification number and service pressure have been stamped out with a series of Xs. Then you may move them to the separate scrap pile.

Ten-Year Testing of Clusters/Banks
How about something to save you some money for a change? Here is a helpful item for anyone who uses clusters, 12 packs, 6 packs, banks or whatever else you may call them. For all these years, we have had to do the cylinder requalification on a five-year schedule. Wouldn’t you love to be able to do the retest on these cylinders every ten years?

There is a special permit (SP-14175) that allows certain cylinders for certain flammable and nonflammable gases in bundles up to 24 cylinders to go ten years on the requalification. To take advantage of this special permit, you need to apply for, and receive back from DOT, a grantee letter that has your company name listed, and then follow the terms of the special permit. To apply for grantee status, follow the simple instructions found in 49 CFR 107.107. I strongly suggest that you use the e-mail instructions they provide. You will get your authorization approval back in a couple of days. Just send an e-mail to and identify by number the special permit application or special permit to which the applicant seeks to become a party. State the name, street and mailing addresses, e-mail address (optional) and telephone number of the applicant; if the applicant is not an individual, state the name, street and mailing addresses, e-mail address (optional) and telephone number of an individual designated as the applicant’s agent for all purposes related to the application.

As always, if there are questions or items with which I can help you, please don’t hesitate to contact me.

Gases and Welding Distributors Association
Meet the Author
GAWDA DOT, OSHA & EPA Consultant Michael Dodd is president of MLD Safety Associates in Poplar Bluff, Missouri. Members can reach him at 573-785-5111 and at