Page 9 - mar-apr 2020

Fact Sheet: Requalification
safety & education Identification Number (RIN)

he Pipeline and Hazardous Materials Safety application For example:
Administration (PHMSA) requires companies • Ex. 1) Sarah’s Propane has a RIN that will
to obtain a Requalification Identification expire in 100 days, but Sarah submits the renewal
TNumber (RIN) to requalify cylinders RINs application to DOT 61 days before it expires On
are valid for 5 years and a facility should submit the day it is set to expire, Sarah still hasn’t heard
a renewal application prior to expiration of the from DOT But, because she submitted the
RIN. The RIN must be stamped or affixed on the renewal application 60 days before the expiration
cylinder after completion of the requalification date, Sarah’s Propane can continue to perform
process The propane industry generally uses two visual inspection to requalify cylinders while she
methods to requalify a cylinder: a hydrostatic test waits to hear back from DOT
(also known as volumetric expansion); or external • Ex 2) Sarah waits – or forgets – to submit
visual inspection Federal regulation 49 C.F.R. the renewal application until sometime after the
180.209 details the requirements for requalification RIN expires The regulations say that Sarah cannot
by either method conduct visual inspection to requalify cylinders
Hydrostatic Test because her RIN has expired The same would be
Cylinders requalified by a hydrostatic true if Sarah submits the renewal application 40
test may be used for 10 or 12 years before days before it will expire; or anytime less than 60
requalification is necessary again. PHMSA days before it expires
attempted to reduce the requalification period Click here to download a RIN application, or
to 10 years, but NPGA petitioned the agency to to complete the RIN application through PHMSA’s
keep the requalification period for hydrostatic online portal ■
tests at 12 years. While PHMSA reviews NPGA’s
petition, either 10 or 12 year requalification period
is acceptable The Enforcement Notice explaining WORLD CLASS PERFORMANCE
the acceptability of 10 or 12 years is available FROM AMERICA’S
on NPGA’s website, the NPGAction App under INDUSTRY LEADER
Resources – Fact Sheets, or by contacting NPGA PRODUCTS:
External Visual Inspection • New TRANSPORT TRAILERS
• New BOBTAILS
Requalification by external visual inspection • New BULK STORAGE TANKS
carries a 5 year requalification period, and it Ask about availability of
used or refurbished
was not affected by the regulatory action of transport trailers and bobtails
PHMSA A facility must submit an application to SERVICES:
PHMSA for a RIN before the facility may perform • Refurbishing & Repairs
• Blasting & Painting
requalification of cylinders by external visual • 5-Year Inspections
inspection The RIN applies to the facility where • Annual Inspections
requalification is performed, rather than an • Stress Relieving
• Parts
individual who performs the requalification at the
facility PROUDLY MANUFACTURED & ASSEMBLED IN THE USA
NPGA recommends submitting renewal MISSISSIPPI
applications 60 days before the RIN expires TANK COMPANY
According to regulation 49 C.F.R. 107.705(c), a
HEADQUARTERS INDIANA DIVISION
current RIN holder whose renewal application P O Drawer 1391 1301 East Elkhorn Road
Hattiesburg, MS 39403-1391 Vincennes, IN 47591-8004
is submitted 60 days prior to its expiration may PH: 800-331-8265 ext. 224 PH: 812-886-8265
FAX: 601-264-0769 FAX: 812-886-8979
continue to requalify by visual inspection if the www .mstank.com
EMAIL: salesid@mstank.com
EMAIL: sales@mstank.com
RIN expires before DOT responds to the renewal
9 Alabama Propane Gas Association | March / April 2020