{"operation":"document","citation":"PHMSA Guidance, Safety Advisory Notice: Special Permits for Composite Gas Cylinders","title":"Safety Advisory Notice: Special Permits for Composite Gas Cylinders","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2021-01-12","effective_on":"2021-01-12","summary":"Safety Advisory Notice: Special Permits for Composite Gas Cylinders Document CNG Special Permit Safety Advisory.pdf (237.21 KB) The Safety Advisory Notice provides recommendations to help facilitate the safe transportation of compressed natural gas under the terms of specific Hazardous Materials Special Permits authorizing the manufacture, mark, sale, and use of non-DOT specification fully wrapped reinforced composit","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-guidance-safety-advisory-notice-special-permits-composite-gas-cylinders-1e63f016.json","markdown":"https://regulus.evalyn.ai/document/phmsa-guidance-safety-advisory-notice-special-permits-composite-gas-cylinders-1e63f016.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-guidance-safety-advisory-notice-special-permits-composite-gas-cylinders-1e63f016","source_url":"https://www.phmsa.dot.gov/news/safety-advisory-notice-special-permits-composite-gas-cylinders","body":"Safety Advisory Notice: Special Permits for Composite Gas Cylinders\n\nDocument\n\n CNG Special Permit Safety Advisory.pdf (237.21 KB)\n\n        The Safety Advisory Notice provides recommendations to help facilitate the safe transportation of compressed natural gas under the terms of specific Hazardous Materials Special Permits authorizing the manufacture, mark, sale, and use of non-DOT specification fully wrapped reinforced composite cylinders. See the Safety Advisory Notice for more details.\n\n          Issued Date: Tuesday, January 12, 2021\n\n<<<PAGE 1>>>\n\nU.S.\nDepartment of\nTransportation\nPipeline and\nHazardous Materials\nSafety\nAdministration\n1200 New Jersey Avenue,\nSE Washington, DC 2059\nSafety Advisory Notice1\n– Special Permits DOT-SP 14951, DOT-SP-16524,\nDOT-SP 16346, DOT-SP 20418, DOT-SP 20425, and DOT-SP 16560\nSummary\nOn March 3, 2020, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\nconducted an Investigative Hearing (Hearing) in response to incidents and roll-over crashes\nassociated with operations using packagings authorized under special permits DOT-SP 14951\nand DOT-SP-16524. These special permits authorize the manufacture, mark, sale and use of non-\nDOT specification fully wrapped fiber reinforced composite gas cylinders (COPV). These\nCOPVs are used for transportation of compressed natural gas (CNG) and other hazardous\nmaterials. Special permits DOT-SP 16346, DOT-SP 20418, DOT-SP 20425, and DOT-SP 16560\nauthorize similar relief and share similar concerns.\nBased on the information presented at the Hearing and the subsequent evaluation, PHMSA\npublishes the recommendations outlined below to provide additional options to facilitate the safe\ntransportation of CNG under the terms of these special permits. We have concluded:\n• The design of the COPVs which contained the CNG performed in a manner which met or\nexceeded the design qualification and testing requirements of the special permits.\n• The frame designs which are used to hold the cylinders met or exceeded the design\nrequirements of the special permit. In the one instance where a crash resulted in\nseparation of the COPVs from the frame assembly, it was calculated the impact loading\nwas 3.75 times higher than the loading required under the special permits.\n• The trailers have a high center of gravity which results in handling characteristics that\nlead to a higher rollover crash rate when compared to most commonly transported\ntrailers.\n• Specialized training can inform the drivers about the operational characteristics of these\ntrailers and how to appropriately respond in certain situations.\n• A common factor in all crashes was driver error.\n1 This document contains guidance provided to help the regulated community understand how to comply with\nregulations, but its contents are not substantive rules themselves and do not create legally enforceable rights, assign\nduties, or impose new obligations not otherwise contained in the existing regulations and standards. However, an\noperator who is able to demonstrate compliance with the content of this document is likely to be able to demonstrate\ncompliance with the relevant regulations. If a different course of action is taken by a regulated entity, that entity\nmust be able to demonstrate that its conduct is in accordance with the regulations.\n\n<<<PAGE 2>>>\n\nBackground\nThe Hearing took place on March 3, 2020 at the Department of Transportation’s Headquarters in\nWashington, DC. In addition to PHMSA, FMCSA, and NHTSA, several major operators as well\nas other stakeholders attended the hearing. The hearing focused on the high center of gravity of\nthe systems and trailers manufactured under the previously mentioned special permits. The\nvehicles using cylinders manufactured under these special permits are configured as a series of\nlarge cylinders mounted within a framework positioned either perpendicular or horizontal to the\nground. Both configurations possess high centers of gravity which lead to a heightened/greater\npossibility of rollover. The greater likelihood for rollover, combined with the nature of CNG, the\nmaterial most commonly transported, magnifies the safety risk inherent to operations conducted\nusing these vehicles. As a result of this hearing, government, motor carriers, offerors and\nmanufacturers of these units verbally agreed to work together to enhance existing practices to\nminimize the risk(s) of rollovers.\nIn 2005, the Federal Motor Carrier Safety Administration (FMCSA) commissioned a study to\naddress the rollover concerns experienced by the hazardous materials cargo tank industry. That\nstudy helped FMCSA identify a series of factors that will result in a reduction of rollovers.\nResults of the 2005 FMCSA study, as well as information gathered at the March 2020 hearing,\nindicated that a combination of Driver Training, Electronic Stability Aids, Vehicle Design and\nthe understanding of Highway Design are all contributing factors to consider in preventing\nrollovers.\nFMCSA further concluded that the most contributable factors that minimized rollovers were\nDriver Training and the use of Electronic Stability Aids. Some of the findings of the study\nconcluded that:\n• “Drivers need to realize the diverse situations that can lead to rollover so they can\nexercise proper care to prevent those situations from developing.\n• Drivers and carriers alike must understand both the benefits and the limits of electronic\nstability aids.\n• And carriers and manufacturers should appreciate the stability improvements to be\ngained from even a small reduction in the height of a cargo tank vehicle.”\nThe current rollover issues associated with the vehicle manufactured under the specified special\npermits are no different than those addressed in the 2005 study. The main difference is vehicle\nconfiguration, however, the concept to address remains the same. Therefore, we are issuing the\nfollowing recommendations to provide additional guidance and awareness of the actions to take\nto minimize the risk and impact of rollover issues.\nOptions for Enhanced Safety\nDue to the design of the commercial motor vehicles (CMV) manufactured with cylinders\nauthorized under the terms of the specified special permits, in addition to baseline requirements,\nwe offer the following suggestions for optional safety enhancements for entities offering CNG to\n\n<<<PAGE 3>>>\n\nmotor carriers and motor carriers operating vehicles manufactured with cylinders authorized\nunder the specified special permits:\n• Under existing requirements, all CMV carriers transporting CNG trailers routinely verify\ntheir CMV drivers are trained in the handling characteristics and operation of these\nvehicle types as required by § 177.817. We encourage CMV drivers to understand the\ndynamics of the CNG trailers they are transporting and that center of gravity, load and\nroad characteristics all contribute to potential rollover;\n• We suggest that all carriers consider using CMVs equipped with electronic roll stability\nin accordance with Federal Motor Vehicle Safety Standard (FMVSS) No. 136, Electronic\nStability Control Systems for Heavy Vehicles;\n• We suggest that all carriers consider using CMVs equipped with appropriate electronic\nmonitoring systems to record vehicle and driver actions in the event of crash or another\nunexpected event. This information can be used to enhance training for drivers of these\nvehicles;\n• We encourage all CMV drivers to consider following designated routes to ensure\nfamiliarity with the characteristics of the roads on which they are driving; and\n• We urge all CMV carriers to consider, in conjunction with the specialized training for\ndrivers of these CNG vehicle configurations, using the FMCSA Cargo Tank Truck\nRollover Prevention Video to train drivers for rollover prevention. This can be found at:\nhttps://www.fmcsa.dot.gov/rolloverprevention\nBy implementing these optional measures, operators may yield additional safety benefits when\ntransporting CNG in motor vehicles containing cylinders authorized under the terms of these\nspecial permits.\nIssued in Washington, DC, January 12, 2021.\nWilliam S. Schoonover,\nAssociate Administrator\nfor Hazardous Materials Safety","truncated":false,"body_characters":8177}