Page 9 - july-august 2022

safety & education

DOT requires RINs to requalify cylinders;

RINs expire every 5 years. Is your RIN valid?

he Pipeline and Hazardous Materials Safety the facility or for the company at-large
Administration (PHMSA) requires compa- NPGA recommends submitting renew-
nies to obtain a Requalification Identifica- al applications 60 days before the RIN expires
Ttion Number (RIN) to requalify cylinders According to regulation 49 C F R 107 705(c), a
RINs are valid for five years. The RIN must be current RIN holder whose renewal application
stamped or affixed on the cylinder after comple- is submitted 60 days prior to its expiration may
tion of the requalification process. The propane continue to requalify by visual inspection if the
industry generally uses two methods to requalify RIN expires before DOT responds to the renewal
a cylinder: a hydrostatic test (also known as vol- application For example:
umetric expansion); or external visual inspection Ex 1) Sarah’s Propane has a RIN that will
Federal regulation 49 C F R 180 209 details the expire in 100 days, but Sarah submits the renewal
requirements for requalification by either meth- application to DOT 61 days before it expires On
od the day it is set to expire, Sarah still hasn’t heard
Each facility must submit an applica- from DOT But because she submitted the re-
tion to PHMSA for a RIN before the facility may newal application 60 days before the expiration
perform requalification of cylinders by external date, Sarah’s Propane can continue to perform
visual inspection The RIN applies to the facility visual inspection to requalify cylinders while she
where requalification is performed, rather than waits to hear back from DOT
an individual who performs the requalification at Ex 2) Sarah waits – or forgets – to submit
the renewal application
until sometime after the
RIN expires The regulations
DEALERS LP EQUIPMENT say that Sarah cannot
An Affiliate of R.E. Michel Company, LLC
conduct visual inspection
to requalify cylinders be-
cause her RIN has expired
Your SINGLE SOURCE for
The same would be true if
Sarah submits the renew-
al application 40 days
before it will expire; or
anytime less than 60 days
before it expires
Click here for a pdf
of the RIN application
ALL
...and ALL your propane equipment needs!
Questions? Con-
tact Sarah J Reboli,
Check us out online at dealerslp.com NPGA’s Vice President
and follow us on of Regulatory & Industry
Affairs.■

1405 Sinnett Avenue • Dothan, Alabama 36303
800-433-8925

9 Alabama Propane Gas Association | July / August 2022