Steel Faber Tanks Do not have DOT stamp

[captain]

http://www.phmsa.dot.gov/staticfile...er Historical Files/61fr__1996/61fr-26750.pdf

http://www.phmsa.dot.gov/staticfiles/PHMSA/SPA_App/OfferDocuments/SP14396_2009031322.pdf covers most of it.

This all evolves from discussions I had with the various cylinder manufacturers/engineers I dealt with in regard to foreign cylinders. As I stated you can use them for personal use.

Any hydro facility who tested them would have to be authorized by the proper foreign agency to test and stamp said cylinder. If someone wanted a "courtesy hydro" without stamping, that's another situation

All I can define in the regulation is that a foreign made cylinder "must be hydroed" if it is to be filled and shipped overseas. I see nothing that states it "must" be immediately shipped or shipped at all.

The second is just a special permit to ship a particular gas, arsine, by a particular company.

A hydro facility in the US authorized by the EU to test EU cylinders can test and stamp an EU cylinder.
That cylinder can be filled but not "transported in commerce" in the US. That an LSD does or does not decide to fill it is in no way related to or covered by DOT regulation. The letter of calcification from the DOT says as much.
Anyone can interpret a meaning of regulation but the only one that counts is DOT's and it is simply a matter of asking for a letter of calcification from the DOT.

 

[Leadking]

You can argue all day long about the DOT but other agencies come into play also. OSHA is one I dealt with extensively. If you have an employee fill a non-DOT cylinder you are in violation of OSHA regulations. Most dive operations are corporations , which means even the "owner" is an employee. The regulations are quite clear, and as I have stated over the years I have posted, DOT is not the only regulating authority.

In Minnesota, and most states, even my 150psi shop air compressor tank had to be regularly inspected and licensed.
It was somewhat ridiculous that my 1000psi accumulator bottles on my die cast machines did not.