Page 9 - july-august 2019
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safety & education
Fact Sheet: Requalification Identification Number (RIN)
he Pipeline and Hazardous Materials is performed, rather than an individual who
Safety Administration (PHMSA) requires performs the requalification at the facility
companies to obtain a Requalification
T Identification Number (RIN) to requalify NPGA recommends submitting renewal
cylinders RINs are valid for 5 years and a applications 60 days before the RIN expires
facility should submit a renewal application According to regulation 49 C.F.R. 107.705(c),
prior to expiration of the RIN The RIN must a current RIN holder whose renewal
be stamped or affixed on the cylinder after application is submitted 60 days prior to
completion of the requalification process its expiration may continue to requalify by
The propane industry generally uses two visual inspection if the RIN expires before DOT
methods to requalify a cylinder: a hydrostatic responds to the renewal application For
test (also known as volumetric expansion); or example:
external visual inspection Federal regulation
49 C.F.R. 180.209 details the requirements for • Ex. 1) Sarah’s Propane has a RIN that
requalification by either method will expire in 100 days, but Sarah submits the
renewal application to DOT 61 days before it
Hydrostatic Test expires On the day it is set to expire, Sarah
Cylinders requalified by a hydrostatic still hasn’t heard from DOT. But, because she
test may be used for 10 or 12 years before submitted the renewal application 60 days
requalification is necessary again PHMSA before the expiration date, Sarah’s Propane
attempted to reduce the requalification can continue to perform visual inspection to
period to 10 years, but NPGA petitioned the requalify cylinders while she waits to hear back
agency to keep the requalification period for from DOT
hydrostatic tests at 12 years While PHMSA
reviews NPGA’s petition, either 10 or 12 • Ex 2) Sarah waits – or forgets – to
year requalification period is acceptable submit the renewal application until sometime
The Enforcement Notice explaining the after the RIN expires The regulations say
acceptability of 10 or 12 years is available on that Sarah cannot conduct visual inspection
NPGA’s website, the NPGAction App under to requalify cylinders because her RIN has
Resources – Fact Sheets, or by contacting expired The same would be true if Sarah
NPGA submits the renewal application 40 days
before it will expire; or anytime less than 60
External Visual Inspection days before it expires
Requalification by external visual
inspection carries a 5 year requalification Click here to download a RIN application,
period, and it was not affected by the or to complete the RIN application through
regulatory action of PHMSA A facility must PHMSA’s online portal.
submit an application to PHMSA for a RIN Contact Sarah J. Reboli, NPGA’s Deputy
before the facility may perform requalification Counsel, Regulatory Affairs, at sreboli@npga.
of cylinders by external visual inspection The org with any additional questions. ■
RIN applies to the facility where requalification
9 Alabama Propane Gas Association | July / August 2019
