How to identify a Luxfer 6351 tank?

[oxyhacker]

A tank not made under DOT approval can never be retroactively be made legal in the eyes of the DOT (ditto TC). However it is completely legal to transport privately owned tanks which are either non-DOT or out of hydro or overfilled in a private vehicle. Not because it is necessarily a good idea, but just because the DOT has not jurisdiction over them.

See 49 CFR 171.1 "(d) Functions not subject to the requirements of the HMR. The following are examples of activities to which the HMR do not apply:
(6) Transportation of a hazardous material by an individual for non-commercial purposes in a private motor vehicle, including a leased or rented motor vehicle."

It is also legal for a dive shop to fill an out of hydro or non-DOT tank if it is privately owned and not being used in commerce (which means, being used to transport hazmats for sale, simply filling a tank does not enter it into commerce). Not that most of them will do it, but if they did it would be a matter between them and their insurance company rather than the DOT. Actually, if PST fails renew the SP9791 next time it comes due we may see a lot of pressure on shops to do so.

I was also told by the DOT that the procedure spelled out in the CFR for hydrotesting non-DOT cylinders from a foreign boat or aircraft, that is to say stamping it with the retest date but not the requalifier's RIN stamp, would be a legal and appropriate thing to do if one had a privately owned non-DOT tank one insisted on using - say, if one was a collector of Soviet diving gear - and still wanted to maintain it safely.

The only legal way to use non-DOT tanks in the US I know of is to have your own compressor, dive off the boat moored at your back porch, and never drive with them on the roads with more than 40psig in them.

IF you can get a hard copy of the retest specs from the country where the tanks are made you may be able to get the hydroed in the US, but as it may put the retester at legal risk with our govt most won't play.

 

[Leadking]

A tank not made under DOT approval can never be retroactively be made legal in the eyes of the DOT (ditto TC). However it is completely legal to transport privately owned tanks which are either non-DOT or out of hydro or overfilled in a private vehicle. Not because it is necessarily a good idea, but just because the DOT has not jurisdiction over them.

See 49 CFR 171.1 "(d) Functions not subject to the requirements of the HMR. The following are examples of activities to which the HMR do not apply:
(6) Transportation of a hazardous material by an individual for non-commercial purposes in a private motor vehicle, including a leased or rented motor vehicle."

It is also legal for a dive shop to fill an out of hydro or non-DOT tank if it is privately owned and not being used in commerce (which means, being used to transport hazmats for sale, simply filling a tank does not enter it into commerce). Not that most of them will do it, but if they did it would be a matter between them and their insurance company rather than the DOT. Actually, if PST fails renew the SP9791 next time it comes due we may see a lot of pressure on shops to do so.

I was also told by the DOT that the procedure spelled out in the CFR for hydrotesting non-DOT cylinders from a foreign boat or aircraft, that is to say stamping it with the retest date but not the requalifier's RIN stamp, would be a legal and appropriate thing to do if one had a privately owned non-DOT tank one insisted on using - say, if one was a collector of Soviet diving gear - and still wanted to maintain it safely.

Vance,

While your discussion takes place around DOT rules, you are omitting OSHA. An employee, (and that includes owners of a corporation) cannot legally fill a high pressure cylinder that is not DOT or ASME approved. DOT does allow testing of non-DOT cylinders BUT the tanks must be IMMEDIATELY exported and the retestor must be registered by the country to which they are being exported to. I do not have a dis-agreement about a retest date sans RIN number but that hold no validity in any issue discussed here.

 

[WD8CDH]

A tank not made under DOT approval can never be retroactively be made legal in the eyes of the DOT (ditto TC). <snip>

True, but a group of tanks from the same batch can (with enough money). They would have to meet ALL of the requirements of a particular DOT standard and the batch would be tested just like they were just manufactured, including destructive testing of some of them. Not easy but it has been done.

 

[cbrich]

The 6351 cylinders are not "crappy".... They just require an annual eddy current test in addition to the visual inspection.

A 6351 cylinder that passes annual inspection is just as "good" as a 6061 cylinder that passes inspection.



There's no reason not to fill a pre-1990 cylinder that has a valid eddy current , visual inspection sticker and hydro. Any fill operator who says differently is ignorant of the facts.

I agree, my LDS will fill a 6351 but it has to have an annual inspection sticker and annual eddy current. When they do an annual inspection they do the eddy current test on all aluminum cylinder whether they are 6351 or 6061. I have 3 6351 tanks and was not thinking when I bought them because they were super cheap. When I talked to by LDS they said no problem, it's the same procedure as a new aluminum cylinder. Again my LDS does an eddy current on all aluminum cylinders, does not matter the manufacturer date on the cylinder.