American Cylinder and Safety, LLC
|Posted on October 1, 2020 at 11:55 AM|
Today is the first day of October. This means different things to different people. For some it means fall is here, the leaves change, and weather starts to get colder. For the U.S. Government, it means the beginning of a new fiscal year. The new fiscal year brings about new editions of the Codes of Federal Regulations (CFR). Updated every year, they are published and available for purchase starting in November. This is important because a cylinder requalifier needs to have on hand the latest regulations in order to satisfy the requirements of the U.S. Department of Transportation under section 180.205(a)(4). If you are party to a unannounced compliance inspection, one of the first questions a DOT enforcement inspector will ask during an audit is "show me your latest CFR book". If you show them a previous edition it could be a $600 - $1200.00 fine. Ensure that you are not out of compliance by procuring the latest edition when published.
|Posted on September 29, 2020 at 3:30 PM|
The US Department of Transportation (DOT) has reached a reciprocity agreement with Transport Canada (TC) which allows all DOT-3AL qualified aluminum high pressure gas cylinders to be sold, put into service, and retested in Canada. Transport Canada has advised that the TC-3ALM crown markings/stampings on aluminum cylinders are no longer necessary.
|Posted on September 24, 2020 at 12:30 AM|
The US Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) has released the 2020 edition of its Emergency Response Guidebook (ERG). This edition provides first responders with the revised and updated go to manual that offers guidance on what to do in that first critical 30 minutes of a HAZMAT response. The revised ERG contains an indexed list of dangerous goods, their associated ID numbers, and general hazards that they might pose in a transportation accident. It also provides the recommended safety precautions when responding to a event with HAZMAT. This guidebook is available to all public safety agencies in all States and territories for free, through designated state Emergency Management coordination offices. It is also available as a free mobile app. For additional information visit www.phmsa.dot.gov.
|Posted on July 14, 2020 at 9:05 PM|
PHMSA has extended the Exemption of Enforcement of Division 2.2 cylinders that are out of Requalification through October 31st, 2020. Full details can be read in the blog bost below.
|Posted on April 19, 2020 at 10:30 AM|
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.
|Posted on April 19, 2020 at 9:50 AM|
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.
|Posted on November 26, 2019 at 11:10 AM|
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.
|Posted on November 25, 2019 at 1:05 PM|
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.
|Posted on November 8, 2019 at 10:25 AM|
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.
|Posted on July 28, 2019 at 6:30 PM|
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