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Old 08-01-2008, 11:38 AM   #21
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Default RE: tank O2 cleaning

Ok finally I foundtheanswer I was looking for.

Sorry, but it took me a few days to get all the information.

The above quote is from DOT Regulation 173.34. section a-1 This is just a small piece of the PAGES of legalese.....:banghead


The entire regulation can be found here:

http://hazmat.dot.gov/sp_app/approvals/regs/173.34.htm

"1) No person may charge or fill a cylinder unless it is as
specified in this part and part 178 of this subchapter. A cylinder that
leaks, is bulged, has defective valves or safety devices, bears evidence
of physical abuse, fire or heat damage, or detrimental rusting or
corrosion, must not be used unless it is properly repaired and
requalified as prescribed in these regulations."


So....we have to now reference the "subchapter, part 178"


so we scroll down through the legalese..

Our tanks are Dot-3A, DOT-3AA (steel) and DOT-3AL (Aluminum)

Retest and Inspection of Cylinders \1\
------------------------------------------------------------------------
Minimum retest
Specification under which pressure (p.s.i.) Retest period
cylinder was made \2\ \3\ (years)
------------------------------------------------------------------------
DOT-3A, 3AA.................... 5/3 times service 5, 10, or 12 (see
pressure, except Sec. 173.34



Well fud! What is it? 5 years 10 years or 12 years?:banghead

12) A cylinder made in conformance with specification DOT-3A, DOT-
3AA, DOT-3B, DOT-4BA or DOT-4BW (Secs. 178.36, 178.37, 178.38, 178.51,
178.61 of this subchapter) having a service pressure of 300 psi or less
that is used exclusively for methyl bromide, liquid; mixtures of methyl
bromide and ethylene dibromide, liquid; mixtures of methyl bromide and
chlorpicrin, liquid; mixtures of methyl bromide and petroleum solvents,
liquid; or methyl bromide and nonflammable, nonliquefied compressed gas
mixtures, liquid; that is commercially free of corroding components, and
that is protected externally by a suitable corrosion resistant coating
(such as galvanizing or painting) and internally by a suitable corrosion
resistant lining (such as galvanizing) may be tested every 10 years
instead of every five years, provided that a visual internal and
external examination of the cylinder is conducted every five years in
accordance with CGA Pamphlet C-6

Well our tanks have a working pressure over 300 pis..so more legalese..


(16) DOT-3A or 3AA cylinders. (i) A cylinder made in conformance
with specification DOT-3A or 3AA with a water capacity of 125 pounds or
less
that is removed from any cluster, bank, group, rack or vehicle each
time it is filled, may be retested every ten years instead of every five
years, provided the cylinder complies with all of the following--

(B) The cylinder is used exclusively for air (GOOD SO FAR)


10 years perhaps...NO!

(E) The cylinder is not used for underwater breathing; (BAM! FIVE YEARS)


But wait! Who do these regulations actually apply to?


TITLE 49--TRANSPORTATION

CHAPTER I--RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION, DEPARTMENT OF
TRANSPORTATION

PART 173--SHIPPERS--GENERAL REQUIREMENTS FOR SHIPMENTS AND PACKAGINGS
--Table of Contents

Soooo more research is required....


According to Brian D. Basura of http://brianb.org/ whom I contacted, a do it yourselfer in the diving industry..

" Brian,

It?s a CGA and/or DOT regulation governing the ?Interstate Transport of Compressed Gas Cylinders?. It?s not a ?Law??

The dive industry has adopted this regulation as a guideline and their liability insurers have mandated they abide by it as a defendable standard in court cases."

A little legalese so I asked him the direct question:

So in other words I cannnot be charged with a criminal offense for having a full "out of hydro" cylinder and a dive shop cannnot be charged for any type of offense for filling a tank out of hydro. Correct?


His reply.."That is my understanding?"

A little vague for me...lets confirm his statement....


so....

I called Washington DC, the Federal Department of Transportation.

According to the DOT their regulations apply to commerce. Tanks transported for business purposes. Not to me in my Toyota Highlander unless I am conducting commerce. And not to the guy filling the tanks. He is not transporting them on public roads. Unless he picks up and delivers the tanks and charges for the service. (commerce)

I asked them these questions specifically. The response, "These regulations do not apply to a group of guys out to have a good time."

This Cameran fellowspoke in laymen terms. He cut out the legalese....


DOT in Washignton DC, 202-366-4000, spoke with Cameran Satterthwaite. He was quite familar with the above referenced regulation.


Mr. Vance Harlow is partially correct. There is no law, and the regulations apply to vehicles transporting cylinders on public roads for commerce purposes.


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Old 08-01-2008, 05:07 PM   #22
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Default RE: tank O2 cleaning

OK Brian. You can play sea lawyer all you want.If you get busted, I hope the judge will see things your way.

I'm still not filling out of date tanks.In black and white it'sultimately a safety issue. But I guess I can send everyone over to your house to get them filled?

And there are 2 "D's" in Fudd.

:letsdrink
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Old 08-01-2008, 05:35 PM   #23
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Default RE: tank O2 cleaning

LOL Evensplit!

Dont send em my way! I have no compressor YET!

But I dont think FUD has two D's.

http://en.wikipedia.org/wiki/Fear,_u...inty_and_doubt

Computer term coined by IBM.

But I'll consult my attorney!

Anyhow's I understand the safety concerns and especially the insurance aspect. Just wanted to get the low down on how the actual laws and regulations applied.

over and out!
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Old 08-01-2008, 05:57 PM   #24
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Default RE: tank O2 cleaning

Quote:
bmoore (8/1/2008)LOL Evensplit!

But I dont think FUD has two D's.

http://en.wikipedia.org/wiki/Fear,_u...inty_and_doubt

Computer term coined by IBM.

But I'll consult my attorney!
This is why he is called FUDD with two D's.

http://en.wikipedia.org/wiki/Elmer_Fudd
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Old 08-01-2008, 06:07 PM   #25
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Default RE: tank O2 cleaning

I wasn't calling anyone FUD I was using it interchangeably with FU**.

It stands for fear uncertianity and doubt.
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Old 08-01-2008, 06:48 PM   #26
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Default RE: tank O2 cleaning

Quote:
bmoore (8/1/2008)I wasn't calling anyone FUD I was using it interchangeably with FU**.

It stands for fear uncertianity and doubt.
That's funny. Because Evensplit's nickname is Fudd.:doh
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Old 08-01-2008, 07:14 PM   #27
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Default RE: tank O2 cleaning

But for an entirely different reason....:letsdrink
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Old 08-25-2008, 10:02 AM   #28
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Default RE: tank O2 cleaning

tunis
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