Renewing DOT tank exemptions

[jdh]

I know you weren't asking me, but I think it's essentially irrelevant outside the cloistered halls of the DOT. In the rest of the world, the simple fact remains that most shops aren't interested in looking for technical legal loopholes that might allow them to avoid/alter procedures that they are mostly happy with. Most shops aren't going to fill your tanks unless they are confident that; (a) the shop isn't going to incur some special liability by doing so, and; (b) that the tanks aren't going to blow up in their faces.

You're going to have a hard time getting traction with the argument that the law doesn't apply - the shops don't care if it applies, so long as it makes sense and helps ease their liability concerns. With your own compressor, you can do anything.

That wasn't what I asked.
What legal requirement is there "that each fill station MUST have a copy on site to legally fill the cylinder." The DOT says that their regulations do not cover filling personal cylinders unless they are offered for transport in interstate commerce.
I'm not having a hard time with anything.

John

 

[oxyhacker]

Actually, it says where the "package is offered for tranportation" not filled. This is just another reminder that scuba tanks are an odd fit into the DOT regs, which are aimed at commercial transport of hazardous materials, and assume each packager/shipper has fleets of identical tanks. Since privately owned scuba tanks are not subject to DOT jurisdiction if not entered into commerce the relevance of this requirement is questionable and I sure wouldn't worry about it if the shop doesn't. But if one is a stickler, its easy enough to go to the DOT website and print out a copy of the exemption, as can any dive shop that starts worrying about it.

Re: the Doudera letter someone else posted, this just confirms what I, and many others, have been saying for years. Note that it is an old letter; the distinction between intrastate and interstate commerce was eliminated some years ago. I should probably also mention that I was told at DEMA that a representative of one of the major tank inspection training agencies has been denouncing the letter as a forgery!

One of the requirements of an exempt cylinder is that each fill station MUST have a copy on site to legally fill the cylinder.

 

[SDAnderson]

That wasn't what I asked.
What legal requirement is there "that each fill station MUST have a copy on site to legally fill the cylinder." The DOT says that their regulations do not cover filling personal cylinders unless they are offered for transport in interstate commerce.
I'm not having a hard time with anything.

John

Sorry. My misunderstanding.

 

[Wayward Son]

ttt