 Hi, I'm Jack Thompson. As a cylinder retester, like yourself, I have a lot of headaches running my business. I have to worry about suppliers, employees, customers, taxes, and regulations. And the last thing I need is to get hit with some kind of fine from the federal government. Fortunately, keeping in compliance with federal regulations for cylinder retesting is not all that difficult. Most of it is just good business sense. Keeping your equipment safe and your records up to date. This videotape is meant to help you comply with Department of Transportation regulations governing the retesting of compressed gas cylinders. It takes you step-by-step through a DOT compliance inspection so that you know what to expect and what's expected of you. First and foremost, there's the safety issue. Many retesters are not using correct procedures when performing hydrostatic retests on compressed gas cylinders. A small mistake could lead to injuries, property damage, even a fatality. And this is not only a hazard to the cylinder retester. End users of compressed gas cylinders are endangered also. DOT's Office of Hazardous Materials Enforcement is going to make sure that you're in compliance with 49 CFR, federal regulations pertaining to compressed gas cylinder retesting. Out is required to have your facility inspected by an independent inspection agency every five years. This doesn't mean that you won't get an unannounced inspection from DOT. Once again, these compliance inspections are meant to make sure that your company is doing the right thing, that you aren't endangering either yourself or your customers. DOT inspectors see a variety of violations, but some of the most often encountered and repeated violations are... Unaccurate tests, meaning the retester is not able to calibrate his system to within one percent accuracy. Failure to perform tests on cylinders. Some retesters actually mark cylinders as being retested without performing the tests. Expired approvals. It's important to renew your DOT approval on time. Little or no training. Retesters are performing tests without adequate training or knowledge of the proper procedures. And incomplete or non-existent records. Many retesters aren't keeping complete records on the cylinders that they test. If DOT conducts a compliance inspection, like happened to me last week, here's what you may expect. Good morning. Good morning. I'm Ryan Post and I'm with the U.S. Department of Transportation out of Washington, D.C. I'm here to conduct an unannounced compliance inspection of your hydrostatic retest facility. Like to speak with the plant manager or the president of the company if I could, please. Let me get Mr. Thompson for you. The inspector will usually arrive unannounced. The first thing he'll want to know is some general information about your company, including the names of your test operators and their years of experience. The inspector will verify that your company has a DOT retester's ID number or RIN and that your approval hasn't expired. All retesters of compressed gas cylinders are required to obtain a DOT approval and to renew the approval every five years. A copy of your RIN letter should be posted near your test equipment. Cylinder retesters should have on hand a copy of Title 49 Code of Federal Regulations or at least be familiar with Section 173.34e. This is the section that applies to the requalification of compressed gas DOT specification exemption cylinders. The inspector will also want to know which compressed gas association or CGA pamphlets are on file. Retesting facilities should have or be familiar with CGA pamphlets C1, C5, C6, C6.1, C6.2 and C6.3. At this point, the inspector will want to talk with your technicians and test their knowledge of cylinder retesting. First the inspector will ask a number of questions relating to your business and to the types of cylinders being retested. Are you a compressed gas distributor? Yes, we are. And what gases do you fill? Well, we fill oxygen, CO2, nitrogen, argon and helium. Okay. Do you serve as fire extinguishers? Yes, we do. We do halon, CO2s and dry cam. Okay. As you know, there are a variety of cylinder types in circulation. The DOT inspector is going to ask questions designed to make sure that retestors know the difference and know how to accurately test the different types of cylinders. Our DOT exemption cylinders marked as E6498, E7042, E8107, E8364 or E8422 being retested. Yes, we do have those come in sometime. Okay. How do you determine the test pressure for these cylinders? Those are just the same as a 3AL, five-thirds. The exemptions for those cylinders have expired. If they are to continue to be used, they need to be re-qualified and marked 3AL. The inspector is then going to ask another series of questions relating to exemption cylinders. Here's a quick list. Are other exemption cylinders tested? Does the operator know the re-qualification requirements for exemption cylinders tested? Are DOT E7235-4500 cylinders being retested? Does the operator know to check for neck ring retrofit? Does the company know how to obtain copies of exemptions? And what copies of exemptions are on file? Retestors should have a copy of all current exemptions on file. If you don't have them, they're available from the DOT docket's office. The inspector will also want to know if any retests are being performed on foreign cylinders for export. The retester's stamp on a cylinder implies that it meets DOT standards. Therefore, retesters are not authorized to use their retester's identification number to re-qualify any cylinder that does not meet DOT standards. The inspector will ask whether any retesting or other services are performed by outside vendors, and if so, why? This question is designed to make sure that cylinders aren't being sent out for processing that might be damaging to the cylinder. Next, the inspector will ask the retester questions related to his standard procedures for retesting cylinders. These questions are designed to inform the inspector about your methods and business practices related to cylinder retesting. Once again, the inspector will want to know what you do and that you are doing it right. If you valve and devalve cylinders and replace the same valve in the cylinder unless it's faulty, what method do you use to keep track of the cylinders and their corresponding valves? Are you verifying that the correct safety disc is in use? Do you visually inspect the inside of the cylinder before testing? Your internal inspection equipment must allow a complete visual examination of the shoulder, neck, sidewall, and bottom of all cylinders. The shoulder and neck area of aluminum cylinders should be inspected with a mirror or some other device for signs of sustained load cracking. Retesters should also visually inspect the outside of the cylinder. The inspector will want to know what method is used to differentiate between painted steel and painted aluminum cylinders and what method is being used for paint removal. Anything that prevents the retester from assessing the condition of the cylinder or prevents him from reading any prior markings or numbers such as excessive paint, labels, and corrosion should be removed. Also, any removable attachments, such as bands and boots, must be removed from cylinders to perform a complete visual examination. For those cylinders that fail the visual test and are not hydro-tested, are these results recorded on your test records? The inspector will ascertain the rejection criteria used to condemn the cylinder visually. For example, did the cylinder show evidence of corrosion, pits, dense, arc burns, or fire damage? CGA pamphlet series C6 contains information on visual rejection criteria. The most important thing that a cylinder retester can do is to ensure that his test equipment is accurately calibrated and functioning correctly. In order to ensure that the retester is in compliance, the DOT inspector will ask a number of questions related to the hydrostatic test console and other equipment. Many of these questions are straightforward, but are designed to make sure that the retester is knowledgeable. Are all cylinders tested by the water jacket volumetric method? Yeah, we use the water jacket. I'm going to get some information on your hydrostatic test console. The inspector makes note of the testing console's manufacturer's name and address. He also notes the maximum capacity and increments of the pressure gauges and asks several questions related to test gauge calibration. What method is used for certifying the test gauge calibration? We send them off to ACME Recal Shop and they use a deadweight tester. When were the gauges last recalibrated? About two months ago. Okay, with what frequency do you have the gauges calibrated? Every six months. Test gauge calibration is important to the inspector since an accurate test gauge is critical to ensuring accurate cylinder requalification. Of the several types of test equipment from manual through fully computerized that are commonly used, each type must be accurate. The inspector will go on to note whether the expansion gauges are the computerized or burette type and the maximum capacity and increments on the gauges. He'll also note whether the burettes are adjustable, whether all readings are taken at the zero level and how long the cylinders are held at test pressure. It is important to hold cylinders at test pressure for at least 30 seconds and as much longer as may be necessary to secure complete expansion of the cylinder. Remember, hold time is not over until the cylinder has stopped expanding and is stabilized. Next, the inspector will ask several questions related to test failure. If test pressure on a cylinder cannot be maintained due to failure of the test apparatus, is the cylinder retested a second time? Yeah, we repeat that test. Obviously the cylinder needs to be retested a second time and it's important to note that if the cylinder fails to maintain pressure after it exceeds 90% of the test pressure, the test pressure for the second test must be increased by either 10% or 100 psi, whichever is the lower value. For example, if a high-pressure cylinder with a test pressure of 3,000 psi fails the first test due to equipment failure, it must be retested at 3,100 psi. However, if a low-pressure cylinder with a test pressure of 480 psi fails the test due to equipment failure, it should be retested at 528 psi, which is 480 plus 10%. Next, the inspector is going to want to know what method is used for drying the cylinders once the hydrostatic test is complete. If heat is used, remember for aluminum cylinders, the maximum temperature should not exceed 350 degrees Fahrenheit. If the cylinders are steam cleaned, the inspector will want to know the maximum internal temperature of the cylinders. And finally he'll ask if the cylinders are again visually inspected inside after testing and drying. The next section of the DOT compliance inspection deals with cylinder markings. The inspector will want to look at your date and rinse stamps and he'll ask some questions about some of the other stamps and labels used in cylinder re-qualification. The first thing the inspector will want to know is whether you mark cylinders before or after they have been visually inspected and hydrostatically retested. Remember, cylinders should only be marked after they have been inspected and tested. Next, the inspector will ask to see examples of and the smallest size of your date stamps and retester's identification number stamp. He or she will also ask to see a low-stress steel date stamp for 3-HT cylinders and a low-stress steel rinse stamp if DOT 3-HT cylinders are retested. The inspector will make impressions of these stamps on his inspection form. Hey, Daryl. How are fiber-reinforced plastic, full-wrapped or hoop-wrapped exemption cylinders being marked? Well, for the full-wrapped we mark a label and then epoxy that onto the cylinder. Are cylinders being marked with a plus sign? Yes. What criteria is used to determine if a cylinder is marked with a plus sign? Well, we use Table 2 and CGA pamphlet C5 to determine the REE. A plus sign mark indicates that cylinders can be 10% overfilled. The best way to determine if cylinders should be marked with a plus sign is to use Table 2 of CGA pamphlet C5. However, if you use wall-stress calculations to determine REE, you must keep a record of your calculations. The inspector will also want to know if you are using a five-pointed star mark to indicate those cylinders that can only be used for non-corrosive gases. Since it is difficult for the retester to know exactly what a cylinder will be used for, it is up to the owner of a cylinder to provide the information necessary to determine if the cylinder can be marked with a five-pointed star. Retester should obtain written permission from the owner of a cylinder before marking it with a five-pointed star. The next part of the inspection deals with the disposition of failed cylinders. Cylinders which are rejected, either by visual inspection or by failing the hydrostatic test, should be painted, tagged or labeled with the word rejected or condemned. Failed cylinders could also be destroyed or mutilated beyond use, but this should only be done with the permission of the owner. The inspector will then ask several questions about cylinder charging. The retester should be able to describe what types of thread sealants are used and when. Know if cylinder test dates are checked prior to charging a cylinder. Whether or not cylinders are inspected for leaks after filling and whether or not a certain specification cylinder is authorized for that service. At this point the inspector will want to review the retester's knowledge of calibration procedures for the hydrostatic test equipment. Okay Daryl, what method do you use to ensure the accuracy of your hydrostatic test equipment to within one percent? We use our calibrated cylinder. Is this the only method used by your facility? Yeah. And how often do you check your test equipment for accuracy? Every day that we're going to test we run the calibrated cylinder. Okay Daryl, I'd like you to perform a calibration test on the equipment now. Okay, I'll need to put the cylinder in the test jacket. During a calibration test demonstration the inspector will note the following data. Actual pressure, charted expansion of the calibration cylinder, actual test expansions whether there were any leaks and based on the total and permanent expansion readings obtained whether the equipment was within one percent accuracy. Here's the proper calibration test procedure. After the head's latched in, I'll get the hoses put on make sure that they're secured and I'll raise the level of water to be sure that my jacket's completely filled with water. Once that's accomplished, I activate my head seal and now I can zero the level of my burette. With the burette on zero, I'll close my bleed valve and make sure that it stays on zero before I begin my calibration. Now I'll begin pressurizing and by taking the system to 3,000 psi I should be able to read the reading of 55 and a half cc's and sure enough I'm on 55 and a half cc's expansion. Next I'll go to 4,000 psi. At 4,000 psi I should have a reading of 73.8. Looking at my burette I can see that I'm at 74 cc's and so I'm within two tenths of a cc of the mark on my calibrated cylinder well within my one percent. Next I'll go to 5,000 psi. At 5,000 psi my calibrated cylinder is stamped 92 and a half cc's and I have a reading of 92 and a half cc's. So now I'll go on to 6,000 psi. At 6,000 psi my calibrated cylinder should read 111 cc's of expansion and my water level is right at 111 cc's of expansion. I'll hold here for just a moment to be sure that I don't have any pressure leaks in my system and that my expansion is going to stay stable. Everything looks stable and accurate so I'll bleed down and when I bleed down it's imperative that I return to zero. If I don't return to zero I need to begin the process all over again. And the water level in my burette came right back to zero and that's how we calibrate at the beginning of every day. The inspector will also want to take a look at your test records. He'll be looking to see whether the records contain the following information for each cylinder tested. Daily calibration of equipment, serial number, manufacturer's identification symbol, DOT ICC specification, service pressure, test pressure, visual inspection results, total expansion results, permanent expansion results, percent permanent expansion, disposition of cylinder, retester's initials, cylinder owner's name, and the certification signature of the retester's supervisor. The inspector then attaches a copy of a sample test record to his inspection form. DOT requires that records be kept until the expiration of the retest period or until the cylinders are retested. The inspector may also review your shipping papers and other aspects of your operation if you ship hazardous materials. The inspector will also review your training records. The last thing the inspector will do is conduct an exit interview and let you know how you did. Well Mr. Thompson, during the course of the inspection we found no violations and as I noted here I just asked that you read the back paragraph at the bottom here and it just says that you acknowledge that you received the form by signing it. All applicable regulations and information relating to the re-qualification of compressed gas cylinders are available in 49 CFR or incorporated references. If anything about this compliance inspection isn't clear you should be able to find further information there. Failure to follow the regulations in 49 CFR may result in civil or criminal prosecution and or fines. Further questions regarding these compliance inspections should be directed to the U.S. Department of Transportation Office of Hazardous Materials Enforcement DHM 40 407th Street Southwest Washington D.C. 20590 Call 202-366-4700