NPGA Bobtail

Summer Fills: Is your RIN renewed?

Bottom Line: DOT requires RINs to requalify and fill cylinders; RINs expire every 5 years. Is your RIN valid?

The Pipeline and Hazardous Materials Safety Administration (PHMSA) requires companies to obtain a Requalification Identification Number (RIN) to requalify cylinders.  RINs are valid for five years. The RIN must be stamped or affixed on the cylinder after completion of the requalification process. The propane industry generally uses two methods to requalify a cylinder: a hydrostatic test (also known as volumetric expansion); or external visual inspection. Federal regulation 49 C.F.R. 180.209 details the requirements for requalification by either method.

Each facility must submit an application to PHMSA for a RIN before the facility may perform requalification of cylinders by external visual inspection. The RIN applies to the facility where requalification is performed, rather than an individual who performs the requalification at the facility or for the company at-large.

NPGA recommends submitting renewal applications 60 days before the RIN expires. According to regulation 49 C.F.R. 107.705(c), a current RIN holder whose renewal application is submitted 60 days prior to its expiration may continue to requalify by visual inspection if the RIN expires before DOT responds to the renewal application. For example:

          Ex. 1) Sarah’s Propane has a RIN that will expire in 100 days, but Sarah submits the renewal application to DOT 61 days before it expires. On the day it is set to expire, Sarah still hasn’t heard from DOT. But because she submitted the renewal application 60 days before the

expiration date, Sarah’s Propane can continue to perform visual inspection to requalify cylinders while she waits to hear back from DOT.

          Ex. 2) Sarah waits – or forgets – to submit the renewal application until sometime after the RIN expires. The regulations say that Sarah cannot conduct visual inspection to requalify cylinders because her RIN has expired. The same would be true if Sarah submits the renewal application 40 days before it will expire; or anytime less than 60 days before it expires.

Click here to complete the RIN application through PHMSA’s online portal.

Questions? Contact Sarah J. Reboli, NPGA’s Vice President of Regulatory & Industry Affairs.