American Cylinder and Safety, LLC

The industry leader in compressed gas HAZMAT training

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DOT Emergency Exemption of Re-qualification for Certain Cylinders

Posted on April 19, 2020 at 10:30 AM Comments comments (2)

NOTICE OF ENFORCEMENT DISCRETION REGARDING CYLINDERS THAT HAVE EXCEEDED THEIR PERIODIC REQUALIFICATION TEST DATE

 

The U.S. Department of Transportation's Pipeline and Hazardous Materials Safety Administration (PHMSA) understands that due to the Coronavirus Disease 2019 (COVID-19) public health emergency, many members of the medical and industrial gas industry may be experiencing difficulty in obtaining cylinders due to the increased demand for these gases or a disruption in the normal business model for cylinder exchanges. This has made it difficult for the industry to consistently obtain cylinders which can be filled in accordance with the requalification provision specified in 49 CFR 173.301(a)(6). PHMSA gives notice that it will not take enforcement action against any person who fills a DOT-specification cylinder used to transport Division 2.2 non-flammable gas provided the cylinder meets all requirements of the Hazardous Materials Regulations (HMR) except that the cylinder is overdue for periodic requalification by no more than 12 months. Depending on the cylinder type, periodic requalification is required at either a 5-year or 10-year interval. This enforcement discretion is in response to unprecedented changes in business practices related to the COVID-19 outbreak and is intended to minimize disruptions in the supply chain, especially those related to providing medical gases to the health care industry. This enforcement discretion will be exercised by the Federal Motor Carrier Safety Administration and PHMSA. This relief applies only to transportation by motor vehicle, and does not extend to transport by air, vessel, or railroad. Prior to filling and offering for transportation, all cylinders must be inspected in accordance with the applicable Compressed Gas Association Pamphlet and DOT requirements. Any cylinder that does not pass the prefill inspection criteria must not be filled. This notice is limited to the filling and offering of cylinders containing Division 2.2 gases when such cylinders are no more than 12 months past their periodic requalification test date. These cylinders must be in compliance with all other requirements of the HMR. This Notice of Enforcement Discretion is effective while the Department of Health and Human Services determination that a public health emergency related to COVID-19 exists or 90 days from its date of issuance, whichever is sooner.

Issued April 6, 2020, in Washington D.C.

 

DOT Announcement on HAZMAT Training Requirements

Posted on April 19, 2020 at 9:50 AM Comments comments (0)

NOTICE OF ENFORCEMENT POLICY REGARDING TRAINING REQUIREMENTS


The U.S. Department of Transportation's Pipeline and Hazardous Materials Safety Administration (PHMSA) understands that many hazardous materials (hazmat) employers may be experiencing difficulty in either obtaining or providing recurrent training as required by the Hazardous Materials Regulations (HMR, 49 CFR Parts 171-180) due to the Coronavirus Disease 2019 (COVID-19) outbreak.

PHMSA gives notice that it will not take enforcement action against any hazmat employer who is unable to provide recurrent training consistent with HMR training requirements. This enforcement discretion is in response to unprecedented changes in business practices related to the COVID-19 outbreak and is intended to minimize disruptions in the supply-chain. Thisenforcement discretion will be exercised by the Federal Aviation Administration, the Federal Motor Carrier Safety Administration, the Federal Railroad Administration, PHMSA, and the United States Coast Guard.

PHMSA does want to take this opportunity to remind employers that the HMR does not require training to be provided in a traditional classroom setting or through on the job training. Any method of training delivery, including web based, self-paced computer instruction, remotely delivered classroom instruction, on the job training, or some combination of those methods that cover the required elements in 49 CFR 172 Subpart H are acceptable. PHMSA encourages the utilization of any of these training methods to provide hazmat employees with appropriate recurrent training even if testing is not possible. This notice is limited to the recurrent training requirements found in 49 CFR 172. 704( c )(2). Hazmat employers must comply with all other obligations under the HMR and other applicable laws. This notice will remain in effect for 90 days from the date of issuance.

Issued March 25, 2020, in Washington D.C.

COVID-19 Class Cancelations

Posted on March 22, 2020 at 11:40 AM Comments comments (0)

Unfortunitly due to the recent COVID-19 Outbreak, we have ahd to cancel some classes that are scehduled in the near future.  As of today, we have canceled all in-Person classes through July 2020.  This is due to many states ordering a ceasation of gatherings over 10 people.  As soon as this current outbreak is determined to be ont he downturn, we we reschedule inperson classes.  American Cylinder and Safety apoligizes for these cancelations but the health and safety of our students is paramount.  

New Class Dates Added for 2020

Posted on January 10, 2020 at 10:00 AM Comments comments (0)

We have added new class dates to our 2020 Training Schedule.  More classes will be added as we schedule them.  Please continue to check back.  We are also happy to schedule a course at your facility that works with your schedule.

The Cost of a Violation

Posted on November 26, 2019 at 11:10 AM Comments comments (0)

Don’t think that penalties imposed by PHMSA for violations are anything to worry about? Think again! If you willfully violate 49 CFR, it can cost you, your business, and your pocketbook plenty. In October of this year (2019), PHMSA increased the amount of money it can fine you in the event of a violation. The new adjustments are summarized as follows:

Minimum penalty for a hazardous materials training violation - -$493

Maximum penalty for a Hazardous Materials Violation - $81,993

Maximum penalty for a Hazardous Materials Violation that results in death, serious illness, severe injury to any person, or substantial destruction of property - $191,316

As you can see, the cost rises significantly depending on the severity of the violation. All of these can simply be avoided by proper training at your facility. Contact us to schedule training or to discuss whether your facility training already covers the PHMSA requirements.

 

Important Update For Linde Gas Customers

Posted on November 25, 2019 at 1:05 PM Comments comments (0)

Important update for customers of Linde Gas.

Linde and its affiliates, including Praxair, Inc., will increase the prices of product and equipment rentals in North America, beginning 1st December (2019), or as contracts permit.

 

The industrial gas giant today announced the following increases:

 

Up to 15% for nitrogen and oxygen

Up to 20% for carbon dioxide, argon and hydrogen

Up to 15% for facility fees or equipment rentals

Helium prices will also be increased as contracts permit.

 

The adjustments are being made to help maintain reliable supply to customers through infrastructure reinvestment, including continued capacity upgrades and expansion where possible.

 

Safety Advisory: Fraudulent Low Pressure Cylinders

Posted on November 8, 2019 at 10:25 AM Comments comments (0)

PHMSA is issuing this safety advisory notice to inform the public, industrial gas stakeholders, and relevant government officials of the risks associated with re-qualifying, filling, and transporting cylinders bearing the DOT specification markings ‘‘DOT 4E’’ or ‘‘DOT 4BA’’ that were produced by a company located in Thailand by the name of Metal Mate. Metal Mate does not have an approval from PHMSA to manufacture cylinders to DOT specifications; therefore, cylinders marked with the Metal Mate name are not DOT specification cylinders. These cylinders are to be considered fraudulent and should not be filled.

Sign Up Special

Posted on July 28, 2019 at 6:30 PM Comments comments (0)

Email us to sign up for our mailing list and we will send you a free copy of our Compressed Gas Cylinder Storage and Safety Booklet.  Get important industry updates, safety announcments, and notification of sales and classes by being on our mailing list.

Compressed Gas Cylinder Codes and Marking Guide on Sale

Posted on May 17, 2019 at 9:40 AM Comments comments (0)

The Compressed Gas Cylinder Code and Markings Guide is on sale through the end of May.  Get it now for 20% off the normal price.

Special Permit 16320 has Expired

Posted on April 30, 2019 at 12:45 AM Comments comments (0)

One of the more recent controversies in the compressed gas market is the use of MAE testing to extend the service life of Carbon Fiber SCBA Cylinders. You can refer to previous blog articles to understand what all of the hoopla is about. In the meantime, it has come to our attention that SP 16320 which allows the procedure is expired. USDOT Permits office published a notification on their website confirming the permit holder Digital Wave applied for renewal but at this time their application has been denied. USDOT indicated they expect ongoing discussion regarding the permit and at some point it may be renewed.

In the meantime, since this is a testing SP and not a manufacturing SP, it is not clear the ramifications to cylinders tested with this method but USDOT will follow up with information on what this means for previously tested cylinders (if anything). However until the permit is renewed, testing by this method is not allowed.

 


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