DOT cylinder requalification rule to impact propane marketers

January 19, 2017 By    

The Department of Transportation (DOT) finalized a rule last year that affects the time frame for the requalification of propane cylinders and is set to take effect Jan. 23, according to the National Propane Gas Association (NPGA).

The new rule impacts anyone who requalifies, fills, transports or prepares shipments of DOT cylinders. The changes were part of a Pipeline and Hazardous Materials Safety Administration (PHMSA) rulemaking titled HM-233F, which was published as a final rule on Jan. 21, 2016. HM-233F incorporated about 100 special permits into the federal hazardous materials regulations, NPGA says. The changes modify 49 CFR 180.209e of the hazardous materials regulations.

The rule reduces the initial requalification period for DOT cylinders from 12 years to 10 years from the date of manufacture. It reduces the period from 12 years to 10 years for cylinders requalified using volumetric expansion testing. However, the requalification period for DOT cylinders following a proof pressure test increases from seven years to 10 years. The five-year visual inspection method for cylinder requalification does not change.

NPGA estimates the new rule will affect at least 5 million DOT-specification cylinders, including many that are used for home heating, forklifts and grill cylinders. Additionally, NPGA adds that the rule will likely affect about 3,000 propane marketers.

“We have a practical concern that now marketers must make a change to how they conduct business, how they review and requalify cylinders and how they educate and train employees,” says Sarah Reboli, director of regulatory affairs at NPGA. “The second concern is that this change has come across without any discussion, rationale, justification or evaluation. After the rule had been finalized, we identified that the change quite literally snuck into the back of the rulemaking.”

The association has been in communication with PHMSA regarding the rulemaking, and has sent a formal petition for a stay of enforcement in order to review the intent of the changes. In addition, NPGA and the Propane Education & Research Council (PERC) have been working closely regarding the issue.

“PERC is handling the education and safety side of this to address materials that need updated,” says Mollie O’Dell, vice president of communications at NPGA. “[NPGA is] handling the regulatory side of it.”

O’Dell says the Trump administration favors small businesses and consumer protections, but she adds the DOT rulemaking does not line up with those objectives.

Editor’s Note: NPGA released an update on this rule in March 2017, which can be viewed online. For more information or questions on this rule, contact Sarah Reboli at

About the Author:

Megan Smalley was an associate editor at LP Gas magazine.

3 Comments on "DOT cylinder requalification rule to impact propane marketers"

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  1. Jay lininger says:

    It already makes consumers mad that they have to requalify or replace cylinders that are perfectly fine. Some need it, but most grill tanks do not. It is just another expense for the consumer.

  2. Greg Pipkin says:

    Do the cylinders that are in service now have to have valve with relief changed at 10 or since stamped at 12 on cylinder still apply? Meaning if it’s never had recertification stamp for first time yet, still do 10 rule or does 12 still apply then 10 after that?

  3. Daniel Hines says:

    This is just more unnecessary regulation written by someone that does not know anything about a propane cylinder.