HM-220D

On August 8, 2002, the Department of Transportation's (DOT) Research and Special Programs Administration (RSPA) issued a Final Notice on HM-220D. This notice details requirements for the maintenance, requalification, repair, transportation and use of DOT Specification Cylinders so it may affect anyone who operates in any of these capacities. The effective date in general for these new regulations was October 1, 2002. However, an extension to the compliance date has been granted for certain provisions of HM-220D via a communication issued on September 30, 2002 by RSPA. (See Federal Register, September 30, 2002, Vol. 67, Number 189, pages 61287-61289.)

Numerous regulations have changed as a result of HM-220D. This article concentrates on the major provisions described below.

Transport after Service Life
The first major change, effective September 30, 2002, prohibits a filled cylinder with a specified service life from being offered for transportation in commerce after its service life has expired. However, a cylinder in transportation or a cylinder filled prior to the expiration of its authorized service life may be transported for reprocessing or disposal of the cylinder's contents. After the cylinder's contents have been purged, it must be condemned in accordance with the condemnation procedures identified in Section 180.205.

Aluminum Alloy Cylinders
The second change specifies that after September 30, 2002, DOT 3AL cylinders made of aluminum alloy 6351-T6 may not be filled and offered for transportation or transported with a Division 2.3 or 6.1 Hazard Zone A material. An exception however, does permit the transportation of these cylinders for reprocessing or disposal of the cylinder's contents until April 1, 2003 if the cylinder was filled prior to October 1, 2002 and is otherwise serviceable and conforms to the regulation in effect on September 30, 2002.

RSPA has issued an Advisory which describes all affected cylinders by exemption number and/or manufacturer and/or date of manufacture. This Advisory can now be located on the RSPA website at www. rspa.dot.gov.

In addition to the DOT 3AL specification cylinders described above, this prohibition applies to the following exemption cylinders DOT-E 6498, 7042, 8107, 8364, 7235, 8023 and 8115. RSPA has indicated that a table will be made available which will identify all affected cylinders by date of manufacture, serial number, manufacturer, etc.

CGA Pamphlets and ASTM Standards
The third major change was the incorporation by reference of the latest editions of previously approved Compressed Gas Association (CGA) Pamphlets and American Society for Testing and Materials (ASTM) Standards. An interesting note here is that RSPA chose not to incorporate CGA pamphlet C-1 “Methods for Hydrostatic Testing of Compressed Gas Cylinders,”1996 edition, because the CGA is currently in the process of completely revising this standard.

In an attempt to enhance the accountability of the cylinder requalification process, this change expands the approval provision for persons performing periodic cylinder requalifications to include those who perform visual inspections, pressure tests, repairs and rebuilding of cylinders. A transition period of one year has been instituted to allow affected individuals sufficient time to comply.

Due to the expansion of this rule to include repairers and rebuilders, the terms “retester” and “retester identification number” (RIN) have been revised to “requalifier” and “requalifier identification number” respectively.

Requalification Markings
The fifth major change will allow the application of requalification markings on cylinders by using alternative methods that produce “durable” and “legible” marks without first obtaining the written approval for these methods from the Associate Administrator as identified in the original Notice of Proposed Rulemaking (NPRM).

Pressure Relief Devices
The final major change is the requirement that pressure relief devices (PRDs) on all DOT-3 series specification cylinders must be set at test pressure with a tolerance of -10% to +0% beginning at the first requalification due on or after the effective date. This effective date was originally October 1, 2002 but it has been extended to May 30, 2003 via a communication issued by RSPA on September 30, 2002. (see Federal Register, pages 61287-61289)

Omitted from Final Regs
As major as some of these changes are, some might consider what was omitted from the final regulations to be even more significant than what was included. The original NPRM issued on October 30, 1998 included some sweeping provisions for the industry:

Metric-Marked Cylinder Specifications — The first of these provisions pertained to new metric-marked cylinder specifications 3M, 3ALM, 3FM and 4M. In an attempt to align U.S. standards with international standards, RSPA drafted the original proposal based on draft ISO standards. Subsequently, RSPA decided to wait until the ISO standards have been adopted into the UN Model Regulations before they incorporate any changes into the HMR. This determination was communicated via a notice in the Federal Register on February 13, 2002. RSPA has indicated, however, that it will initiate rulemaking action pertaining to this issue in the “near future.”

Ultrasonic Examination — Another controversial change in the original NPRM, which was not enacted, pertains to the requirement that all of the new metric specification cylinders be requalified by ultrasonic examination. This rulemaking was withdrawn along with the metric specification in the February 13, 2002 communication in the Federal Register. RSPA has indicated that it will address issues related to ultrasonic testing in a “subsequent rulemaking.”

Independent Inspection Agency — Additionally, a proposal in the 1998 NPRM would have required that all cylinders manufactured or rebuilt to the new metric specifications be approved by an Independent Inspection Agency (IIA), as opposed to an employee of the manufacturing company. The purpose of this requirement was to subject low-pressure cylinder manufacturers to the same requirements as high-pressure cylinder manufacturers. This change was omitted in conjunction with the metric-marked cylinder specifications.

Puncture-Resistance Requirements — A final provision which was deleted from the original NPRM specified that certain puncture-resistance requirements for cylinders be met for Hazard Zone A and B materials. Even though this provision was excluded, the final regulations did include a new performance requirement that metal attachments for cylinders be constructed in a way that would prevent the likelihood of puncturing the cylinder.

Miscellaneous Provisions
Below is an assemblage of provision in the new regulations that are of lesser significance, yet are noteworthy:

Cylinders which contain Class 2 materials may only be loaded in a horizontal position when the cylinder has been designed so that the inlet port to the relief channel of the Pressure Relief Device (PRD) is located in the vapor space of the cylinder. The effective date of this provision has been delayed until May 30, 2003.

The requirements for repair and/or rebuilding of DOT-4 series cylinders (excluding DOT-4-L) were provided. (See Section 180.211)

The regulations now permit the use of pressure sensitive labels to display the requalification markings on fire extinguishers.

Section 180.205(f)(2) now requires the removal of any coating or attachments which may inhibit the visual inspection process.

Requalifiers are prohibited from relying on REE markings on cylinders applied by persons other than the manufacturer.

Ultrasonic testing will continue to be permitted under the exemption program.

Pass It On
Readers affected by these provisions are encouraged to explore in greater depth the regulations pertaining to these changes. They are detailed in over 40 pages of information in the September 30 Federal Register. You also should take steps now to ensure that all of your training materials have incorporated these new and revised provisions.

Keep in mind that DOT regulations state the following: “If RSPA adopts a new regulation or changes an existing regulation that relates to a function performed by a hazmat employee, that hazmat employee must be instructed in those new or revised function-specific requirements without regard to the three-year training cycle.”