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Hydro testing CO2 Cylinders

Question asked by Charles Forsythe on Sep 13, 2017
Latest reply on Oct 19, 2017 by Douglas Hicks

Recently I followed up on fire extinguisher inspection issues with an inspection contractor. During research of NFPA 10, I found the following: 

 

NFPA 10 (2013)
• Chapter 8 Hydrostatic Testing
• 8.1.1 Pressure vessels used as fire extinguishers and specific components of fire extinguishers shall be hydrostatically tested in accordance with this chapter
• 8.1.2 Cylinders and cartridges bearing U.S. Department of Transportation (DOT) or Transport Canada (TC) markings shall be retested in accordance with the applicable DOT or TC regulations.

 

...when you read the applicable DOT standard...

      • CFR TITLE 49 TRANSPORTATION, Part 180 (CONTINUING QUALIFICATION AND MAINTENANCE OF PACKAGINGS), Subpart C (Qualification, Maintenance and Use of Cylinders)
        • §180.205   General requirements for requalification of specification cylinders.
        • (c) Periodic requalification of cylinders. Each cylinder bearing a DOT, CRC, BTC, or CTC specification marking must be requalified and marked as specified in the Requalification Table in this subpart or requalified and marked by a facility registered by Transport Canada in accordance with the Transport Canada TDG Regulations (IBR, see §171.7 of this subchapter). Each cylinder bearing both a TC specification marking and also marked with a corresponding DOT specification marking must be requalified and marked as specified in the Requalification Table in this subpart or requalified and marked by a facility registered by Transport Canada in accordance with the Transport Canada TDG Regulations (IBR, see §171.7 of this subchapter). Each cylinder bearing a DOT special permit number must be requalified and marked in conformance with this section and the terms of the applicable special permit. Each cylinder bearing only a TC mark must be requalified and marked as specified in the Transport Canada TDG Regulations (IBR, see §171.7 of this subchapter), except that registration with Transport Canada is not required and cylinders must be marked with the requalifiers DOT issued requalifier identification number. No cylinder may be filled with a hazardous material and offered for transportation in commerce unless that cylinder has been successfully requalified and marked in accordance with this subpart. A cylinder may be requalified at any time during or before the month and year that the requalification is due. However, a cylinder filled before the requalification becomes due may remain in service until it is emptied. A cylinder with a specified service life may not be refilled and offered for transportation after its authorized service life has expired.

 

  • I interpret this to meaning that you don’t have to hydro-test a CO2 extinguisher unless it has been used and/or emptied and that the hydrotest date, if expired does not mean that it has to be taken out of service and/or tested

 

  • If a CO2 extinguisher has been damaged or discharged, you would then hydrotest if past the 5 year interval

 

Can I please get an opinion on this?

 

Thank you 

 

Chuck Forsythe

cforsythe@transitchicago.com

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