Thursday

Scuba Cylinders and Title 49 of the Code of Federal Regulations

Here are the hard and fast regulations that we must follow as gas blenders and safe divers.
 
No cylinders will be overfilled more than 10% period.
Here are the facts.


FICTION: Fill Station Operators do not have to be trained
FACT:  The truth is that the US Code of Federal Regulations, Title 49, requires "Function Specific" training for all employees.  If they fill cylinders they need Fill Station Operator training.
In Canada the rules are even more specific.  Transport Canada regulation CSA-B340 requires that persons filling containers be trained although it does not specify the exact nature of that training.
FICTION: The Code of Federal Regulations is not law.
FACT:  While technically true, 44 USC 1507 (public law) requires that the Federal Register be “judicially noticed”, that is, recognized by the courts as law.  All aspects of the CFR have been first printed in the Federal Register and the CFR is prima facie evidence of the text of the original documents as published in the Federal Register. 
In short, while the CFR may technically be regulation and not law, you will never win that argument in court.
FICTION:       Compressed air is not a designated Hazardous Material.
FACT:  Compressed air is a HAZMAT.  49CFR173.115 defines a compressed air at 40.6 psia or greater at 68ºF as a Class 2, Division 2.2 HAZMAT.
FICTION:       Formal training in HAZMAT is not required.
FACT:  Absolutely wrong!  49CFR172.702 requires a hazmat employer to ensure that each of its hazmat employees is provided appropriate function specific training and to ensure that each of its hazmat employees is tested by appropriate means. 49CFR172.704 goes on to specify what this training must consist of.  This training must be completed within 90 days of employment or change in job function and then every three years thereafter.
FICTION:       Persons who receive no compensation but who handle high pressure cylinders are not required to have formal and documented HAZMAT training.
FACT: This is one of the most onerous myths of all. 49CFR171.8 defines a HAZMAT employee as one who, among other things, is employed by a hazmat employer and who in the course of employment directly affects hazardous materials transportation safety. This term includes an individual, including a self-employed individual, employed by a hazmat employer who, during the course of employment loads, unloads, or handles hazardous materials.
Do not confuse “employed” with “paid”.  Employ means to use, whether there is compensation involved or not. Those divers who just hang around a dive store asking to help and who are used by the dive store to move, load and fill cylinders require formal and documented function specific training just as much as do paid employees.  Not conducting this training can be very costly.
Furthermore. § 1910.101   Compressed gases (general requirements) provides for: (a) Inspection of compressed gas cylinders. Each employer shall determine that compressed gas cylinders under his control are in a safe condition to the extent that this can be determined by visual inspection. Visual and other inspections shall be conducted as prescribed in the Hazardous Materials Regulations of the Department of Transportation (49CFR parts 71–179 and 14CFR103). Where those regulations are not applicable, visual and other inspections shall be conducted in accordance with Compressed Gas Association Pamphlets C–6, C-6.2, C-6.2 and C6.3 which are incorporated by reference as specified in §1910.6.
FICTION:     The inspection guidelines of Compressed Gas Association (CGA) Pamphlets C-6, C-6.1, C-6.2, and C-6.3 are not mandatory.
FACT: 49CFR180.205 incorporates these publications “by reference” into the CFR itself.  As such, the guidance on these publications are to be considered by US courts as being part of the Code of Federal Regulations and treated as if they were Federal Law.
 CGA C-6 is entitled Standards for Visual Inspection of Steel Compressed Gas Cylinders
CGA C 6.1 is entitled Standards for Visual Inspection of High Pressure Aluminum Compressed Gas Cylinders
CGA C-6.2 is entitled Guidelines for Visual Inspection and Requalification of Fiber Reinforced High Pressure Cylinders
CGA 6.3 is entitled Guidelines for Visual Inspection and Requalification of Low Pressure Aluminum Compressed Gas Cylinders
FICTION:     A steel cylinder may not be authorized for a 10% excess fill after the first hydrostatic retest.
FACT:    The US Code of Federal Regulations establishes the requirements for pressurizing steel cylinders beyond their stamped service pressure.  49CFR173.302 sets forth the requirements for pressurizing cylinders 10% in excess of its marked service pressure.  These requirements are:
1)     Cylinder must be 3A or 3AA (steel)
2)     Cylinder must be equipped with the proper frangible (burst) disc.
3)     Cylinder’s must have been tested or retested using the hydrostatic water jacket method
4)     Neither the average nor maximum wall stresses exceed the limits established in the CFR
5)     An external and internal visual inspection made at the time of the test or retest shows the cylinder to be free of excessive corrosion, pitting or dangerous defects.
6)    A plus sign “+” is added following the test date marking.
 The use of the term “test or retest” clearly authorizes hydrostatic retest facilities to reauthorize an appropriate cylinder for a 10% excess fill.  Is this common?  No.  Is it legal?  Yes.
FICTION:       Steel cylinders do not have to be visually inspected for cracks.
FACT:  Yes they do.  CGA Pub. C-6 lists a crack inspection as part of the inspection procedure – and remember that C-6 has been “incorporated by reference” into the CFR.
FICTION:       A condemned cylinder must be rendered incapable of holding air by drilling a hole in the sidewall or by destroying the neck threads.
FACT:  49CFR180.207 prescribes the procedures for the condemnation of cylinders.  They are to be condemned by stamping a series of “X”s over the DOT specification number and the service pressure or by stamping “CONDEMNED” on the cylinder shoulder. Only at the direction of the cylinder owner may the requalifier render the cylinder incapable of holding pressure.  Additionally, the cylinder owner must be notified IN WRITING that the cylinder is condemned and may not be filled with a hazardous material.
 Cylinders failing hydrostatic retest or visual inspection cannot be returned to their owner without being condemned.  However, those facilities that destroy your cylinder neck threads or drill a hole in the sidewall WITHOUT YOUR PERMISSION are in violation of the law.
FICTION:       The law requires all 6351-T6 alloy aluminum cylinders to be inspected with an eddy current tester.
FACT:  49CFR180.205 requires only that 6351 alloy cylinders in SCUBA, SCBA and oxygen service be eddy current tested at time of hydrostatic requalification.
FICTION:       6351-T6 alloy aluminum is still authorized for the manufacture of high pressure 3AL cylinders.
FACT: 49CFR178.46 is the specification for 3AL seamless aluminum cylinders.  It specifies 6061-T6 alloy only. 
 This DOES NOT mean that existing 6351-T6 alloy cylinders are to be pulled from service.  It only means that no new 3AL cylinders can be manufactured from this alloy.
FICTION:       All 6351-T6 alloy cylinders have been recalled.
FACT: This is closely related to the above myth and is absolutely untrue.   49CFR178.46 simply no longer authorizes 6351-T6-T6 for future manufacture on 3AL cylinders (all new 3AL cylinders must be manufactured using 6061-T6 alloy).  6351-T6 cylinders in use may be used so long as they remain within established hydrostatic testing and visual inspection standards for continued service.   Postulating this myth to customers is unethical.
 FICTION:       No special training is required to visually inspect the Luxfer fiber wrapped (FRP2) SCUBA cylinder E12479
FACT: DOT Special Permit SP-12479 specifically requires that the cylinder be given an annual visual inspection by a Professional Scuba Inspectors, Inc. (PSI) certified person.
FICTION:       An external visual inspection of a cylinder is not required before filling
FACT: 49CFR173.301 requires that before each cylinder filling the person filling it must visually inspect the outside of the cylinder for cracks, leaks, bulges, defective valve, leaking or defective burst disc, evidence of physical abuse, fire or heat damage, and detrimental corrosion.  Any such cylinder may not be filled.
 Failure of the Fill Station Operator (FSO) to conduct this routine informal visual inspection may have a highly memorable consequence.
FICTION:       Paintball and Spare Air cylinders do not require hydrostatic retesting
FACT:  Even though paintball and Spare Air cylinders are filled by the cylinder owner, they still require periodic requalification.  49CFR180.205 requires that each cylinder bearing a DOT specification marking be requalified (hydrostatically retested) as specified in the Requalification Table of section 180 of the CFR. Cylinders bearing a DOT Special Permit number (SPxxxxx) must be requalified in conformance the terms of the applicable Special Permit.
 There is an exception.  49CFR180.209 Table 1 exempts cylinders not exceeding 2 inches outside diameter AND less than 2 feet in length from periodic volumetric expansion tests.  If either dimension exceeds the limit a periodic requalification is required.   Paintball cylinders and most Spare Air cylinders usually exceed at least one of these limits. 
FICTION:       Steel cylinders with a marked service pressure of 2400 psig are low pressure cylinders
FACT:  Nothing could be further from the truth.  CGA Pub C-6 defines a high pressure steel cylinder as one containing pressures of 900 psig or greater – and don’t forget that CGA Pub C-6 has been “incorporated by reference” into the CFR.
 Strangely, the high pressure definition for aluminum cylinders is different. CGA C-6.1 defines a high pressure aluminum cylinder as one containing pressures of 1800 psig or greater.
FICTION:       Aluminum cylinders manufactured prior to 1990 are no good.
FACT:       To tell a customer this boders on fraud.  The only place where the US DOT has established a terminal use date for cylinders are in the various  Special Permits for the fiber wrapped cylinders.  The terminal date for wrapped cylinders is usually 15 years, but some Carbon Fiber wrapped cylinders are now authorized a 30 year life.  3A, 3AA and 3AL cylinders, even 6351 alloy aluminum cylinders,  are authorized for continued service as long as they are within established hydrostatic test and visual inspection standards.
FICTION:       Cylinders are hydrostatically tested to 5/3 of their stamped Service Pressure
FACT:  While this is generally true, cylinders containing a stamped test Pressure (TP) are to be tested to the specified test pressure.  Usually, but not always, this is 3/2 service pressure rather than 5/3.
FICTION:       A cylinder exposed to excessive heat must be condemned.
FACT: While simple exposure to high heat may require a cylinder to be pulled from service for further examination, it does not condemn a cylinder.  Condemnation requires some portion of the cylinder itself to be heated to the specified temperature.
 49CFR 180.203 defines overheating as a condition in which the temperature of any portion of an aluminum cylinder has reached 176 °C (350 °F) or higher, or in which the temperature of any portion of a steel or nickel cylinder has reached 343 °C (650 °F) or higher.  The various Special Permits governing fiber wrapped cylinders specify overheating as when any portion of the aluminum liner reached a temperature of 250 ºF.
FICTION:       The Code of Federal Regulations does not apply to me because I am not in interstate commerce
FACT:  In establishing the applicability of the CFR, 49CFR171.1 uses the term “in commerce” which has been misinterpreted by many as meaning in commercial and interstate commerce.  If we read the CFR further, however, we find in 49CFR171.8 that it defines “commerce” more broadly as meaning “trade or transportation in the jurisdiction of the United States within a single state; between a place in a state and a place outside of the state; or that affects trade or transportation between a place in a state and place outside of the state” (Emphasis mine).
 Do you use state and federal roads and highways to transport your Division 2.2 Hazmat (compressed air) to/from a dive site or an emergency?  If so, the code applies to you.
FICTION:       The Exemption or Special Permit number on a cylinder is the authorization to manufacture cylinders and has nothing to do with the longevity of the cylinder.
FACT:  In order for an E or SP cylinder to remain in service its Special Permit (as of 1 Jan 2006 the terminology has again changed and Exemptions are again called Special Permits) must be current.  That means it must be in effect.  Requalifiers are required by DOT to have on hand the "current" Special Permit of the cylinder being requalified.  If the Special Permit has expired it cannot be current.  Hence the cylinder is no longer authorized for service.
FICTION:       DOT/TC cylinders, when in need of a requalification, may be requalified by either a DOT or a TC authorized requalifier and then be filled and transported in both the United States and Canada.
FACT:  While a cylinder manufactured to DOT/TC standards may be used and transported in both Canada and the United States, when the cylinder receives its periodic hydrostatic test requalification its usability may be limited.  To be filed and transported in the United States it MUST be requalified by a USDOT authorized requalifier.  To be filled and transported in Canada it MUST be requalified by a TC authorized requalifier.
FICTION:       There is no authority for SCUBA cylinders to have an annual visual inspection.  This is just a standard of practice in the SCUBA industry
FACT:  In CGA Pub P-5 Paragraph 6.1 the Compressed Gas Association requires all cylinders in SCUBA service to be visually inspected annually.
FICTION:       All UN cylinders may be used to transport hazardous material in the United States
FACT:  To be transport hazardous material in the United States UN cylinders must bear the additional marking of USA or CAN (alternatively, US or CA).
FICTION:       All Aluminum cylinders manufactured prior to 1990 must be eddy current tested.
FACT:  Using the date 1990 is the lazy and inaccurate method of determining cylinder alloy. 
49CFR180.209 requires only cylinders manufactured of 6351 alloy to be eddy current tested.  Not all cylinders manufactured prior to 1990 meet this criterion.  NO Catalina cylinder is made from this alloy regardless of its date of manufacture.  ALL Walter Kidde cylinders were made from this alloy.  Only SOME Luxfer cylinders were made from this alloy.  For SCUBA. SCBA and Oxygen  cylinders Luxfer phased a changeover in alloys from 6351 to 6061 over an thirteen month period from May 1987 through June 1988 and based it on cylinder size.
To ascertain the specific alloy for Luxfer cylinders you need to refer to the Luxfer Technical Bulletin dated November 12, 2003.  Here is a link to the Luxfer document.
FICTION:       The usability of the PSI Evidence of Inspection sticker expires.
FACT:  Unlike other EOI stickers which show the year of the visual as the last two digits in the century (00-99), the PSI-PCI sticker shows the year of the inspection as the last single digit in the decade (0-9).  Determining the decade of the inspection is really not significantly more difficult than determining the century of the inspection. If there is confusion as to the decade, a simple look at the hydro date should help. You NEVER have to replace your sticker inventory because you passed the highest two digit date on the sticker. 
Part 173 - Shippers - General Requirements for Shipments and Packaging
Subpart A-General
173.1 Purpose and Scope
173.1(a)(1)(2)(3)
 This part includes: Definitions of hazardous materials for transportation purposes; requirements to be observed in preparing hazardous materials for shipment by air, highway, rail, or water; and inspection, testing and retesting responsibilities for persons who retest, recondition, or maintain compressed gas cylinders used in the transportation of hazardous materials.
173.2 Hazardous materials classes and index to hazard class definitions.
Relative to scuba cylinders, the Class No. of the hazardous materials being considered is a"2", the Division No. is "2.2" and the name of the class or division is non-flammable compressed gas", and the 49CFR reference for definitions is 173.115
173.6 Materials of trade exceptions
When transported by a motor vehicle in conformance with this section, a material of trade (see 171.8) is not subject to any other requirements... besides those set forth or referenced in this section. (Section 6 of part 173)
173.6(a) Materials and amounts A material of trade is limited to...:
173.6(a)(2) A division... 2.2 material in a cylinder with a gross weight not over... 220 pounds
173.6(b) Packaging
173.6(b)(1) Packaging must be leak tight... and securely closed, secured against movement, and protected against damage
173.6(b)(5) A cylinder...containing Division 2.2 material must conform to packaging, qualification, maintenance and use requirements of this subchapter (subchapter C).  Manifolding of cylinders is authorized provided all valves are tightly closed.
173.6(c) Hazard Communication
173.6(c)(3) a DOT specification cylinder... must be marked as prescribed in this subchapter.
173.6(c)(4) The operator of a motor vehicle that contains a material of trade must be informed of the presence of the hazardous material... and must be informed of he requirements of this section. (173.6)173.6(d) Aggregate gross weight
...the aggregate gross weight of all materials of trade on a motor vehicle may not exceed 440 pounds.
Subpart B - Preparation of Hazardous Materials for transportation
173.23 Previously authorized packaging
173.23(a) 
When regulations specify a packaging with specification marking prefix "DOT", a packaging marked prior to January 1, 1970, with the prefix "ICC" may be used in it's place if the packaging otherwise conforms to applicable specification requirements. The markings on older scuba cylinders contain the prefixed ICC, the markings on newer scuba cylinders contain the prefix DOT
173.23(c) After July 2, 1982, a seamless aluminum cylinder manufactured in conformance with and for use under DOT special permit (SP) or exemption (E) 6498, 7042, 8107, 8364 or 8422 may be continued in use if marked before or at the time of the next retest with either the specification identification "3AL" immediately above the special permit or exemption number, or the DOT mark... in proximity to the special permit or exemption marking.
173.34 Qualification, maintenance and use of cylinders
173.34(a) General qualification for use of cylinders
173.34(a)(1) No person may charge or fill a cylinder unless it is specified in this part (Part 173) and part 178 (All American made and/or marketed Scuba Cylinders meet this requirement) A cylinder that leaks, is bulged, has defective valves or safety devices, bears evidence of physical abuse, fire or heat damage, or detrimental rusting or corrosion, must not be used unless it is properly repaired and re-qualified as prescribed in these regulations.
173.34(b) Grandfather clause. A cylinder in domestic use previous to the date upon which the specification therefore was made effective in these regulations may be used if the cylinder has been properly tested and otherwise complies with the requirements applicable for the gas with which it is charged. Currently here are few, if any "grandfathered" cylinders being used as scuba cylinders. However, any such cylinders which continue to pass their hydrostatic retests and their five year and annual visual inspections and continue o be suitable for the gases intended to be contained may be continued to be used.
173.34(c)Cylinder Marking. Each required marking on a cylinder must be maintained so that it is legible. Retest markings and original markings which are becoming illegible may be reproduced by stamping on a metal plate which must be secured to the cylinder.
173.34(c)(1) Additional information not affecting the markings prescribed in the applicable cylinder specification may be placed on he cylinder (applies o such information as annual evidence of inspection stickers, allowing them to be placed)
173.34(c)(3) Markings required on cylinders may not be altered or removed the exception to this is that the marked service pressure may be changed but only after a lengthy and involved procedure not typically pursued by recreational scuba divers (and not allowed for cylinder which have failed their periodic hydrostatic retesting unless reheat treated and requalified in accordance with this section [frankly speaking, not something to be pursued])
173.34(d) Pressure relief device systems. Cylinders must be equipped with one of more pressure relief devices per CGA Pamphlet S-1.1
173.34(d)(1) Safety devices are not required on cylinders 12 inches in length or less (exclusive of neck) and 4.5 inches or less in outside diameter. A pressure relief device is required on a cylinder charged with nonliquified gas to a pressure of 1800psi or higher a 70 degrees F (Scuba cylinders fall into this category)
173.34(e) Periodic qualification and marking of cylinders.
173.34(e)(1)(2) Every 5 years cylinders with the following specification marks (3A, 3AA or 3AL) must be retested to 5/3 times he service pressure, or to the test pressure marked on the cylinders shoulder when such is present. (what his means is that a cylinder's markings need o be carefully scrutinized prior to the retest procedure to determine  to what pressure he cylinder is to be retested. No cylinder maybe charged (filled) unless that cylinder has been inspected and retested and the retester has marked the cylinder appropriately. The retest must be performed by an authorized retester (A person holding a current retester's identification number issued by the Associate Administrator for Hazardous Material Safety.
173.34(e)(3) Visual Inspection.. each time a scuba cylinder is retested, it must be visually inspected, internally and eternally, in accordance with CGA Pamphlets C-6, C-6.1 as applicable.
The only requirement in the Code of Federal Regulations for visual internal and external examination is at the time of retest (once every 5 years, etc) Annual visual inspections are by mutual agreement... scuba cylinder owners submit their cylinders for annual inspections to individuals known to have been trained and certified to do annual inspections.
A person who only performs visual inspections on DOT or ICC specification cylinders is not required to obtain a retester identification number. However, a compressed gas cylinder may only be rejected by a person who has obtained such a retester identification number
173.34(e)(4) Pressure retest. Each cylinder required to be retested must be retested by means suitable for measuring the expansion of the cylinder under pressure (interior hydrostatic pressure in a water jacket, or other suitable apparatus)
173.34(e)(5) Cylinder rejection
173.34(e)(5)(i) A retester shall reject a cylinder when on visual inspection, it meets rejection standards in CGA pamphlet C-6, C-6.1 as applicable
173.34(e)(5)(iii) When a cylinder is rejected, the retester shall notify the cylinder owner in writing that the cylinder has been rejected and may not be filled.
In general, scuba cylinders which have been rejected should be condemned. A cylinder can only be rejected by an approved tester.
173.34(e)(6) Cylinder condemnation.
A scuba cylinder must be condemned when: upon inspection, it meets a condition of condemnation in CGA Pamphlet C-6 or C-6.1 (as appropriate); the cylinder leaks through its wall; there is evidence of cracking the extent that the cylinder is likely to be weakened appreciable; or permanent expansion exceeds 10% of total expansion. A cylinder is condemned by having a series of X's stamped over the ICC or DOT specification number and the marked service pressure.. or the word CONDEMNED is stamped on the shoulder.. or.. a the direction of the owner he cylinder is rendered incapable of holding pressure. When a cylinder is required to be condemned, the retester shall notify the cylinder owner, in writing that the cylinder is condemned and may not be filled. A cylinder can only be condemned by an approved retester. Steel scuba cylinders condemned because of excessive permanent expansion may reheat-treated (see note above) 3AL cylinders (aluminum) condemned because of excessive permanent expansion may not be reheat-treated.
173.34(e)(7) Retester Markings
Each cylinder passing retest must be marked with the cylinder retester's identification number set in a square pattern, between the month and year of retest date. The retester's identification number must be in characters not less than 1/8 inch high. Dates of previous tests must not be obliterated.
173.34(e)(8) Recordkeeping
The Code of Federal Regulations only identifies retesters (persons holding current retester identification numbers from the associate administrator for Hazardous Material Safety) as individuals who shall maintain records (current retester identification number issuance letters, daily records of visual inspections, hydrostatic retests, etc)
173.34.(e)(16) DOT-3A or 3AA cylinders. Defines so-called "star service". "Star service does not apply to cylinders used for diving, but may apply to cylinders in dive store compressed gas banks. A cylinder made in compliance with specification DOT-3A or DOT-3AA not exceeding 125 pounds water capacity (Steel scuba cylinders meet this criterion) and removed from any cluster, bank, group, rack or vehicle each time it is filled may be retested every 10 years instead of every 5 years provided the cylinder complies with all of the following:
  • Was manufactured after December 31, 1945
  • Used exclusively for air or certain other gases (argon, helium, nitrogen, oxygen or permitted mixtures)
  • Passes the CGA Pamphlet C-6 hammer test prior to each refill
  • Is stamped with a five-pointed star following the test date
  • Is dried inside immediately following hydrostatic testing
  • The cylinder is not used for underwater breathing
Some hydro-station and air fill station personnel misinterpret the "Star Service" description to mean that certain steel cylinders ("old") ones must be taken out of service. They are mistaken.
173.34(f) Cylinders subjected to the action of fire. Such cylinders must not again be placed in service until they have been properly reconditioned. Aluminum scuba cylinders subjected to the action of fire shall not be reheat treated and must be removed from service. Certain steel cylinders subjected to the action of fire shall be hydrostatically retested, other steel cylinders shall be reheat treated and reconditioned as specified in paragraph G.
173.34(g) Reheat treatment. The description is lengthy, and the process is involved. It will be safer and simpler to condemn such a cylinder (one which was subject to the action of fire) and remove it from service.
173.34(h) repair by welding or brazing of specification DOT-3A, DOT-3AA, ...cylinders.. describes a lengthy procedure not applicable to steel scuba cylinders and not at all applicable to aluminum ones. Frankly speaking, any scuba cylinder deemed to require repairs by welding or brazing should instead be condemned and removed from service.
Subpart C - Definitions, Classification and Packaging
Class 1
173.50 Class 1 - Definitions
173.50(a) 
An explosion is defined as an extremely rapid release of gas and heat. When a scuba cylinder under pressure ruptures, there is no release of heat. Although such incident can not technically defined as "explosions" they will always be described as such
Subpart D - Definitions, Classification, Packing Group Assignments and Exceptions for (certain) Hazardous Materials
173.115 Class 2 Division 2.2 - Definitions
173.115(b) 
Division 2.2 (Non-flammable, non-poisonous compressed gas-including compressed gas and oxidizing gas) For the purpose of this subchapter, a non-flammable, non-poisonous compressed gas (Division 2.2) means any mixture which-
173.115(b)(1) exerts in the packaging an absolute pressure of 40.6psia or greater at 68 degrees f. The gases in scuba cylinders referenced in this book meet this definition
173.115(d) Non Liquefied compressed gas. A non-liquefied compressed gas mean a gas, other than in a solution, which in a packaging under the charged pressure is entirely gaseous at a temeperature of 68 degrees f. The gases in scuba cylinders referenced in this book meet this definition
173.115(i) Service Pressure. The expression service pressure means the authorized pressure marking on the packaging. For example, for a cylinder marked "DOT3A1800", the service pressure is 1800psi
Subpart G - Gases; Preparation and Packaging
173.300a Approval of independent inspection agency
173.300a(a) 
Any person who does not manufacture cylinders.. and... is not directly or indirectly controlled by any person or firm which manufactures cylinders... may apply to the Department of Transportation for approval as an independent inspection agency for the purpose of performing cylinder inspections and verifications... require by part 178 (A very involved process)
173.301 General Requirements for shipment of compressed gases in cylinders...
173.301(b) Ownership of a container. A container charged with a compressed gas must not be shipped unless it was charged by or with the consent of the owner of the cylinder
173.301(c) Retest of Container. A container for which prescribed periodic retesting has become due must not be charged and shipped until such retest has been properly made.
173.301(d)(1) Manifolding containers in transportation. Manifolding of compressed gas cylinders is allowed for containers of argon, air, helium, nitrogen (or) oxygen, provided that each container is equipped with a pressure relief device [per 173.34(d)]
173.301(e) Container Pressure. The pressure in the container at 70 degrees f must not exceed the service pressure for which the container is marked or designated except as provided in 173.302(c) [173.302(c) describes the "10% overfill" allowed for some steel cylinders
173.301(f) Container pressure a 130 degrees f. The pressure in he container at 130 degrees f shall not exceed 5/4 times the service pressure.
173.301(h) Compressed gas containers. Compressed gases must be in metal containers built in accordance with DOT specifications in effect at time of manufacture.
173.301(i) Foreign cylinders in domestic use. Foreign cylinders are allowed in the USA provided they were manufactured, inspected and tested in accordance with the applicable DOT specification set forth in part 178
173.301(j) Charging of foreign cylinders. If the foreign cylinder is not manufactured, inspected and tested in accordance with DOT/ICC specifications it can only be charged for export.
173.302 Charging of cylinders with non-liquefied compressed gases.
173.302(a) 
Detailed requirements. Cylinders of compressed gases must be shipped, per 173.301 and 173.305 in the following containers:
173.302(a)(1) Specification 3A and 3AA (to mention only two). Applies to cylinders of compressed air, cylinders of compressed oxygen, cylinders of compressed helium, cylinders of compressed nitrogen and cylinders of compressed argon.
173.302(a)(5) Authorizes the use of aluminum cylinders (DOT 3AL) for compressed air, argon, helium, nitrogen and oxygen (to mention only a few)
173.302(a)(5)(i) In oxygen service, 3AL aluminum cylinders must be equipped only with brass or stainless steel valves
173.302(a)(5)(ii) In oxygen service, aluminum cylinders (DOT3AL) must be equipped only with straight threads in the neck opening.
173.302(a)(5)(iii)(iv) In oxygen service, aluminum cylinders (3AL) must be cleaned in compliance with the requirements of Fed Spec R-C-901b (Aug 7, 1967), paragraphs 3.7.2and 3.8.2 Cleaning agents equivalent to those specified in RR-C-901b may be used provided they are not capable of reacting with oxygen. One cylinder selected at random from a group of 200 or less, cleaned at the same time, must be tested for oil contamination in accordance with RR-C-901b paragraph 4..4.2.3 and meet the standard of cleanliness specified, and when used in oxygen service, the pressure in the aluminum cylinder may not exceed 3000psig at 70 degrees f
173.302(b) Filling limits. The pressure in the container at 70 degrees f must not exceed the service pressure for which the container is marked or designated. The only exception to this filing limit is provided in 173.302(c) which follows below.. and which does not apply to 3AL aluminum cylinders. 3AL aluminum scuba cylinders must not be overfilled.
173.302(c) Special filling limits for specifications 3AA cylinders. This is the regulation which permits 10% over-fill of certain steel cylinders. Steel cylinders may be over-filled by 10%, provided:
  1. Such cylinders are equipped with frangible disc safety relief devices (without fusible metal backing) having a burst pressure not exceeding the minimum prescribed test pressure
  2. Such cylinders were last tested or retested by the water jacket method
  3. for DOT 3AA cylinders the average wall stress shall not exceed 67,000PSI or the maximum wall stress shall not exceed 73,000 psi maximum. These figures in no way represent the pressure of gas in the cylinder, This wall stress is the internally (within the steel itself) distributed  force-per-unit-area mechanical reaction of the steel resulting from he deformation (stretching of the steel)
  4. An external and visual examination made at the time of test or retest shows the cylinder to be free from excessive corrosion, pitting or dangerous defects.
  5. That a plus sign (+) be added following the test date marking on the cylinder to indicate compliance with (c)(2), (c)(3) and (c)(4) above.
173.305 Charging of cylinders with a mixture of compressed gas and other material. Applies to nitrox, trimix etc
173.305(a)
 Detailed requirements. If the mixture is a compressed gas, that mixture must be treated as a compressed gas in accordance with these regulations
173.306 Limited Quantities of compressed gases
173.306(a) Limited quantities of compressed gases (air, argon, helium, nitrogen and oxygen, to name a few) are excepted from labeling (except when offered for transportation by air). In addition, shipments are not subject to subpart F of 172 (placarding), nor to part 174 (Carriage by rail) except 174.24, nor to part 177 (Carriage by public highway) except 177.817. Each package may not weigh more than 66 pounds gross weight

Wednesday

PADI TEC 40 Course Details




If you're interested in technical diving, but haven't yet met the prerequisites for the PADI Tec 50 Diver course or PADI Tec 45 course, you can consider enrolling in the PADI Tec 40 course. It is the first subdivision of the full PADI Tec Deep Diver course and consists of the first four dives. Because you can do one of  these dives in confined water (such as a swimming pool), many divers start the Tec 40 courses in the winter months, ready to continue in open water when spring arrives.

You'll learn to

  • Use decompression software and dive computers to plan and make decompression dives with no more than 10 minutes of total decompression and not deeper than 40 metres/130 feet. 
  • Use a single cylinder of decompression gas with up to 50 percent oxygen (EANx50) to add conservatism to the required decompression. 
Since it's part of the course, your PADI Tec 40 course training credits toward the PADI Tec 45 and Tec 50 courses.

The Scuba Gear You'll Use

You use recreational scuba equipment, with some minor additions to enhance your ability to deal with tec diving conditions.

The Learning Materials You'll Need

You'll use the Tec Deep Diver Crew-Pak, which introduces you to
  • tec diving lingo 
  • emergency procedures 
  • decompression and stage cylinder handling 
  • gas planning 
The pak includes a manual, dive planning checklist and dive planning slate. The optional Equipment Set-up and Key Skills video on DVD is a great tool to help you practice at home in between your tec diving adventures. You'll continue to use the Tec Deep Diver Crew-Pak through Tec 50.

Prerequisites


  1. Student divers must meet the following training prerequisites before starting the PADI Tec 40 course:
  2. Certified as a PADI Advanced Open Water Diver or provide a qualifying certification from another training organization. For this course, a qualifying certification is proof of training beyond entry level with experience in deep diving and underwater navigation.
  3. Certified as a PADI Enriched Air Diver or qualifying certification from another training organization. For this course, a qualifying certification is proof of training in enriched air nitrox diving with training that includes gas analysis cylinder labeling, oxygen toxicity, oxygen exposure, determining maximum depth limits, and planning enriched air dives with different enriched air blends (not just EANx32 and EANx36).
  4. Certified as a PADI Deep Diver or show proof of at least 10 dives to 30 metres/100 feet.
  5. Minimum age: 18 years.
  6. Have a minimum of 30 logged dives, of which at least 10 dives were made with enriched air nitrox deeper than 18 metres/60 feet.
  7. Course Tuition $600 plus materials, gas fills, and dive charter or park entry fees.

Tec 40 Equipment Requirements

Any one of the following appropriately labeled and marked options: A single cylinder with a dual valve (e.g., H valve or Y valve)

A single cylinder with single outlet valve and a pony bottle. Pony bottle should have same gas as main cylinder, or be breathable at the deepest planned dive depth. The minimum size cylinder is one with a free gas capacity of 850 litres/30 cubic feet.

Back mounted doubles with dual isolator manifold

Two side mounted cylinders (sidemount configuration)

Two complete regulators, one with a two meter/seven foot hose for air sharing and one with SPG. Where two, unmanifolded cylinders are used (sidemount or pony bottle), each regulator must have an SPG, carried and/or marked in such a way as to avoid confusion between them.

Stage/deco cylinder with attachment hardware and a single second stage regulator and SPG.

BCD with D-rings or other attachment points for a stage/deco cylinder.

Two dive computers, or one computer with a backup timer and depth gauge with dive tables.

Exposure suit appropriate for environment and dive duration. If student will use dry suits, they should be trained/experienced in their use in recreational diving prior to using them for Tec training or diving.

Weight system. Students should weight for the contingency of decompressing with near-empty cylinders.
Jon line (as needed for environment)

Inflatable signal tube, whistle and/or other visual and audible surface signaling devices. Note that a sausage type DSMB may double for the inflatable signal tube.

Reel and lift bag or DSMB. A suitable DSMB has sufficient buoyancy to help steady a diver during a drifting decompression, and is unlikely to spill when deployed from the underwater.

Knife/cutting device and back up

Slate

Back up mask (optional)

Compass

Lights

Backup buoyancy control. The student must have a reliable means for controlling buoyancy and maintaining decompression stops in midwater with a failed primary BCD. This is usually accomplished with a backup BCD (double wings) or, when using light weight cylinders, the use of a dry suit is permitted. 

ADDITIONAL EQUIPMENT CONSIDERATIONS
Equipment provided by Instructor

  • Computer with decompression software
  • Oxygen analyzer
  • Emergency Oxygen & first aid kit
  • Contents labels

  • Required Paperwork

    Tec 40 Knowledge Development Session 1

    Tec 40 Knowledge Development Session 2

    Tec 40 Knowledge Development Session 3

    Practical Application

     Training Dives

    Tec 40 Training Dive 1

    Key Standards

    Environment: Confined water or limited open water with ready access to water shallow enough in which to stand (Local Pool)
    Minimum Depth: 2.5 metres/8 feet
    Maximum Depth: 10 metres/30 feet
    Decompression: No stop only
    Gases: Air, EANx up to EANx50
    Ratios: 6:1, 8:1 with one or more certified assistants

    Skills

    To successfully complete this training dive, students must be able to:
    1. Assemble and inspect the basic technical diving rig.
    2. Demonstrate the proper weight required for the dive.
    3. Demonstrate neutral buoyancy while wearing the basic technical dive rig by hovering for 1 minute without sculling or kicking.
    4. Within 30 seconds, independently close the cylinder valve to a regulator that is experiencing a simulated free flow.
    5. Assist a team mate by closing the correct valve to a regulator that is experiencing a simulated free flow.
    6. Within 30 seconds, independently close the isolator valve in response to a simulated manifold leak.
    7. Respond to a simulated out of gas emergency by signaling a team mate., switching to the team mate’s long hose second stage, then swimming 30 metres/100 feet using the long hose regulator and maintaining contact with the team mate.
    8. Respond to a team mate’s simulated out of gas emergency by, on signal, proving the team mate with the long hose second stage, switching to the short hose secondary, then swimming 30 metres/100 feet as the team mate uses the long hose regulator, maintaining contact.
    9. Working in a team, perform a bubble check, descent check and S-drill.
    10. Independently don, remove and re-don a stage/deco cylinder on the bottom.
    11. Perform gas switches to a stage/deco cylinder correctly following the NO TOX procedure.
    12. Shut down both manifold valves and the isolator valve, and switch second stages to maintain a breathing supply, beginning with any valve chosen by the instructor, within 60 seconds (or within 40 seconds if there is no isolator valve).
    13. Deploy a lift bag or DSMB from the bottom in water too deep in which to stand.
    14. Swim at a steady pace at a constant depth for sufficient time to determine the SAC rate.
    15. Using only neutral buoyancy, maintain a simulated decompression stop for eight minutes.
    16. Remove and replace stage/deco cylinder at the surface in water too deep in which to stand
    Tec 40 Training Dive 2

    Key Standards

    Environment: Open water (Dive Boat or Spring)
    Minimum Depth: 10 metres/30 feet
    Maximum Depth: 18 metres/60 feet
    Decompression: No stop only
    Gases: Air, EANx up to EANx50
    Ratios: 6:1, 8:1 with one or more certified assistants

    Skills

    To successfully complete this training dive, students must be able to:
    1. Working in a team, plan the dive following the A Good Diver’s Main Objective Is To Live procedure, and perform predive checks following the Being Wary Reduces All Failures procedure.
    2. Independently don and remove a single deco cylinder at the surface.
    3. Descend along a line to the bottom, maintaining control of depth and descent speed by adjusting buoyancy.
    4. Working as a team, perform appropriate bubble checks and descent checks.
    5. While continuously swimming, independently stage a deco cylinder, swim at least 10 metres/30 feet from it, return to it, and don it.
    6. Swim at least two minutes and a distance of 18 metres/60 feet sharing gas with the long hose as both the donor and the receiver.
    7. Perform the gas shutdown drill within 60 seconds (40 seconds if not wearing isolator doubles).
    8. Perform a working rate SAC swim by swimming for approximately five minutes at a level depth, recording the appropriate information for later calculation.
    9. Demonstrate time/depth and gas supply awareness by writing the depth and time at each 35 bar/500 psi of back gas consumed.
    10. Demonstrate turn pressure and time limit awareness by signaling the instructor upon reaching the turn pressure or time limit the team had planned were this really a decompression dive.
    11. As a team, deploy a lift bag/DSMB from the bottom.
    12. As a team, simulate a partially failed lift bag/DSMB by deploying a second lift bag/DSMB up the line of the first lift bag.
    13. Use primarily proper buoyancy control to ascend along a line at a controlled rate not to exceed 10 metres/30 feet per minute, or slower if specified by a dive computer, to stop at a simulated decompression stop at 5 metres/15 feet, without ascending past it.
    14. Record the appropriate information for later calculation of a deco rate SAC by simulating a 10 minute required decompression stop at 5 metres/15 feet.
    15. While neutrally buoyant at a simulated deco9mpression stop, with a team mate, NO TOX gas switch to decompression cylinder while maintaining depth within 1 metre/3 feet of the stop depth.
    16. Throughout the dive, respond appropriately to simulated emergencies prompted by the instructor.
    17. Post dive, use desktop decompression software to determine the oxygen exposure (OTUs and CNS “clock”) of the dive as it was actually made.
    Tec 40 Training Dive 3

    Key Standards

    Environment: Open water (Dive Boat or Spring)
    Minimum Depth: 15 metres/50 feet
    Maximum Depth: 27 metres/90 feet
    Decompression: No stop only
    Gases: Air, EANx up to EANx50
    Ratios: 4:1, 6:1 with one or more certified assistants

    Skills

    To successfully complete this training dive, students must be able to:
    1. Working in a team, plan the dive following the A Good Diver’s Main Objective Is To Live procedure, and perform predive checks following the Being Wary Reduces All Failures procedure.
    2. Complete a simulated decompression dive based within Tec 40 limits (40metres/130 feet max depth, 10 minutes max deco. EANx50 max oxygen content).
    3. Descend along a line to the bottom, maintaining control at depth and descent speed by adjusting buoyancy.
    4. Working as a team, perform appropriate bubble checks and descent checks.
    5. Perform the gas shutdown drill within 45 seconds (30 seconds if not wearing isolator doubles).
    6. Demonstrate turn time/depth and gas supply awareness by writing the cylinder pressure at each 10 minutes of dive time.
    7. Demonstrate turn pressure and time limit awareness by signaling the instructor upon reaching the turn pressure or time limit the team had planned were this really a decompression dive.
    8. As a team, deploy a lift bag/DSMB from the bottom.
    9. Ascend the lift bag/DSMB line and complete the simulated decompression, staying together with the team, remaining neutrally buoyant and staying within plus or minus .5 metres/1.5 feet of stop depth by controlling buoyancy.
    10. Throughout the dive, respond appropriately to simulated emergencies prompted by the instructor.
    Tec 40 Training Dive 4

    Key Standards

    Environment: Open water (USS Oriskany)
    Minimum Depth: 26 metres/85 feet
    Maximum Depth: 40 metres/130 feet
    Decompression: Up to 10 minutes total decompression time based on breathing bottom gas throughout the dive (no accelerated decompression)
    Gases: Air, EANx up to EANx50
    Ratios: 3:1, 4:1 with one or more certified assistants

    Skills

    To successfully complete this training dive, students must be able to:
    1. Working in a team, plan the dive following the A Good Diver’s Main Objective Is To Live procedure, and perform predive checks following the Being Wary Reduces All Failures procedure.
    2. Complete an actual decompression dive within Tec 40 limits (40 metres/130 feet max depth, 10 minutes max deco, EANx50 max oxygen content).
    3. Descend along a line to the bottom, maintaining control at depth and descent speed by adjusting buoyancy.
    4. Working as a team, perform appropriate bubble checks and descent checks.
    5. As part of a team, demonstrate time/depth and gas supply awareness and turn pressure and time limit awareness by turning the dive at the planned time, when any team mate’s computer shows the planned decompression time or when any team mate reaches turn pressure.
    6. Ascend at a safe rate not to exceed 10 metres/30 feet per minute, or slower if prompted by a dive computer, and complete the required decompression as a team.
    7. Throughout the dive, respond appropriately to actual or simulated problems or emergencies. 

    Tuesday

    Bonaire Trip

    Everything about Bonaire has surpassed expectations.
    We started out with a nice tour of the island on the way to our resort.
    We did a not so quick orientation and hit the water as soon as we could.

    The second day we did our first boat dives on they Bayena to the small island and encountered sea turtles, angles, barracuda, peacock flounder, snake eels, and morays.

    The night dives were even better as huge tarpon hung with us and hunted in our lights.
    Angie and Lila got up close and personal with an eagle ray.  Lucky.

    We loaded up in our trucks and hit the shore for some quite adventuresome beach dives that hosted double reefs and creatures galore.

    The nights were filled with camaraderie and friendship over awesome meals.

    With unlimited and easy diving I recommend this trip to everyone.

    Instructor Course

    Emergency First Response (EFR) Instructor course --
    Emergency First Response (EFR) Instructor course | After the recent hurricanes in the Americas and in the wake of the tsunami in Asia, emergency preparedness is gnawing at the edge of our collective consciousness; it reinforces the need for all of us to be prepared to be self-sufficient in a time of crisis -- especially in the magnitude of disasters like the world has seen in the past year. We also face the omnipresent threat of terrorist attacks; each of us may be called upon to help a fellow traveler, possibly in the mist of our daily commute to work or while shopping at our local market. Now is the time to take stock of your personal situation. Are you prepared? | Preparedness goes far beyond having a flashlight, water and a battery-powered radio. Having training in CPR and first aid is critical, as you are likely to be the emergency responder for your family or in your workplace or neighborhood when Emergency Medical Services are delayed or unavailable.Instructor Course
    $399
    EFR Instructor Materials are included!
    Emergency First Response Instructor course | You can get CPR, AED and first aid training in your neighborhood from Emergency First Response. Our training approach to training builds your confidence to provide care when there is a medical emergency - and confidence is everything when a true emergency is at hand. We do this by teaching CPR and first aid skills in a non-stressful learning environment and providing more hands-on skill practice time. General academic information is covered using our independent study materials. This allows the instructor to focus class time on skill development rather than lecture. More practice time means better skill retention, which gives you the confidence to respond in the event of a medical emergency.During the Emergency First Response Instructor course, you will build on your skill as an Emergency Responder and focus on developing your instructional abilities to teach these skills to others. The Instructor course provides you with the additional training necessary to teach the Emergency First Response Primary Care (CPR), Secondary Care (First Aid) and Care for Children courses. Through a multi-media approach of independent study, classroom sessions and practical teaching assignments, you learn to conduct Emergency First Response courses.
    The instructor course covers specific goals and performance requirements for the Primary Care, Secondary Care and Care for Children courses, along with instruction on how to structure learning, the requirements of performance-based training, and your role as the instructor in the learning environment. You also learn how to motivate EFR students, evaluate student knowledge, present course content effectively, become proficient in developing students' hands-on skills practice sessions, and are taught how to present an effective scenario-based learning experience.
    The Emergency First Response program also provides for optional (yet recommended) Automated External Defibrillator (AED) and Emergency Oxygen sections.

    Prerequisite: To enter the Emergency First Response Instructor course, you must be 18 years old and have completed adult, child and infant CPR and first aid training in the past 24 months or a be a practicing medical professional such as a physician, Emergency Medical Technician, Paramedic or Registered Nurse.

    Course Fee: $399.00*, Includes Instructor manual.
    EFR (Emergency First Response) | EFR Instructor manual and other required materials are included with the course
    *(Plus EFR student materialss if not EFR Certified.
    Instructor Application Fee $86.50 paid to EFR, not Down Under)

    Certification: EFR Instructor

    Sample EFR Instructor Course Schedule: 
    Day 1
      EFRI Orientation
    -Program Philosophy
    -Learning & Instruction
    -Primary Care (CPR) Skills Workshop
    -Lunch 
    -Care for Children
    -Care for Children Skills Workshop
    -Introduction to AED

    Day 2
    -Secondary Care (1st AID) Skills Workshop
    -Introduction to Emergency Oxygen Use
    -Lunch
    -Organizing & Marketing EFR Course
    -EFR Instructor Examination
    -Administrative Paperwork / Graduation

    Wednesday

    Divemasters Wanted!




    Job Description : Divemaster/Boat Crew/Retail Center Staff



    DUTIES AND RESPONSIBILITIES Guide
    A part time or full time hourly position rotating through Dive and Snorkel Charters, Discover Scuba Diving/Scub Tune Ups, and Retail
    A varied schedule will include day, evening and weekend shifts

    Essential Job Functions:
    Execute all duties as boat crew for snorkel, scuba, and special charter trips including, but not limited to, boat set up and breakdown, boat maintenance, briefings, interpretive tours, guiding and site setting
    Independently supervise guided tours and run Divemaster Conducted Programs
     Set up, check out, distribute and maintain rental equipment, blend nitrox and fill air cylinders as needed
    Enthusiastically answer inquiries
    Attend all staff meetings and all in-service training programs

    Requirements:
    Active Status PADI Divemaster
    V&B Professional Liability Insurance
    DAN Dive Accident Insurance
    US Citizen or have valid visa or immigration status to work in the US
    Valid US drivers license
    Ability to lift 50 pounds
    Maintain DOT Drug testing card



    Job Description : Retail Center Staff


    DUTIES AND RESPONSIBILITIES GUIDE
    A part time or full time hourly position that rotates through retail sales, equipment inspection & repair, gas blending, charter reservations, and booking scuba training courses
    A varied schedule will include day, evening and weekend shifts
    Essential Job Functions:
    Greet customers and ascertain what each customer wants or needs.
    Open and close cash registers, performing tasks such as counting money, separating charge slips, coupons, and vouchers, balancing cash drawers, and making deposits.
    Enthusiastically answer incoming calls.
    Maintain knowledge of current sales and promotions, policies regarding payment and exchanges, and security practices.
    Recommend, select, and help locate or obtain equipment based on customer needs, desires, and stock levels.
    Independently sell and set up the following: retail items ranging from T-shirts to Trimix Computers, Diving & Snorkel Charters, gas fills, and training courses from DSD to OWSI.
    Answer questions regarding the items listed above.
    Describe and explain equipment use, operation, and care to customers.
    Demonstrate use or operation of equipment.
    Clean shelves, counters, and displays.
    Exchange merchandise for customers and accept returns.
    Bag or package purchases.
    Help customers try on or fit equipment.
    Inventory stock.
    Prepare equipment for purchase or rental.
    Prep equipment for delivery.
    Estimate and quote equipment packages.
    Estimate cost of repair or service of equipment.
    Estimate cost of service, gear, or training required, such as “Cost of Sidemount Diver Course, Price of Sidemount BCD, Cost of Gas Fills, and Dive Charter” requested to complete Sidemount Diver specialty from the dive boat in their own BCD.
    Rent gear and prepare rental contracts for customers.
    Distribute and maintain rental equipment, blend nitrox and fill air cylinders as needed.
    Attend all staff meetings and all in-service training programs.


    Other Skills/Attributes
    Self-motivated, professional, courteous and enthusiastic team player
    Have a friendly outgoing personality and be goal oriented
    Possess strong communication and exceptional customer service skills
    Maintain an organized and neat work environment
    Be passionate about your interests and personal growth
    Able to multi-task in a multi-disciplined work environment
    Adhere to training standards as set by PADI, EFR, and DAN
    Follow personal and professional safe diving practices
    Comply with Down Under Dive Shop dress code and code of conduct as described in employee handbook, and Retail Center Staff