DOT approves NPGA petition on cylinder requalification

The Pipeline and Hazardous Materials Safety Administration (PHMSA) has approved the National Propane Gas Association’s (NPGA) petition on the requalification of Department of Transportation (DOT)-specification cylinders by hydrostatic testing, also known as the volumetric expansion testing method.

The action, announced by PHMSA in an Oct. 30 final rule, returns the requalification period to 12 years. NPGA reported the development in a member alert.

NPGA says it had previously identified an oversight by PHMSA as part of the agency’s development of a 2016 rule that changed 49 CFR 180.209(e), which reduced the initial requalification period for DOT-specification cylinders following volumetric expansion testing from 12 years to 10 years and increased the time frame for requalification following a proof pressure test from seven years to 10 years.

“In order to comply, thousands of propane marketers would have had to remove from service potentially millions of DOT cylinders to be requalified two years sooner than expected or planned for,” says NPGA President and CEO Steve Kaminski in an email to LP Gas.

PHMSA, an agency under DOT, did not provide any rationale for the changes, which resulted in a significant, negative impact on the propane industry, according to NPGA. The association took the fight to PHMSA and engaged the support of Congress, as well as prepared legal measures in order to secure a correction.

With PHMSA’s final approval of the petition, NPGA estimates regulatory savings of more than $100 million a year for the industry.

“It’s a big victory because the ramifications of the previous rule, which had no technical justification or safety benefit, would have caused widespread disruption across the industry, to the tune of $100 million every year in increased costs,” Kaminski says. “In addition, major changes to existing training materials and procedural manuals would have been required.”

The changes published in the final rule take effect Nov. 30, though voluntary compliance may begin Oct. 30, NPGA says.

After initial pushback from the NPGA, PHMSA released an enforcement notice in March 2017 that stated the agency would not take enforcement action against the requalification of DOT-specification cylinders by hydrostatic testing according to a 12-year period. Instead, the enforcement notice permitted a 12- or 10-year requalification period for volumetric expansion testing. With the latest changes, the enforcement notice will terminate Nov. 30.

Kaminski says NPGA couldn’t take any chances and rely solely on the enforcement notice as it relates to cylinder requalification regulations.

The regulatory action, NPGA also notes, does not impact the five-year cylinder requalification period for the external visual inspection method. It addresses this and other key points in a fact sheet titled DOT Cylinder Requalification Periods, which is available on its member dashboard.

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