The Pipeline and Hazardous Materials Safety Administration (PHMSA) of the Department of Transportation (DOT) published a Notice of Proposed Rulemaking to return to a 12-year period after applying the hydrostatic (also known as volumetric expansion) testing method for cylinder requalification.The proposal is in response to a petition from NPGA to return to the 12-year requalification period following a hydrostatic test. NPGA put forward a petition after PHMSA changed 49 C.F.R. 180.209(e) to reduce the initial requalification period from 12 years to 10 years for DOT cylinders following a hydrostatic test. Nowhere in that rulemaking process did PHMSA address the changes in any form or provide any rationale or substantiation for the changes.
The 10-year requalification period following hydrostatic testing took effect in January 2017, but after aggressive pursuit by NPGA, PHMSA released an Enforcement Notice in March 2017 that states the agency will not take enforcement action against the requalification of DOT-specification cylinders by hydrostatic testing according to a 12-year period. Instead, the Enforcement Notice permits either a 12- or 10-year requalification period. The Enforcement Notice remains in effect until the proposal by PHMSA is finalized. The proposal is not yet finalized. A copy of the Enforcement Notice is available on the NPGA Member Dashboard.
In the prior rulemaking, PHMSA also changed the requalification period following the proof pressure testing method from 7 years to 10 years. In the latest proposal, PHMSA suggests allowing the proof pressure requalification period to remain at 10 years. PHMSA also proposes several changes to tables in the regulations in order to reflect more clearly the requirements in the regulatory language. NPGA is responding to the PHMSA proposal with strong support to correct the requalification period to 12 years following the hydrostatic testing method.
Please direct any questions or comments to NPGA’s Sarah Reboli, Deputy Counsel, Regulatory Affairs.