From: Beltis.K**At_Symbol_Here**TIAXLLC.COM
Subject: Re: [DCHAS-L] Hydrostatic Test Date
Date: Wed, 5 Feb 2014 19:49:10 -0500
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: OF761DADF3.A97C6328-ON85257C77.0003527D-85257C77.00047FE8**At_Symbol_Here**tiaxllc.com
In-Reply-To <9C666C16-3D61-44C5-8997-F26CAD80C11D**At_Symbol_Here**nyc.rr.com>
Demystify:
49 CFR 180.205 (c) does specifically state
that "...a cylinder filled before the requalification becomes due
may remain in service until it is emptied."
180.205 General requirements for requalification of
specification cylinders. ...
(c)
Periodic requalification of cylinders. Each cylinder bearing a DOT specification marking must
be requalified and marked as specified in the Requalification Table in
this subpart. Each cylinder bearing a DOT special permit
number must be requalified and marked in conformance with
this section and the terms of the applicable special permit. No cylinder
may be filled with a hazardous material and offered
for transportation in commerce unless that cylinder has
been successfully requalified and marked in accordance with this subpart.
A cylinder may be requalified at any time during or
before the month and year that the requalification is
due. However, a cylinder filled before the requalification becomes due
may remain in service until it is emptied. [emphasis added] A cylinder
with a
specified service life may not be refilled and offered
for transportation after its authorized service life has expired.
-Kevin
*********************************************************
Kevin J. Beltis
Director of Health, Safety and Environment
TIAX LLC
TIAX, LLC is a privately held company at the intersection of business and
technology. TIAX builds on a rich heritage based on creating business opportunities
and growth through the power of science, technology, and innovation.
From:
"Carlos Rentas
Jr." <crentas1**At_Symbol_Here**NYC.RR.COM>
To:
DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Date:
02/05/2014 05:30 PM
Subject:
Re: [DCHAS-L]
Hydrostatic Test Date
Sent by:
DCHAS-L Discussion
List <dchas-l**At_Symbol_Here**MED.CORNELL.EDU>
Ben,
In my experience, when I encountered a cylinder that upon
inspection had an expired hydrostatic date, we would remove the cylinder
from service, and return it to be retested and qualified. This is a legal
requirement as well as a best practice. (See 49 CFR 180.209 - REQUIREMENTS
FOR REQUALIFICATION OF SPECIFICATION CYLINDERS).
Carlos Rentas Jr., DPH CSP CHMM
Certified Safety, Health & Environmental Consultant
(888) 315-2498
Via iPhone 4S
I understand that compressed gas cylinders must have a current hydrostatic
test to be filled. I have read a vendor site that indicates that
a cylinder may be transported after the hydrostatic test expiration date
if it was filled prior to the expiration date. If cylinders that
have exceeded the hydrostatic test date are considered safe to transport
are they considered safe to continue using? In other words, if a
compressed gas cylinder is not empty but has exceeded the hydrostatic test
expiration date is it required by regulation or prudent practice to be
returned for testing or can it continue to be used?
Thanks,
Ben
----------------------------------------------------
Ben Owens
Assistant Director, Laboratory Safety
University of Nevada, Reno
EH&S Dept., MS 328
Reno, NV 89557
775-327-5196 (office)
775-843-2113 (cell)
The content of this page reflects the personal opinion(s) of the author(s) only, not the American Chemical Society, ILPI, Safety Emporium, or any other party. Use of any information on this page is at the reader's own risk. Unauthorized reproduction of these materials is prohibited. Send questions/comments about the archive to secretary**At_Symbol_Here**dchas.org. The maintenance and hosting of the DCHAS-L archive is provided through the generous support of Safety Emporium.
