By the time you get done with hydro tests & shipping, it might be a better value for you to buy cylinders when you arrive, then sell them when you leave. Your time frame in country would seem to justify that option.
German tanks in US….DOT cert
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Bob DBF
Contributor
DOT jurisdiction is commercial transportation and not what you do with your personal tank. You will need a hydro to fill at a business, not on your own compressor.
Can you point me to a source for the written law on that? I read it about 20 or 30 years ago, but haven't known where to find it since.
I agree with you that if you fill your own tanks, you will likely not have any realistic risk of getting fined, but I am not sure if you are technically legal in doing so. I would love to get a fresh read on the actual law.
DOT Hydrostatic Testing - Pressure Testing & Tank Hydro Testing in Los Angeles - Tyms
Tym’s Inc. is the premier solution for the utilization of compressed gasses in Los Angeles for a variety of industries. Tym’s is DOT approved to hydrostatically test most kinds of cylinder assemblies.
www.tymsinc.com
I'm still digging around looking for that DOT reg that I haven' read in 20 years. So far I have found that civil violations can range from $25k to 100k & criminal violations can get you 5 years in the slammer, but I haven't found the part about who the rules actually apply to yet.
49cfr 180 & 49cfr190 are where I have been looking so far.
Hydrostatic Testing FAQs - Aerospace Turbine Rotables
Hydrostatic Testing for Aviation Oxygen and Fire Bottles FAQ’s: What is Cylinder Requalification? The process of inspecting and testing pressure cylinders Pressure cylinders must be inspected and tested at specific intervals to ensure that no conditions exist that preclude the cylinder from...
www.turbinerotables.com
The closest I could find to an answer to my question was in CFR 180.205c
"...No cylinder may be filled with a hazardous material and offered for transportation in commerce unless that cylinder has been successfully requalified and marked in accordance with this subpart. A cylinder may be requalified at any time during or before the month and year that the requalification is due. However, a cylinder filled before the requalification becomes due may remain in service until it is emptied. A cylinder with a specified service life may not be refilled and offered for transportation after its authorized service life has expired."
This would seem to support
Bob's description when read in it's entirety.
The first line referrers to transportation in commerce. It is therefore logical to conclude that the later "offered for transport", also is assumed to be transportation in commerce. It is possible that 20 years ago, I only read the second half & missed the "in commerce" part.
Yeah, the great dive shop/dive industry conspiracy to get rich quick with VCI's. ALL of those industry and subject matter experts who said that VCI's are necessary and must be done at least once per year (more for commercial organizations) don't know what you seem to know of course.
And, of course, we are to trust and believe some annoymous internet experts with fake names and fake credentials and do away with the well known industry experts and equipment manufactures.
broncobowsher
Contributor
I went and looked up the "in commerce" since I wasn't exactly sure how it plays into this. I got
Commerce is the exchange of goods and services, especially on a large scale. The English-language word commerce has been derived from the Latin word commercium
So a simplified version would be
...No cylinder may be filled with a hazardous material and offered for transportation in the exchange of goods and services unless that cylinder has been successfully requalified...
Personal use won't fall into this. No exchange of good and services. Unless you start doing work, making money, etc.
A dive shop filling a cylinder, could be off the hook depending on the offered for transportation. The banks in the back room, they are not transported (OSHA is a different story). But as far as DOT goes, no transportation, they are not over it. The remember the T in DOT. It could be argued that as long as the shop doesn't transport the cylinder (offered for transportation). Once it leaves the shop, no longer in commerce (unless it is a rental). It is back in the personal use. Transportation? how does the shop know if it will be transported? Maybe they just want to top off the tires in all the cars in the parking lot?
But the shop hauling the cylinders to the local pool, lake, etc. That would be transporting cylinders filled with hazardous material (compressed air falls into that category) and they would be involved in the exchange of good and services being they are getting paid for the class they are teaching.
So what if I went to my local hydraulics shop. Ordered up a hydraulic cylinder custom built. But leave out the piston and rod, just have 2 end caps installed instead? I just built my own cylinder. Not that different than an accumulater. If there was a piston in the middle, charge one side with Nitrogen, the other side gets oil. Nothing unusual here.
Commerce is the exchange of goods and services, especially on a large scale. The English-language word commerce has been derived from the Latin word commercium
So a simplified version would be
...No cylinder may be filled with a hazardous material and offered for transportation in the exchange of goods and services unless that cylinder has been successfully requalified...
Personal use won't fall into this. No exchange of good and services. Unless you start doing work, making money, etc.
A dive shop filling a cylinder, could be off the hook depending on the offered for transportation. The banks in the back room, they are not transported (OSHA is a different story). But as far as DOT goes, no transportation, they are not over it. The remember the T in DOT. It could be argued that as long as the shop doesn't transport the cylinder (offered for transportation). Once it leaves the shop, no longer in commerce (unless it is a rental). It is back in the personal use. Transportation? how does the shop know if it will be transported? Maybe they just want to top off the tires in all the cars in the parking lot?
But the shop hauling the cylinders to the local pool, lake, etc. That would be transporting cylinders filled with hazardous material (compressed air falls into that category) and they would be involved in the exchange of good and services being they are getting paid for the class they are teaching.
So what if I went to my local hydraulics shop. Ordered up a hydraulic cylinder custom built. But leave out the piston and rod, just have 2 end caps installed instead? I just built my own cylinder. Not that different than an accumulater. If there was a piston in the middle, charge one side with Nitrogen, the other side gets oil. Nothing unusual here.
You seem to interpret my comments about the details of the laws that are in place, to indicate that I am against inspecting tanks. Perhaps I should clarify my position a little better.
My oxygen cylinders don't need annual visual inspections. Neither do my nitrogen cylinders, my helium cylinder, my C25 cylinders, nor my CO2 cylinders. Only the SCUBA industry seems to have this standard in place. It is out of step with other industries.
If one were to argue that in this case it is life support equipment, therefore a stricter standard is appropriate, I would comment that medical gas cylinders, aviation gas cylinders and large industrial breathing air cylinders that are commonly used on hazmat sites, do not normally get annual visual inspections, as far as I know. Please correct me if I am misinformed about any of this.
I am actually in favor of regularly inspecting SCUBA cylinders visually if they are heavily used, have been filled from a questionable source, show signs of corrosion or show signs of physical mistreatment. I am not in favor of the visual inspection being required each year in order to get a scuba shop to fill the tank with air.
I am in favor of having a hydro test done at the prescribed intervals, even if I plan to only fill the tank myself. I have one tank sitting empty now that I could fill myself, but I plan to get it hydro'd before doing so, because I believe it is the prudent thing to do.
But those are just my observations & opinions. Your mileage may vary.
I actually have a pretty healthy respect for the dangers of high pressure gasses. I'm not looking to cut corners. I'm just pointing out details of current regulations & inconsistencies in the current systems that exist.
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