Cylinder Requalification

The emphasis for this magazine issue is cylinders, so I wanted to re-emphasize some points made in previous issues, along with some new items.

Two members have told me 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.

Allow me to 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. Only call them scrap cylinders after the DOT specification number and service pressure have been stamped out with a series of Xs. Then move them to the separate scrap pile.

Speaking of DOT audits, I have heard from two other members about having full-blown compliance reviews, one of which lasted several days. If you call me as soon as you hear that you are having an audit, I will be happy to give you several pointers on items that will be asked about.

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 in 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 will 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.

Use the words “cylinders in process” for all the cylinders that you throw into an out-of-service pile. Only call them scrap cylinders after the DOT specification number and service pressure have been stamped out with a series of Xs. Then move them to the separate scrap pile.

To apply for grantee status, follow the instructions found in 49 CFR 107.107, which are very simple. I highly suggest that you use the e-mail instructions they provide. You will get your authorization approval back in a few days. Just send an e-mail to specialpermits@dot.gov 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.

Cylinder Requalification
I always recommend that you audit your hydrotest vendors to ensure that they are doing everything properly. I published a Traffic Bulletin back in September 2005 that will give you questions to ask and the answers that you should get back. You can access it under the Consultants link at the Members Only page of GAWDA’s Web site.

Neck Leakers
If you are valving your own high pressure cylinders and having neck leakers, then see the September 2005 Traffic Bulletin mentioned above for a suggested procedure that virtually eliminates neck leakers.

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

Gases and Welding Distributors Association

Michael Dodd 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 MLDSafety@hotmail.com.