Passed hydro, failed vis-galvanized

[Scared Silly]

Ok.....so.....There seems to be a little confusion. Here you will find two links. One is from a representative of PSI (which is a DOT recognized cylinder inspection training agency) which states a cylinder inspectors obligations. The other is the CFR section pertaining to condemnation of SCUBA cylinders.
Facts & Fictions
http://edocket.access.gpo.gov/cfr_2006/octqtr/pdf/49cfr180.207.pdf

You are confusing three issues - rendering a cylinder incapable of holding pressure (requires owners permission no matter who is doing the inspection), the obligation of someone doing a DOT requal test and condemning a cylinder that fails requal (DOT tester may condemn by XXX serial number), and a person doing an annual visual inspection for scuba diving and rejecting a cylinder (they may condemn only with owners permission).



Now what I did find interesting was the last fiction/fact. This statement regarding the CGA standards and scuba cylinders is the first that I can recall from my course from PSI:

FICTION: There is no authority for SCUBA cylinders to have an annual visual inspection. This is just a standard of practice in the SCUBA industry

FACT: In CGA Pub P-5 the Compressed Gas Association requires all cylinders in SCUBA service to be visually inspected annually.

 

[redacted]

You are confusing three issues - rendering a cylinder incapable of holding pressure (requires owners permission no matter who is doing the inspection), the obligation of someone doing a DOT requal test and condemning a cylinder that fails requal (DOT tester may condemn by XXX serial number), and a person doing an annual visual inspection for scuba diving and rejecting a cylinder (they may condemn only with owners permission).



Now what I did find interesting was the last fiction/fact. This statement regarding the CGA standards and scuba cylinders is the first that I can recall from my course from PSI:

FICTION: There is no authority for SCUBA cylinders to have an annual visual inspection. This is just a standard of practice in the SCUBA industry

FACT: In CGA Pub P-5 the Compressed Gas Association requires all cylinders in SCUBA service to be visually inspected annually.

Don't overlook the tittle of Pub 5; "Suggestions for the Care of High Pressure Air Cylinders for Underwater Breathing"

I added the bold. I doubt if a document tittled "SUGGESTIONS...." is establishing legal requirements.

 

[Scared Silly]

Good point, I do not have a copy of the pamphlet. I plan to visit my hydro facility this afternoon and take a look at them. I wish the damn pamphlets were not so damned expensive.

 

[captain]

I also take issue with his definition of in commerce. Commerce is the act of exchanging money for a service or product. In the case of DOT the service being paid for is transporting of hazardous materials and the container that contains it.
Small arms ammunition is considered hazardous material when transported by commercial carrier and must meet DOT packing and labeling requirements. From his definition we must also meet those requirements when driving to the hunting area with small arms ammunition in our car. I don't think so.

Also unless a GCA suggestion or procedure is adopted into the regulations by DOT it carries no legal authority.

You also have to be aware of definitions and how they are applied in the regulations, for instance DOT refers to common carriers, contract carriers and private carriers.

You will also find a regulation referring to carrying hazardous material in passenger vehicles. again this does not refer to the family car or boat. It refers to taxi cabs. busses, limos, ferries, charter boats, etc. operating for hire.

http://www.phmsa.dot.gov/hazmat/regs

http://www.phmsa.dot.gov/portal/sit...gnVCM1000009ed07898RCRD&vgnextfmt=print#page3

A common carrier is a company like UPS, they transport items for most anyone.
A contract carrier transports for some specific company or companies as say a tank truck line transporting oil for one or more oil companies.
Private carriers, and here is the one that can be misapplied. A private carrier is a company that does its own transporting with company owned vehicles and employees. This is not you and me private citizen carrying tanks in our private vehicle

 

[oxyhacker]

CGA publications have regulatory clout only if they have been "referenced into law" , which only a few of them are, and when they are, it is often only in a very limited context. See 49 CFR 171.7 for the list of referenced publications, and where they are referenced.

CGA P5 not one of them, indeed it's full title is SUGGESTIONS FOR THE CARE OF HIGH PRESSURE AIR CYLINDERS FOR UNDERWATER BREATHING. They would hardly use the word "suggestions" if it was "required"!

There are a number of other references to annual visual inspections in the CFR and referenced CGA publications, but they pretty clearly refer to a casual external inspection rather than the valve-off inspection we do to scuba tanks.

Now what I did find interesting was the last fiction/fact. This statement regarding the CGA standards and scuba cylinders is the first that I can recall from my course from PSI:

FICTION: There is no authority for SCUBA cylinders to have an annual visual inspection. This is just a standard of practice in the SCUBA industry

FACT: In CGA Pub P-5 the Compressed Gas Association requires all cylinders in SCUBA service to be visually inspected annually.

 

[Paladin]

Back in the early '80s, I was given an old 72 with a 1/2" neck. It had a white coating inside and the guy at the hydro shop tumbled it for hours until it was removed. The steel underneath was perfect. Of course, he was a little embarrassed when I told him that he had removed a factory coating!

 

[Aigtbootbp]

Allright, y'all have convinced me to tumble this tank myself. Look for a new posting here asking how.
Thanks again everyone!
Gary

 

[Texfrazer]

Small arms ammunition is considered hazardous material when transported by commercial carrier and must meet DOT packing and labeling requirements.

A common carrier is a company like UPS, they transport items for most anyone.

What's really funny is that the USPS is not subjected to the same level of the regulations as FedEx or UPS, which is why most online suppliers of small arms ammunition will only ship via USPS.

 

[captain]

What's really funny is that the USPS is not subjected to the same level of the regulations as FedEx or UPS, which is why most online suppliers of small arms ammunition will only ship via USPS.

Why is that funny, does the federal government ever regulate itself.

 

[oxyhacker]

Before we draw too many conclusions about the perfidy of the US gov from this, it might be worth mentioning that it's really the other way around. The post office will not ship loaded or primed ammunition, period. UPS will, as long as it is packaged and labeled according to DOT regs.

What's really funny is that the USPS is not subjected to the same level of the regulations as FedEx or UPS, which is why most online suppliers of small arms ammunition will only ship via USPS.