Once tank owners apply to be party to the new "use" SP (which can be done by mail, fax or email) they will be sent an authorization letter. This letter, and a copy of the SP, should be kept with the tank when it is being filled or transported in commerce, or hydrotested. There is no charge for either the initial use SP or being made party to it.
The DOT people I have talked to foresee no problem in granting the use permit for the 9791s if PST doesnt' renew their SP, as they say they have already established a good enough track record that the determination has been made that they are safe for use, so the SP is in effect already preauthorized. This also means the reporting of problems with the tanks mentioned in the application will not be necessary.
The only catch in all this is the possible delay in getting things done, if PST has just vanished. Unless they inform the DOT that they will not be renewing the SP, the DOT cannot consider issuing a use permit until 60 days before the old manufacturer's SP expires, and issuing the new one can take between 2 and 8 weeks depending on how busy they are. So there might be a gap between the old manufacturer's SP expiring and the new one coming into effect, however, I doubt this would be a serious problem as most dive shops won't even be aware it has happened - remember, in the case of the recent Norris and Asahi expirations it was months and months before anyone noticed.
There are a couple other things worth noting:
- It is not necessary to register each tank separately, and once a business or individual becomes party to the SP they can fill or transport any 9791 tank, not just ones belonging to them.
- Since privately owned tanks are not subject to DOT regulations, a diver can disregard much of the above, that is to say, there is no reason why you should have to keep the paperwork with you every time you go diving, or to the shop when you get the tanks filled unless, of course, the shop insists on it. My suspicion is that most shops will just go on filling the tanks, as they are legally entitled to do, regardless of the exemption status. One will need the paperwork to get the tanks hydrotested, though.
Also, I'm curious, is the end result here some sort of certificate that the govt mails out to me, that I have to bring/show to any entity/shop/boat that fills my tanks to 'prove' my tanks are 'special'/'legal' ? ...and if the answer is 'yes', I forsee any infinite supply of baffled/*** ? looks I'm gonna be getting from the average shop monkey filling my tanks......I guess my hope is that I'll only REALLY need this paperwork once every 5 years to show the hydro facility, and that as long as my tanks have ongoing/valid hydros 99.9 % of shops/boats either won't have a clue or couldn't care less about this 'exemption crap' !