E-Series DOT Exemption

[Lemonade]

I just read that the PST E-Series are manufactured under an exemption from DOT (E9791), rather than to meet a certain DOT standard, and the exemption has to be renewed by PST every couple years. So, if, for an instance, PST goes out of business (I realize that is not very likely) and does not apply to renew the exemption, the tanks cannot be re-hydro’ed.

Is that right?

 

[rmediver2002]

Yes that is about it...

Someone must reapply for the exemption, normally just a paperwork drill to keep it running.

Jeff Lane

 

[oxyhacker]

This is not just a theoretical concern - it does happen. I have an orphan '73 alu 80 SP6688 that was sold here, the story goes, by some foreign company (BW? SRP? those are the other markings) that then got out of the US market. The tank is like new, but cannot be hydroed because the exemption expired.

I've seen a few others gathering dust in shops. This is one of those issues a lot of dive shops don't understand. More than one shop owner has pointed one of these tanks out to me and said "See that tank? They were so dangerous that the DOT had to ban them".

No law against filling them though - I use mine as a portable argon tank.

 

[Sandy Eggo Jake]

So, if, for an instance, PST goes out of business (I realize that is not very likely) ...

:boom:

I've been shopping for a PST HP120 tank as all my dive buddies rave about theirs. Still, in doing my homework came across this....


"Pressed Steel Tank Co., in West Allis, plans to be among the area manufacturers to eliminate jobs. The company intends to eliminate about 50 of its 120 workers in the next couple of months."

http://www.jsonline.com/bym/career/aug03/163640.asp

Hmmm. Orphan tanks? No thank you. Perhaps I'll avoid the new DOT exemption tanks!

 

[Genesis]

and want steel, IMHO PST is the only sane choice.

The reason is that they are the only hot-dipped galvanized tank on the market.

Cold-dip and painted steel is a disaster in salt water. Hot dip is the only way to go - and there is only one company to get it from.

You could dive AL tanks, of course.....

 

[LUBOLD8431]

Sandy Eggo Jake once bubbled...

Hmmm. Orphan tanks? No thank you. Perhaps I'll avoid the new DOT exemption tanks!

New exemption? Not really... The e-9791 exemption has been around for over 10 years....

It was just recently (last year) changed a little...

 

[Sandy Eggo Jake]

Good point. Were all the PST HP120 tanks manufactured under E9791? Hot dipped or otherwise?

 

[LUBOLD8431]

Yes, they were and still are e-9791. Even back to when Sherwood was distriuting PST cylinders...

Actually, when I think about it, I think the E-9791 rating has been around for at least 15 years, and maybe longer...

 

[bgi]

The pressed steel E-9791 issue is raising it's head again. Before I type in the thread of research I just completed, I'd like to pose a couple questions:


Oxyhacker, are you certain about the statement you made: "No law against filling them" ? I doubt this is true if the hydro expires.

Who can apply for an extension of the DOT E-09791 and what does it cost to do so?


Lemonade, PST may, in fact, go out of business soon.


Here's what I found:

Google ["pressed steel" scuba tank "dot exemption"] and find this newsletter which describes Pressed Steel's DOT exemption 9791:

http://www.danenet.org/4lkscuba/newsletters/Newsletter1005.pdf

Searching for DOT Exemption scuba tank, I find this list of links:


http://www.psicylinders.com/links.htm>

Which leads me here:

http://hazmat.dot.gov/exemptions_index.htm

This link has expired, but it points me here:

http://hazmat.dot.gov/sp_app/special_permits/spec_perm_index.htm

Remembering that Pressed Steel's exemption is 9791, I click on "Exemptions E-09000 - E-09999" that sends me here:

http://hazmat.dot.gov/sp_app/special_permits/exe_9000.htm#e09000

then click on "E09791" to get to the exemption here:

http://hazmat.dot.gov/sp_app/special_permits/docs/09000/E09791.pdf

This exemption expires August 31, 2007. The exemption allows these tanks to be legally hydro tested through that date. The net result is: If the exemption is not renewed, the tanks cannot be legally hydro tested after August 31, 2007, so they will be orphaned when their current hydro expires. Existing tanks may be filled until the hydro expires. So to maximize the life of my tanks, I can consider getting a hydo test done prior to the exemption expiration (next year).


This is a list of cylinder markings:

http://hazmat.dot.gov/sp_app/special_permits/spec_perm_index.htm

This describes the cylinder markings for wisconsin manufacturers and identifies the pressed steel HP cylinders as "M5625" The cylinders are marked "DOT-E 9701" (the exemption) and "TP 5250" (test pressure)

http://hazmat.dot.gov/sp_app/approvals/symbol/m_wi.pdf

This exemption is an interesting read! Parts of pages 5-6 describing the testing are amazing.
An interesting note: The specified minimum wall thickness is only 0.179 inch!

Hydro specs:

http://a257.g.akamaitech.net/7/257/2422/12feb20041500/edocket.access.gpo.gov/cfr_2004/octqtr/pdf/49cfr180.209.pdf

The whole "DOT Exemption" thing is regarding the approval to manufacture, mark, sell, and use a cylinder, that doesn't conform to a standard DOT specification, to transport compressed gasses. The exemption means that the cylinders are exempt from 49 CFR 173.301(a)(1), 173.301(a)(2) and 173.302a(a)(1)
49 CFR 173.301(a)(1) is found here (shows the DOT approved markings, including the common DOT-3AA and DOT-3AL):

http://a257.g.akamaitech.net/7/257/2422/12feb20041500/edocket.access.gpo.gov/cfr_2004/octqtr/pdf/49cfr173.301.pdf

 

[royalediver]

BGI

you need to check with the DOT, but my understanding is that to fill a cylinder commercially, you need a copy of the exemption in your files (E-9791). If the exemption has expired YOU CANNOT fill it.

It may be worth it before you send everyone in the wrong direction.

I may be wrong, but I doubt it.