NFPA 58 update specifies documentation of face seal inspections

The 2020 Edition of NFPA 58 now requires that fillers of Compressed Gas Association (CGA) 791 and 793 consumer cylinders inspect the face seal for damage prior to filling the cylinder. If damage is found, the container owner and user shall be notified in writing that it cannot be filled. See Sections 7.2.2.2 and 7.2.2.7 of NFPA 58.

The face seal requires a mating of male and female seals before gas flow can occur. The type of damage that the filler needs to look for is evidence of cracking, gouging, tearing, roping or a double seal. The safety concern is that an imperfect seal could result in leakage. 

This new code requirement creates new questions and new performance requirements for the industry. It forces the filler to make specific note of the condition of the face seal each time a cylinder is filled. This is a good safety practice. One might argue that this type of inspection was already being done when cylinders were being filled. But now there is added emphasis to ensure this type of inspection occurs.

Each time a cylinder is filled, a visual inspection of the cylinder is completed to confirm there are no excess gouges, scrapes, rust or cuts. These inspections aren’t usually documented on paper. If a cylinder does not pass the visual inspection, it is set aside and is usually scrapped.

The requirement of inspecting the face seal for damage prior to filling does not require that the inspection be documented. But if the face seal fails the visual inspection, Section 7.2.2.7 requires that the owner and user be notified in writing that the cylinder shall not be used.

In many cases, this notification will be a matter of internal documentation. For the vast number of cylinder refills that are company-owned, the identification of damaged face seals can be noted on a company spreadsheet, and that would seem to satisfy the code requirement. For consumers who get their cylinders refilled, a notation on a fill ticket would also seem to satisfy the code requirements.

But as a lawyer, I note the very specific code requirement that a failed face seal requires written notification to the container owner and user. This type of documentation needs to be accessible in the event a leaking cylinder results in a fire or explosion. Your company should develop a protocol or practice regarding how it will document that a face seal has failed.

Should you document a face seal that has none of the safety issues specified in the code? How will you document that the face seal did not fail and that it did not have any visible evidence of cracking, gouging, tearing or a double seal? And how will you train employees who refill these cylinders?

I understand the Propane Education & Research Council is developing training on this new code requirement. Be sure your employees are aware of the code requirement, and document that they are trained on what to look for during visual inspections. You will also want to train your employees on proper documentation of any face seal that does not pass a visual inspection, including sending written notification that the cylinder shall not be filled to the owner and user.

As with all safety rules, this new requirement serves a valuable purpose – removing potentially dangerous cylinders from use to avoid a gas leak that could result in a fire or explosion. Implementing this new requirement in a way that satisfies the requirements of code will require some thought. Take a practical look at what you need to do as a marketer to satisfy the training and documentation requirements of this new code section.

John V. McCoy is with McCoy, Leavitt, Laskey LLC. His firm represents industry members nationally.