GWSS Interoffice Memo
To:All Field Personnel
From:Geary Senterfitt
Date:09/26/00
Re:HYDRO TESTING INTERVALS OF BREATHING AIR CYLINDERS AND ATTACHED EMAIL FROM USCG/DOT IN WASHINGTON D.C.
Every 3 to 4 years the reoccurring question comes up regarding hydro testing intervals of breathing air cylinders regarding 5 or 10 year intervals. Gulf Wide Safety Systems has written to Washington DC to both the USCG and DOT officials and asked for documentation and rulings on their positions on this hydro testing intervals. Gulf Wide Safety Systems also provided both agencies with documentation from CFR’s 46 and 49 and provided paperwork on past rulings by the USCG on Hydrotesting intervals on DOT 3A and 3AA cylinders that are marked with a plus (+ - 10% overfill/and a star 10 year hydrotest). It is widely stated that D.O.T. regulations (USA Flagged vessels) breathing air cylinders, marked with a star, did not have to be hydrotested with-in the first 10 years of manufacture and every 5 years thereafter. This is not the case as provided with the attached documentation. This is believed to come from the foreign manufactured (solas) cylinder regulations, which requires a 10-year hydro after manufacturer and every 5 years thereafter.
In recent weeks the Washington DC USCG and Washington DC DOT representatives were contacted and were jointly involved in the CFR’s on this hydrostatic testing intervals. The email attached was received this past Friday from Lt. Mike Farrell from the Morgan City USCG office. Simply stated, as believed by Gulf Wide Safety Systems, the hydro test interval required pressurized cylinders, marked with a plus (+) and/or a star will be 10 years even after the initial 10 year manufacturing date. The cylinders must be re-hydrotested in accordance with the CFR’s pertaining to a plus and a star requalification procedures and only if that cylinder was originally tested and marked with a plus and a star.
The following references are provided for reference only for pressurized cylinders of several types:
CFR 46 147.60Compressed gasses
CFR 46 147.65Hydro testing CO2
USCG NAVIC 15-95Halon cylinder hydro test intervals
CFR 49 173.30210% overfill
CFR 49 173.3410 year hydro test
CFR 49 173-301 (J&I)Foreign cylinders
Merchant Marine Circular No. 70Testing of CO2 cylinders – Panamanian – Panama Policy On Technical Matters
NFPA 10 Table 5-2Hydro testing interval of fire cylinders
MSC/Circ. 847-12 June, 1998Solas Chapter II-2 Vague Expressions and Wording Solas Chapter 6.5 – Panama/6.2.1 Denmark/6.2 Liberia
UL 300Wet galley cooking suppression systems
NVIC 7-70Portable Fire Extinguishers
NVIC 13-86Portable Fire Extinguishers
Email memo from Lt. Mike Farrell10 year hydrostatic testing on breathing air cylinders
Classification Society Memo 3/13/00Regulation for hydraulic test frequency of pressure vessels by various countries
All Field Technicians have been provided with the above interoffice memos. The above references are not intended to be regarded as a ruling and are provided for reference only. If anyone has documentation, standards or information that should be considered, please advise with reference dates and source. If you need copies of any of the referenced sources se me.
Personnel References:
Jim Ruggieri – USCG Compliance, Washington DC (202)267-0028
James Jones – DOT Compliance, Washington DC (202)366-4505
Commander Haws – USCG, Morgan City, LA (504)380-5360
Lt. Mike Farrell – Memo/Email dated September 22, 2000 – USCG< Morgan City, LA (504)380-5360
Lt. Joe Grimes – Memo, May 21, 1998 – USCG, New Orleans, LA
Lt. Jim Elliott – Memo, July 9, 1997 – USCG, Morgan City, LA
Lt. June Thompson – Memo, October 12, 1996 – USCG, Port Arthur, TX
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