cylinder requalification - crum & forster insurance2 develop written procedures for requalifying...
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RISK ENGINEERING
CYLINDER REQUALIFICATION In order to ensure your safety and the safety of your customers, propane cylinders must be inspected prior to each time they are filled. One step in the pre-fill inspection identifies cylinders that are due for requalification before they can be returned to service. If a propane cylinder is neglected to be properly requalified, this could cause issues should the cylinder be involved in an accident.
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Four Ways to Address DOT Cylinder Requalification
1 Understand the DOT, OSHA, and CGA standards.
2 Develop written procedures for requalifying cylinders.
3 Train all employees involved in the inspecting, filling, marking, requalifying, and inspecting DOT cylinders.
4 Document all training and cylinder requalification of cylinders.
There are various issues involving accidents with DOT cylinders. Some of the issues that were highlighted as major deficiencies included, but not limited to:
1 Cylinders not requalified2 Age of cylinder3 Leaking cylinders4 Cylinder markings5 Employee training6 Written requalification procedures7 Cylinder requalification records
As a result, this safety brief is to serve as a reminder how important it is to follow the DOT, OSHA, and Compressed Gas Association (CGA) Code Publications when inspecting, filling, marking, and requalifying DOT cylinders.
What could happen if a propane cylinder is involved in an accident that was not properly requalified? It could cost up $160,000,000 million.
Food Truck Explosion – Case involving a propane cylinder that was not visually requalified.e.g. Philadelphia food truck explosion; https://www.youtube.com/watch?v=NGGlddddi_0
Explosion Case Briefhttps://www.apnews.com/28a8843f0e844ca8829d81c540d01d60
How is your compliance with requalification of DOT cylinders?Below are a few questions to answer.
Cylinder RequalificationRisk Engineering
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RISK ENGINEERINGContact Information Reporting Claims or Loss24-hour toll free number:
1.800.690.5520Email to:
1 Do you requalify DOT Specification and/or Special Permit cylinders?2 Are all employees requalifying cylinders adequately trained?
• Did you properly document the training?
• Are you providing refresher training at minimum of every 3 years?3 Are employees prepared to answer questions regarding your procedures for requalifying cylinders?4 Do you have written procedures for requalifying cylinders on-hand at each requalifying facility? 5 Do all employees know where to find your requalification procedures?6 Do you have a Requalifier Identification Number (RIN) for each physical address where the cylinder
requalification is being performed? If you have multiple locations within your company requalifying cylinders, each separate physical location must have their own (RIN).
7 Is the RIN registration within expiration date?8 Are you documenting the visual requalification of cylinders and documenting all required items per CGA
Publications and DOT requirements?
Cylinder RequalificationSafety Alert
RISK ENGINEERINGContact Information Reporting Claims or Loss24-hour toll free number:
1.800.690.5520Email to:
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Training & Training Records (49 CFR 107.805)• All persons requalifying cylinders shall be trained.• CGA Publications, such as CGA C-6 and C-6.3 are two standards that can be used as guidance
materials to formalize your training for requalifying cylinders. CGA publications can be used as guidance in developing your cylinder requalification training procedures, but not designed to be considered the stand alone documents for training. Therefore, if you have the Plant Operations or Cylinder Requalification training modules from the Propane Education and Research Council (PERC), they would suffice as appropriate training guides. It is not required to have the CGA Publications at your requalification facilities, but you definitely should have one of the two PERC pamphlets mentioned above. (Re: PERC Cylinder Requalification 2017 Edition PRC 009673 and Pipeline Hazardous Material Safety Administration Interpretation Document 10-0006 Cylinder Requalifiers)
• A record of training shall be completed with all persons who requalify cylinders.
Requalifier Identification Number (RIN)• Each location requalifying cylinders must have a special registration. All RIN registrations expire
after 5 years.• Check your records to ensure all facilities are registered to visually requalify a DOT Specification
or Special Permit cylinder and within the 5-year expiration date.• If you need to renew your special permit you can send in a renewal form that can be accessed here
Visual Inspection Records (49 CFR Part 180.205)• A visual inspection record must be kept in accordance
with CGA Pamphlets.• Date of requalification• Serial number• DOT specification or special permit number• Actual dimensions• Manufacturer’s name or symbol • Owner’s name or symbol, if present• Result of visual inspection• Disposition, with reason for any repeated test• Rejection or condemnation; and• Legible identification of test operator.
• Each cylinder subject to visual inspection must be approved, rejected, or condemned according to the criteria in the applicable CGA pamphlet.
RISK ENGINEERINGCylinder RequalificationRisk Engineering
This material is provided for information purposes only and is not intended to be a representation of coverage that may exist in any particular situation under a policy issued by one of the companies within Crum & Forster. All conditions of coverage, terms, and limitations are defined and provided for in the policy. This material was developed as a general guide to safety from sources believed to be reliable and is not intended to provide legal, technical or other professional advice. These materials are not intended to replace any training or education that users may wish or need to provide to their personnel. Crum & Forster does not endorse any of the vendors listed in this publication, nor does it endorse the information, products or services that they offer or provide. Compliance with all Federal, State or local laws and regulations remain the policyholder’s responsibility.
The C&F logo, C&F and Crum & Forster are registered trademarks of United States Fire Insurance Company.Version 2.0 2018.07.31 4
Is requalifying cylinders a quick process?Visually requalifying DOT cylinders is not a 2 minute process. There is a lot to know and many steps to take to “properly” requalify a cylinder. If your company elects to take on the responsibility to visually requalify cylinders, then please follow all steps as required from DOT, OSHA, and CGA Publications.
How can we help?1 The Propane Education and Research Council (PERC) developed a training program to
assist propane companies to better understand the standards and procedures for visually requalifying standards. You may obtain this training program from PERC or access it from C & F’s learning management system.
2 Access Crum & Forster’s learning management system (LMS) to download the plant operations and/or cylinder requalification training manuals. To register and obtain access to the LMS: C & F E-learning
3 Below is a screen shot showing where to download the plant operations and cylinder requalification pdf manuals.
4 Contact Todd Buechler at [email protected] or at 309-838-3231 to sign up for a virtual training class for cylinder requalification training. You will need a computer or tablet with a camera and audio features to participate in the class. This training is provided by Silverback Consulting – The Propane University.