Are you aware of any instances where the cylinders did not perform to their nominal specifications?Federal Register :: Request Access
www.ecfr.gov
Look at where it mention INCIDENT in multiple places in the one paragraph of which this is only one of many in the document.
Just a snipet below:
The application must include a statement describing all relevant operational, shipping, and incident experience of which the applicant is aware in connection with the special permit since its issuance or most recent renewal. If the applicant is aware of no incidents, the applicant must so certify. When known to the applicant, the statement must indicate the approximate number of shipments made or packages shipped, as applicable, and the number of shipments or packages involved in any loss of contents, including loss by venting other than as authorized in subchapter C.
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So I would think this is for a legal beagle?
I don't think they mean "dropped on toe" or "got lost in shippment". Deformed, Leaked, or ruptured would probably be relevant.
For me, it would not seem to be particularly (legally) risky to affirm "no incidents known to me" if one doesn't know of any.
I think the bigger risk is that the bureaucracy is likely to sit on individuals' renewals requests because of 1) avoidance of volume, 2) avoidance of precedent.