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The U.S. Department of Transportation
recently released new regulations in an effort to clarify the
regulations on periodic inspection and testing of cylinders.
Document HM22OA was issued as a final rule with an effective date
of October 1,1996. The document can be found in the May 28,1996
Federal Register (Vol.61, Number 103, pages 26749 26764). The
important changes include:
1. Clarification that visual inspection,
internal and external, are required each time a cylinder is
retested.
2. New requirements for accuracy of pressure
gauges and expansion indicating devices (burettes, used in water
jacket testing:
i) Certified gauges with accuracy of +1/2%
of full range.
- ii) Pressure gauges readable to +1
% of test pressure,
- midpoint interpolation of analog
gauges is permitted.
-
- iii) Pressure gauges must be readable
from 90% - 110%
- of test pressure.
-
- iv) Expansion indicating devices must be
accurate to
- +1/2%,
or better, of its full scale and readable to
- +1% or 0.1 cubic
centimeter, whichever is larger.
-
- v) Water jacket test equipment must be
verified accurate to
- +1% each day by the use
of a calibrated cylinder.
- Note: The above requirements for
pressure gauges and
- daily verification of system
accuracy will also apply to
- proof-pressure testers in the
very near future!
3. New wording concerning "condemned"
cylinder and how to mark them.
4. Requirements for cylinders retested by the
proof pressure test method to include the letter "S"
next to the test date.
Note: Cylinders retested by the proof pressure
method do not currently have to have the RIN number marked on the
extinguisher but Amerex recommends that you add your Retesters
Identification Number (RIN) to the hydrotest label that is
approved by exemption E-11372.
5. A clarification that anyone who hydrotests a
DOT specification cylinder using either the water jacket test or
proof pressure test must have a RIN.
6. New and clearer wording on how to obtain a
RIN.
7. Clarification of what is required to obtain
a RIN including :
i) Current copies of 49CFR that apply to
retesting of cylinders.
- ii) Current copies of all exemptions
governing exempt cylinders that are
- inspected, retested and marked
at that location.
-
- iii)Copies of each CGA pamphlet
incorporated by reference that applies to the
- retest activities.
8. Record keeping requirements - records to be
maintained until expiration of the retest period or until
cylinder is again retested, which ever comes first.
Also, system verification records
must be kept in daily logs.
9. The paragraph describing retesting of
specification cylinders used as fire extinguishers is rewritten
and renumbered from 173.34 (e)(18) to173.34 (e)(19).
Note: Paragraph (B) (2) (ii) still
contains an error regarding the test interval for 3A, 3AA and 3AL
cylinders, especially those used as C02 extinguishers. We believe
the correct test interval is 5 years as required by NFPA-1 0.
- Note: This rewrite essentially contains
everything that
- was previously in 173.34 (e)
(18) and E-8886.
- Basically, all Amerex hand
portable dry chemical
- and halon extinguishers using
DOT specification
- cylinders can be proof pressure
tested every 12
- years. Larger extinguishers such
as stored pres-
- sure wheeled extinguishers can
also be proof
- pressure tested, but after the
initial 12 year inter-
- val, subsequent retests will be
required every 7
- years.
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