oxyhacker
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Since the PST scare some weeks ago we have been researching what is involved in renewing the exemption on a DOT exemption tank like PST E9791s should the manufacturer should fail to do so.
It was mentioned in the PST thread that a procedure exists by which an individual could apply for an exemption on a tank if the manufacturer for some reason didn't, but it was not clear at the time whether this would be feasible for anyone without his or her own legal dept.
From what we have found, it appears to be surprisingly easy. There are apparently two kinds of exemptions, one for manufacturing the tanks, and another for just using them, which is intended for just this purpose, to allow someone to go on using tanks if the manufacture orphans them. Getting the latter turns out to be straightforward since the renewal application can ride on the back of the original manufacturer's exemption application, so that no new engineering is necessary. Basically, I was told, all that would be necessary is for someone to write the DOT once the manfacturer failed to renew the exemption, and request that a "to use" exemption renewal be granted in the person's name.
The exemption granted would only cover tanks belonging to the person or business to whom the exemption was granted, but anyone else could become party to the exemption by simply writing the DOT and asking. Actually, I wonder how necessary this would be - I suspect that most shops (those that were even aware of the issue, that is, and I doubt many are) would go on filling these tanks for all comers once word of the renewal got out, without checking to find out whether they were parties to the renewal.
So there doesn't seem to be any reason to avoid exemption tanks, or worry about their future. If PST (or any other exemption tank manufacturer) should go under, someone will almost certainly obtain a renewal for their exemption tanks (the reason we got into this in the first place was we were wanted to be ready to renew the exemption if PST had gone under) and everyone else could become party to it.
It was mentioned in the PST thread that a procedure exists by which an individual could apply for an exemption on a tank if the manufacturer for some reason didn't, but it was not clear at the time whether this would be feasible for anyone without his or her own legal dept.
From what we have found, it appears to be surprisingly easy. There are apparently two kinds of exemptions, one for manufacturing the tanks, and another for just using them, which is intended for just this purpose, to allow someone to go on using tanks if the manufacture orphans them. Getting the latter turns out to be straightforward since the renewal application can ride on the back of the original manufacturer's exemption application, so that no new engineering is necessary. Basically, I was told, all that would be necessary is for someone to write the DOT once the manfacturer failed to renew the exemption, and request that a "to use" exemption renewal be granted in the person's name.
The exemption granted would only cover tanks belonging to the person or business to whom the exemption was granted, but anyone else could become party to the exemption by simply writing the DOT and asking. Actually, I wonder how necessary this would be - I suspect that most shops (those that were even aware of the issue, that is, and I doubt many are) would go on filling these tanks for all comers once word of the renewal got out, without checking to find out whether they were parties to the renewal.
So there doesn't seem to be any reason to avoid exemption tanks, or worry about their future. If PST (or any other exemption tank manufacturer) should go under, someone will almost certainly obtain a renewal for their exemption tanks (the reason we got into this in the first place was we were wanted to be ready to renew the exemption if PST had gone under) and everyone else could become party to it.
