Page 9 - july-august2018

Is your RIN
safety & education renewed?

he Pipeline and Hazardous Materials Safety Administration (PHMSA) requires companies to ob-
tain a Requalification Identification Number (RIN) to requalify cylinders. RINs are valid for 5 years
and a facility should submit a renewal application prior to expiration of the RIN The RIN must be
Tstamped or affixed on the cylinder after completion of the requalification process. The propane
industry generally uses two methods to requalify a cylinder: a hydrostatic test (also known as volumetric
expansion); or external visual inspection Federal regulation 49 C F R 180 209 details the requirements for
requalification by either method.
Hydrostatic Test
Cylinders requalified by a hydrostatic test may be used for 10 or 12 years before requalifica-
tion is necessary again. PHMSA attempted to reduce the requalification period to 10 years, but NPGA
petitioned the agency to keep the requalification period for hydrostatic tests at 12 years. While PHMSA
reviews NPGA’s petition, either a 10 or 12 year requalification period is acceptable. The Enforcement
Notice explaining the acceptability of 10 or 12 years is available on NPGA’s website , the NPGAction
App under Resources - Fact Sheets, or by contacting NPGA
External Visual Inspection
Requalification by external visual inspection carries a 5 year requalification period, and it was
not affected by the regulatory action of PHMSA A facility must submit an application to PHMSA for a
RIN before the facility may perform requalification of cylinders by external visual inspection. The RIN
applies to the facility where requalification is performed, rather than an individual who performs the
requalification at the facility.
NPGA recommends submitting renewal applications 60 days before the RIN expires According
to regulation 49 C F R 107 705(c) , a current RIN holder whose renewal application is submitted 60 days
prior to its expiration may continue to requalify by
visual inspection if the RIN expires before DOT re- Sumter Coatings makes you look good
sponds to the renewal application For example: while protecting your most valued assests.
Sarah’s Propane has a RIN that will expire in 100
days, but Sarah submits the renewal application
to DOT 61 days before it expires On the day it is
set to expire, Sarah still hasn’t heard from DOT
But, because she submitted the renewal applica-
tion 60 days before the expiration date, Sarah’s
Propane can continue to perform visual inspec-
tion to requalify cylinders while she waits to hear
back from DOT
Sarah waits - or forgets - to submit the Formulated specifically for propane tanks
renewal application until sometime after the RIN and equipment,
expires The regulations say that Sarah cannot providing both protection and appearance.
conduct visual inspection to requalify cylinders
because her RIN has expired The same would be th.
true if Sarah submits the renewal application less Spring paint sale ends July 29
than 60 days before it expires
Click here to download a RIN applica-
tion , or to complete the RIN application through
PHMSA’s online portal
Contact Sarah J Reboli, NPGA’s Director
of Regulatory Affairs with any additional ques-
tions 800.448.9504 | bergquistinc.com
Your questions answered by the people who know propane equipment.

9 Alabama Propane Gas Association | July / August 2018