VIP for Ponies?

[divestoclimb]

As with so many GOV regs, it is not entirely clear. But this extract from the DOT reg (
(ii) No cylinder required to be retested by paragraph (e)(1)(i) of this section may be
charged or filled with a hazardous material and transported in commerce....) suggests that as long as I am not filling it and transporting it in COMMERCE, it does not apply. Elsewhere in the reg, it states that once the hydro has expired, the fill cylinder can continue in service but can not be refilled. So, I'm still not sure there would be any violation involved in my private filling and use of a cylinder with an expired hydro.

Hmm, got me there, I didn't know that detail. :doh2: Would you happen to have a link to those regs? I'd like to read more about it.

The whole commerce thing may be a reference to the limits on regulatory authority that DOT has. My guess would be that "transported in commerce" means "whatever activity you do that we as the DOT have some legal authority over," so if the DOT can regulate your transportation on public roadways (can they?) then I think filling and transporting an expired hydro cylinder would violate the rules. That's all a guess though

Also, do the regs have the same "transported in commerce" clause for the 1000 lb limit?

 

[DA Aquamaster]

Many facilities that preform the DOT 5 year hydro's do nothing in regards to an annual vis as required by dive industry standards after the hydro. ALL tanks should be inspected by a trained and certf. inspector after all hydro's prior to returning them to dive service.....this is were many a tank fail the vis is after the hydro not before. All steel tanks should be cleaned after hydro and alm. should at least get a basic rinse assuming they are not being O2 cleaned then of course a proper cleaning is required for both steel/alm.. All tanks should be properly stickered after passing vis.

A VIP is a mandated part of the requalification of a tank. The hydro test is just half the process.

Scuba tanks get treated the same way as medical O2 and welding O2 tanks and many hydro test facilities after testing, drying and inspecting them will revalve them and return them directly for filling. They don't blow up, which presents a compelling argument againstthe need for rigourous tank cleaning. If you failed one of my tanks after it returned from a hydro test, we'd have words as your inspection is either way too picky or you are using a very poor hydro test facility that should have been reported to the DOT.

The valve is another matter entirely as scuba valves are not designed for O2 service and consequently pressurize very quickly and potentially have areas in the flow path that may produce heating due to compression or flow around an obstruction. In that regard cleaning is important to remove a potential fuel source since you cannot remove the O2 or the potential ignition source.

 

[divestoclimb]

This article (Definition of Commerce and Use In Commerce) would suggest that this means DOT can only apply these rules if you transport/trade across state lines, but I know anecdotally that the 1000 lb rule can get enforced on transportation within a state. Are there perhaps state laws that mirror the DOT regs for intra-state transportation?

 

[captain]

I had a conversation with a DOT representative in DC a few years ago about the personal filling and transporting of tanks for private non commercial use and was told that DOT regulations do not apply.

 

[texdiveguy]

A VIP is a mandated part of the requalification of a tank. The hydro test is just half the process.

Scuba tanks get treated the same way as medical O2 and welding O2 tanks and many hydro test facilities after testing, drying and inspecting them will revalve them and return them directly for filling. They don't blow up, which presents a compelling argument againstthe need for rigourous tank cleaning. If you failed one of my tanks after it returned from a hydro test, we'd have words as your inspection is either way too picky or you are using a very poor hydro test facility that should have been reported to the DOT.

The valve is another matter entirely as scuba valves are not designed for O2 service and consequently pressurize very quickly and potentially have areas in the flow path that may produce heating due to compression or flow around an obstruction. In that regard cleaning is important to remove a potential fuel source since you cannot remove the O2 or the potential ignition source.

In my experience I have not encounter any hydro facilities in my area that will hydro/vis- industry sticker and dry and re-valve your scuba tanks, fill them all in one sweep (I do know of a dive shop in SE Okla. that has this all in-house). As most hydro facilities require all tanks to come into the facility un-valved as they are not concerned with your scuba tank valve as part of the hydro process.

In our industry we the scuba inspectors should always preform a vis on any tank hydro'd prior to it being returned into dive service. If this is not done than there is no verification that the tank is safe for service after the hydro.

As to inspecting and passing or failing a recent hydro'd tank that is the duty of the scuba industries inspector. If I get a hydro and do an inspection, it's either going to fail or pass......the fact is many hydro'd tanks fail inspection after being returned from hydro.

As to properly cleaning a scuba tank for O2 standards it's like anything else it requires a set of protocols to be followed to ensure the cleaning is thorough, any thing else is lacking so there are reasons we fully clean tanks for O2 standards.

I for one do not entrust a visual inspection of a newly hydro'd tank to any hydro facility....it gets an industry inspection as it should....all hydro'd tanks are cleaned and those requiring O2 standards go the extra steps. No cutting corners here!



I might suggest to anyone wishing detailed training and info. on industry inspection standards and processes to enrole in a course such as PSI offers for industry scuba cylinder inspectors---well worth the time/cost,,,,also if you are involved in using O2 cleaned tanks in your diving you might look into a Gas Blender course as part of these programs involve training in O2 cleaning standards for both tanks and tank valves.

 

[captain]

In my experience I have not encounter any hydro facilities in my area that will hydro/vis- industry sticker and dry and re-valve your scuba tanks, fill them all in one sweep (I do know of a dive shop in SE Okla. that has this all in-house). As most hydro facilities require all tanks to come into the facility un-valved as they are not concerned with your scuba tank valve as part of the hydro process.

In our industry we the scuba inspectors should always preform a vis on any tank hydro'd prior to it being returned into dive service. If this is not done than there is no verification that the tank is safe for service after the hydro.

As to inspecting and passing or failing a recent hydro'd tank that is the duty of the scuba industries inspector. If I get a hydro and do an inspection, it's either going to fail or pass......the fact is many hydro'd tanks fail inspection after being returned from hydro.


As to properly cleaning a scuba tank for O2 standards it's like anything else it requires a set of protocols to be followed to ensure the cleaning is thorough, any thing else is lacking so there are reasons we fully clean tanks for O2 standards.

I for one do not entrust a visual inspection of a newly hydro'd tank to any hydro facility....it gets an industry inspection as it should....all hydro'd tanks are cleaned and those requiring O2 standards go the extra steps. No cutting corners here!



I might suggest to anyone wishing detailed training and info. on industry inspection standards and processes to enrole in a course such as PSI offers for industry scuba cylinder inspectors---well worth the time/cost,,,,also if you are involved in using O2 cleaned tanks in your diving you might look into a Gas Blender course as part of these programs involve training in O2 cleaning standards for both tanks and tank valves.

The hydro facility I deal with, not a dive shop, prefers the valves to be on the tanks so that they can be sealed after they are tested and dried. They will also fill them if requested as part of the hydro service.

 

[texdiveguy]

The hydro facility I deal with, not a dive shop, prefers the valves to be on the tanks so that they can be sealed after they are tested and dried. They will also fill them if requested as part of the hydro service.

I would say this again is rare from my experience with hydro facilities.

??- does your hydro shop provide as part of their service the final vis and scuba industry standard type evidence cylinder sticker so you can get fills at dive shops.

 

[captain]

I would say this again is rare from my experience with hydro facilities.

??- does your hydro shop provide as part of their service the final vis and scuba industry standard type evidence cylinder sticker so you can get fills at dive shops.

Not a concern, I fill my own, but VIP stickers are not a problem if I need them.

 

[rescue15]

The DOT has very long arms and many sub-divisions. It wouldn't surprise me if they had their hands in the scuba industry.

As with so many GOV regs, it is not entirely clear. But this extract from the DOT reg (
(ii) No cylinder required to be retested by paragraph (e)(1)(i) of this section may be
charged or filled with a hazardous material and transported in commerce....) suggests that as long as I am not filling it and transporting it in COMMERCE, it does not apply. Elsewhere in the reg, it states that once the hydro has expired, the fill cylinder can continue in service but can not be refilled. So, I'm still not sure there would be any violation involved in my private filling and use of a cylinder with an expired hydro.

I believe this refers to HAZ MAT only. However by DOT definitions, commerce applies to transit in vehicles. So, if you put a compressed air bottle in a vehicle, and drive it around it is involved in commerce. DOT does not require annual VIPS...if they did, all the Oxygen bottles that are transported in Ambulances would have to be tested yearly. They are only required to be hydrod as per the schedule (3 yrs for Al and 5 for steel). VIP's ate a scuba industry invention.

As far as not geting regualar VIP's, I think it is a bad practice. Do you really know how well your shop maintains it's compressor? Do you use more than one shop? Travel? You can't keep track of the quality of all the shops you may use.

I have worked on air units in the FD and have seen all the crud that comes out of breathing air quality compressor systems. Bad maintainence =bad air. not so dangerous above the surface but very dangerous below.

And those who fill their own tanks - do you maintain the compressor and use a moisture trap? If you don't there is water in your tanks that can breed bacteria. (HMM, I wonder why I have been so sick lately?)

 

[DA Aquamaster]

I had a conversation with a DOT representative in DC a few years ago about the personal filling and transporting of tanks for private non commercial use and was told that DOT regulations do not apply.

As a government bureaucrat, I can affirm that the answer lies in exactly how the question is asked. If a private non commercial citizen asks if they can fill his or her tanks for personal non commerial use, he or she will be told DOT regs do not apply.

However, if a commercial fill station asks if they can fill your very same tanks for your personal non commercial use, the answer is likely to be quite different. They will push the issue that the shop does not know your true intent and that the tank has the potential to be used in interstate commerce. In additon, in terms of hazordous materials - and that can apply to compressed gas - as a "packager" they fall under the regs by default.

The tendency in government whether it be the IRS, BATF, DOT, etc is to give opinions on very specific and limited situations and to shy away from anything that could be construed as general guidance. In other words, they are never gonna tell shops that privately owned scuba tanks do not have to be hydro tested.

The hydro facility I deal with, not a dive shop, prefers the valves to be on the tanks so that they can be sealed after they are tested and dried. They will also fill them if requested as part of the hydro service.

The hydro facilities I have worked with or at have always valved the tanks to ensure they stay clean and dry. It's a bit pointless to leave them open after an inspection. If you have one that insists on receiving the tanks de-valved that in and of itself warrants you doing your VIP when they get back as lord only knows what could have crawled in them in transit.

DOT required or not, I also do my own VIP's, tumbling and cleaning and I do maintain my own compressor although it has not gotten used much in the last year. I have never noted any more rust or other issues with my air versus the average shop air, but it is worth draining the tank yearly to take a look inside.