10% overfill / Plus + rating on Steel LP tanks

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Steven:

You make a good point. Spec tanks are not inviolate. If a tank is dangerous, DOT is gonna pull the tank off the market--spec or exempt, it won't matter.

But that is a risk all tanks have. My point was that exempt tanks have an additional risk that I didn't know about. How much of a risk is presented from losing the exemption is difficult for me to assess, and I have just begun to look into it. I was anticipating some insightful comments, like yours, which is why I enjoy this board so much.

Here was my first thought after learning about the renewal process for exempt tanks: I figure that I can dive 20 to 25 year more years. What are the odds that a third world country, say China, gets into the cylinder production game? If its cheap labor out competes other tank manufacturers, could the price pressure put PST out of business within the next ten or twenty years? If PST derives only 10% of their gross revenues from SCUBA tank sales, and the rest is from acetylene tanks, liquid petroleum tanks, etc., a low price producer could put PST into chapter 7 (preceded by chapter 11) without ever making a single SCUBA tank. In that case, the avenue of third-party renewal becomes important.

PST is an easy case because they have a lot of tanks out there. In my worst case scenario above, there will probably be a third-party exemption renewal. A less widely sold HP tank is more problematic, which is why this whole issue may auger in favor of PST to the detriment of smaller HP SCUBA tank manufacturers.

In my conversation with DOT today, I learned that many tank exemptions have a renewal period that is specific to the exemption, i.e., you have to review the exemption, not DOT regulations, to see when it comes up for renewal. It is common for the renewal period to be much longer than two years.
 
Uncle Pug:

We dived by the hotel at Mukilteo three weeks ago. Not impressed, other than glad to get my wife to dive elsewhere. Also dived Richmand (sp?) Beach, and again not impressed, other than wife huffed her gear all the way back to the parking lot. After her four knee surgeries, this was some kind of a paradigm shift.

BTW, she doesn't go below 60' yet.

I gave a copy of the webite about "+" fills to a guy at UWS in Everett. Told him to give it to the manager and that I will call in the future. This is the same young man who all but insulted me when I asked if they could do a "+" hydro next year when my tanks need it. I guess I've upped the ante now that my new position is that I don't need "+" hydro.
 
John Hoffer once bubbled...
We dived by the hotel at Mukilteo three weeks ago. Not impressed
Not much to impress there... except the easy access... a few steps from the back of the P/U to the waters edge today as the tide was up to the steps.

Not bad having shore access to such deep water either.

And the little red octopuses that Shane always seems to find (and I miss until he points them out.)

And the juvenile wolf eel that has taken up residence.

And the troll... but ya gotta go deeper for the troll.

But the best part is being able to stop by for a quick but relaxing afternoon dive and then bowl of clam chowder at Ivar's. :D
 
pescador775 once bubbled...
I repeat, the subject post is entirely false. No tester can legally 'plus' rate a tank which does not meet the REE criterion for that tank. To fill the tank above the rated pressure is at the discretion (and liability) of the operator. If the tank is transported interstate by 'common carrier', it is a violation of federal law. To suggest that the E9791 spec will be voided is nonsense.

Edit: Pug, the only person that you are fooling is yourself.

So what you're saying is that I should avoid shipping my jacked LP104's to the dive site on a freight truck or bus. After all, those are examples of common carriers.

I guess I'll continue to transport my gear the old fashioned way. In the back of my pickup.

It would be worthwhile if you could provide a citation to support your claims.
 
pescador775 once bubbled...
I would urge the regulator to remove your subject post as containing bogus information, and speculation which borders on nonsense.

Whether its correct or not, the poster has every right to scribe whatever he likes, and its up to us to believe what we want.

Freedom of something-or-other act I think.:D
 
Maniac, If I were to knowingly post false info, the post would be quickly erased with an admonishment (TOS). Refuting 'research' of this type is not my idea of fun.

Northeastwrecks: the statement I made about interstate commerce has been on the books for decades and every diver, other than a rank newbie, should be aware.

Yeah, the guys at DOT may know about European rating of some types of tanks and privately poo, poo the 'plus' requirement. My 3180+ psi Faber tank is rated @ 3600 psi in Europe. However, these same tanks are marked with specific technical data which the DOT requires to be met before a tank can be plus rated. What is Hoffer's contact saying, 'it's all a joke, folks, go ahead and overfill'? 'If the tank's been in a fire and as a result can't meet the more stringent requirement, don't worry about it'?
 
John Hoffer once bubbled...

Mr. Eichenlaub also confirmed what you said earlier, that filling at your LSD and then driving to a dive location is not putting the tank into interstate transport, and therefore the DOT has no regulations on fill limits, albeit state negligence laws apply.

Without having flashbacks to my first year Civil Procedure and Con Law studies, the federal government does not have the authority to regulate interstate "trasnportation," whereas they do have the constitutional authority to regulate interestate "commerce." As "transportation" relates to "interstate commerce," the government can regulate. Absent the element of "commerce," it's out of bounds...

Note that this is not a "legal opinion," just some thoughts...

Adam
 
pescador775 once bubbled...

Northeastwrecks: the statement I made about interstate commerce has been on the books for decades and every diver, other than a rank newbie, should be aware.


Your misquoting yourself so as to avoid the consequences of your error.

You said that the tanks were to be transported by "common carrier." My private vehicle is not a common carrier. Therefore, your comment is wholly irrelevant.

Of course, that assumes that your comment is even remotely correct. I've yet to see the citation supporting your position.

As for "rank newbie", if your going to resort to insults, take it to PM's. But before you do, why should everyone but a "rank newbie" be aware of an unsupported statement that contains basic errors in terminology?

In view of your basic errors, I implore the regulators to remove your statements from the Board.:D
 
John, thanks for taking the time to do some research. Pescador7 would gain some credibility with that approach.

As NE suggests not everything that crosses a state law is 'interstate commerce' for DOT purposes.
 

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