SP-14175, The 10-Year Retest On Clusters

Here is a helpful item for anyone who uses cradles, 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 10 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 10 years on the requalification. Here is a brief recap of the provisions in the special permit:

  • The cylinders must be 3A or 3AA.
  • The gases must be air, argon, helium, hydrogen, oxygen, nitrogen, compressed gas n.o.s. (mixture of hydrogen, argon, helium, oxygen, and/or nitrogen), or compressed gas flammable n.o.s. (mixture of hydrogen, argon, helium, and/or nitrogen).
  • The cylinder may be requalified by either the hydrostatic testing and visual inspection or by ultrasonic examination (UE) in accordance with existing DOT special permits. The 10-year requalification period applies only to cylinders that meet all requirements specified in 180.209(b), except they are not removed from bundles and hammer tested prior to each refill.
  • Carbon dioxide in any concentration cannot be added to the cylinders in the bundle.
  • Gases that are either toxic and/or corrosive cannot be added to cylinders in the bundle.
  • Each cylinder covered by this special permit must be plainly and durable marked “DOT-SP 14175” in proximity to existing DOT markings. This can be done with decals or stamping. Additionally, one cylinder on each side of a bundle must be marked DOT SP-14175 with letters at least one-inch high on a contrasting background.
  • You must keep a current copy of this special permit at each location that ships these bundles.
  • Documented training for all employees who perform a function under this Special Permit.

Please read the entire special permit for all of the details and fine print.
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. To apply for grantee status, follow the instructions found in 49 CFR 107.107 and be very careful to answer each and every question or your application will be rejected.

I can supply you with a sample application form to become a party to SP-14175. Just ask.

Please note that the intent is to use new or freshly retested cylinders that meet the 10-year retest requirements when you put together the cradle and start using the SP-14175. DOT does not intend for you to take existing cradles and just mark them up and start using this permit.

Feel free to contact me on any of these items if you have questions.

Gases and Welding Distributors Association
Michael Dodd Meet the Author
GAWDA’s DOT, Security, OSHA & EPA Consultant Michael Dodd is president of MLD Safety Associates in Poplar Bluff, Missouri. Members can reach him at 573-718-2887 and MLDSafety@hotmail.com.