Summer Brings Wave Of Hot Topics

GHS Labeling

Hopefully by the time you read this, you are well on your way to having the new cylinder decals on your cylinders. The deadline was to have all cylinders you fill with the new decals on them as they ship by June 1, 2015. There is nothing in the regulations that requires you to change the decals on the cylinders shipped prior to that date, so you don’t need to go out to your customers and change these until they come back to get filled again. The same goes for the cylinders in your plant. You only have to make sure the new cylinder decals are on the cylinders shipped after June 1. If you have cylinders filled by another vendor, then you have until December 1 to have new decals on those cylinders shipped after that date.

Propane Storage & Handling

DOT regulations state the following: 49 CFR 173.301 (f)(2) After December 31, 2003, a pressure relief device, when installed, must be in communication with the vapor space of a cylinder containing a Division 2.1 (flammable gas) material. Very simply, we don’t lay down LPG cylinders unless they are designed to do so, i.e. forklift cylinders but only when positioned so the safety is on the up side. That is the purpose of the indexing pin and hole on the forklift and cylinder.

If the cylinder is positioned so that the liquid is in contact with the safety and it leaks, then you have liquid coming out instead of gas; liquid propane expands to gas 270 times, which means you instantly have 270 times the problem.

NFPA 58 also has some additional information that GAWDA membership needs to bear in mind. When transporting cylinders in an enclosed vehicle, there is a limit of 45 pounds of product per cylinder and a total of 90 pounds in all cylinders transported in the vehicle.

Please note that GAWDA has issued many warnings over the years about transporting cylinders in vehicles. GAWDA has a brochure on a suggested policy and guidelines entitled “Policy on Auto Transportation of Compressed Gas Cylinders.” If you need a copy of this, please ask and I will send it to you.

DOT Audits

Are you ready for an audit? Don’t keep putting your head in the sand hoping that it will go away. It won’t. Still hoping that you won’t be noticed? You will. Remember, you are carrying hazardous materials which are high profile items. Have a serious accident and you will be investigated. I have an audit checklist and a suggested recordkeeping checklist for you by simply asking for it via email.

Sleep factor, you know what that is. Everyone wants to sleep better at night knowing that they are properly managing their company risks. No matter how much out of compliance you may be, getting back on track is really a lot easier than you think. Call your consultants for help and get started.

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.