Compressed Gas Association 2006 Accomplishments

The following accomplishments represent a small fraction of the overall effort and by CGA staff and members to ensure the continued success of the Association in the U.S. and Canada. Not listed are the countless meetings, contacts, and advocacy that occur each day to support programs that are important to our members. Association Development and Management CGA has developed a course of action that will raise the Association to a new level of service to its members and mission. The Executive Committee’s Revenue Task Force (RTF) working with CGA staff has:

Conducted a comprehensive survey of the membership on existing and new products and services including the annual meeting. Staff has analyzed the survey and has recommended changes to member communications and the annual meeting.

Benchmarked CGA’s operations against other associations. CGA staff has analyzed the

Association’s revenue and expenses and compared that to other similar associations. The RTF found that CGA to be on par with others where data are comparable.

Developed recommendations regarding changes to the dues structure to enhance

membership recruitment and retention. The Executive Committee and Board supported staff recommendations on changes to the dues structure and acted at its September 21 meeting. CGA is now implementing the new structure which will phase in over three years.

Recommended evaluation of significant new programs. The RTF recommended that

personnel and equipment certification be evaluated for feasibility in 2007. The Board of Directors approved funding for feasibility analyses (as necessary and approved by the Executive Committee) of these potential programs which will be conducted in 2007.

Recommended a strategic planning effort that will guide CGA’s future activities.

Working with CGA staff, the RTF has recommended that the Executive Committee expand the Task Force’s roll to include overall strategic analysis and planning.

Standards Development

Maintained leadership role in standards development. In continuing its mission of industry safety, CGA published 12 new documents including 9 new standards, 2 safety bulletins, one technical bulletin and an amendment to standard V-1. In addition, 16 documents were revised and 7 were reaffirmed (see attachment for details). With these additions, CGA now has 256 documents in publication.

Improved efficiencies in work process. Committees implemented the new Work Process

2006 which reduces the number of meetings members need to attend to update standards. It also reduces the overall duration of the review process and allows CGA to communicate exactly when decisions will be made on proposed changes. This allows all members to schedule participation in the standards development process for standards which are important to them, rather than having to attend multiple meetings over an 18-month period.

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Gained ANSI approval of silane standard. CGA G-13 (Storage and Handling of Silane and Silane Mixtures) was approved as an American National Standard, after many years of development. CGA has requested that the International Code Council (ICC) adopt G-13 into the International Fire Code. As a result of this effort, CGA is now establishing administrative procedures, including third party involvement that will expedite future approval of CGA standards by ANSI.

International Harmonization and Related Activity1

Committees make harmonization a priority. At Standards Council direction, all CGA

committees reviewed their standards and have prioritized them for consideration for harmonization through CGA’s participation in the International Harmonization Council (IHC).

Harmonized standards. In 2006, CGA worked with industrial gas associations on the IHC

to continue the harmonization process on 15 standards. CGA published six new harmonized standards in 2006.

CGA proposal approved by the United Nations. CGA's proposal to decrease the filling

ratio for tungsten hexafluoride and dichlorosilane, as well as to decrease the maximum working pressure for nitric oxide in P200 of the UN Model Regulations on the Transport of Dangerous Goods was approved by the UN Sub-Committee of Experts on the Transport of Dangerous Goods. This amendment will be included in the upcoming 15th edition of the UN Model Regulations.

Industry through ISO/TC 58/SC 4 challenged revision of ISO 32:1977 (Gas cylinders for

medical use—marking for identification of content). With the help of CGA members, ANSI and CGA, the U.S. Technical Advisory Group for ISO/TC 58/SC 4 successfully challenged the approved final draft international standard, which would have included industrial gases and could have presented economic barriers to international trade.

Government Relations/Regulatory Response Department of Transportation (DOT)

Improved the Hazardous Materials Regulations (HMR). The DOT recently amended the HMR to adopt standards for the design, construction, maintenance, and use of cylinders and multiple-element gas containers based on the standards contained in the United Nations

1 In addition the specific accomplishments listed in this section, CGA maintains a leadership role for the gas cylinder industry in the International Standards Organization (ISO) by serving as the ANSI-accredited, U.S. Technical Advisory Group Administrator for six technical subcommittees--TC 58 and its three subcommittees; TC 220, Cryogenic Vessels; and TC 197, Hydrogen Technologies. In all cases but one, CGA members are U.S. TAG chairmen. In addition, CGA serves as Secretariat for TC 58/SC 4 Gas Cylinder Operational Requirements.

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Recommendations on the Transport of Dangerous Goods. CGA organized and advocated for an industry position relative to the development of the amended regulations.

PHMSA Administrator to speak at CGA Annual Meeting. CGA has arranged for the new

DOT Pipeline and Hazardous Materials Safety Administration (PHMSA), Administrator (Admiral) Thomas Barrett to be the keynote speaker at the 2007 CGA Annual Meeting.

Food and Drug Administration (FDA)

Reversed ambiguous FDA and NIOSH safety notification. FDA and the National Institute for Occupational Safety and Health (NIOSH) issued a safety notification that indicated plastic seals should be avoided because of a potential fire hazard and if used, used only once. CGA and Gases and Welding Distributors Association (GAWDA) representatives met with FDA and NIOSH medical device senior officials to request that the notification be reissued. As a result of the meeting, FDA and NIOSH issued a new notification that helped resolve the ambiguity.

Organized a joint industry response to a major proposed rule. In April 2006, FDA

proposed a major new rule that would change requirements for medical cylinders including labeling, color coding, and connections. The proposal would also prohibit containers that were ever in industrial service from being used in medical service. The latter provision is of particular concern as it would not only increase the number of assets needed, but in order to prove that a container has never been in industrial service all containers would need permanent markings and potentially require tracking container pedigree. CGA and GAWDA have worked together to develop a joint industry response to the proposed rule.

CGA raises concerns with National Drug Code proposal. CGA testified at an FDA public

meeting to voice concerns with proposed changes to the National Drug Code as they would apply to medical gases.

United States Pharmacopeia (USP)

Advocated the industry’s position on USP monographs. CGA’s Medical Gas Regulatory

Policy Committee (MGRP) successfully advocated that USP’s Aerosols Expert Committee reissue its Medical Gas Monographs taking into consideration the industry’s concerns.

Worked with USP on reference standards. Although there is more work to be done to have

USP address a number of our concerns regarding reference standards, USP did agree that they will provide COA-type data with each reference standard.

Department of Homeland Security (DHS)

Worked directly with policy makers on chemical security. CGA has provided input to the DHS on the development of the Nation’s National Infrastructure Protection Plan and its Chemical Security Plan. CGA is a member of a joint DHS and industry committee that works with senior administration officials regarding security concerns.

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Developed a strategic approach to security regulations. The Executive Committee approved a recommendation that CGA improve its security standards so that they would satisfy DHS regulatory requirements should Congress provide the Department that authority. Congress acted in October and CGA is now working to finalize its standards in time for consideration by DHS as part of its rulemaking effort.

Chemical Safety Board (CSB)

Responded to CSB request on CGA standards. CGA has received a request from the CSB requesting that CGA address several recommendations regarding an incident that occurred at a cylinder filling facility in St. Louis in June 2005. The recommendations include some that related to CGA standards. CGA has formed a special task force to develop a response to the CSB.

Responded to CSB request for safety alert. CSB has also requested CGA’s assistance

relative to a confined space asphyxiation incident at a Delaware refinery that occurred in 2005. CGA is responding to the request.

CGA Canada

Improved Canadian Transportation Regulations. CGA's proposal to revise provisions for salvage containers in CSA B340 was approved by the CSA B339/B340 Technical Committee and will be included in the next edition of CSA B340. CSA B339 and B340 are adopted by reference in the Canadian Transportation of Dangerous Goods Regulations.

Inspection activity addressed. At the request of and in cooperation with the Canadian

Pressure Vessels and Piping Systems Committee, the Bulk Distribution Equipment and Standards Committee published PS-28, CGA Position Statement on the Use of Non-ASME Certified Pressure Relief Valves Used for Thermal Expansion Relief in Piping Systems, in response to provincial inspection activity related to thermal relief valves.

Educated Health Canada on medical gases. CGA provided a presentation on the medical

gas industry to Health Canada's Health Products and Food Branch Inspectorate (HPFBI) at their All-Staff Meeting.

Responded to proposed changes to medical gas practices. CGA submitted comments to

Health Canada regarding their draft revised guidance document, Good Manufacturing Practices for Medical Gases. At a bi-lateral meeting later held with Health Canada, CGA’s input was considered and will lead to significant changes in the final published document.

CGA 2006 Accomplishments Page 5 of 6   Detail on CGA Publications Actions in 2006 New

• H-3, Cryogenic Hydrogen Storage, First Edition • H-4, Terminology Associated with Hydrogen Fuel Technologies, First Edition • M-8, Guideline for the Manufacturer of Calibration Gas Standards Used to Analyze Medical

Gases, First Edition • P-8.5, The Impact of Ambient Air Contaminants on Validation Requirements for the Air

Separation Process, First Edition • P-8.6, Unmanned Air Gas Plants—Design and Operation (EIGA Doc 132/05), First Edition • P-56, Cryogenic Vaporization Systems—Prevention of Brittle Fracture of Equipment and Piping

(EIGA Doc 133/05), First Edition • PS-20, Direct Burial of Gaseous Hydrogen Storage Tanks, First Edition • PS-27, Use of Excess Flow Control, First Edition • PS-28, Use of Non-ASME Certified Pressure Relief Valves Used for Thermal Expansion Relief in

Piping Systems, First edition • SB-35, Guidelines for Employee Safety at Customer Locations, First Edition • SB-37, Nitrous Oxide Decomposition, First Edition • TB-22, Guidelines for the Inspection, Maintenance, and Requalification of Liquefied Petroleum

Gas Cylinders, First Edition • V-1 Amendment 1, Standard for Compressed Gas Cylinder Valve Outlet and Inlet

Connections-Amendment 1 • P-53, Security Code Top Screen (pending publication of P-50)

Revised

• E-6, Standard for Hydraulic Type Pipeline Protective Devices as Required by NFPA 51, Fourth Edition

• E-7, • G-13, Storage and Handling of Silane and Silane Mixtures (Formerly P-32), Second Edition • P-1, Safe Handling of Compressed Gases in Containers, Tenth Edition • P-16, Recommended Procedures for Nitrogen Purging of Tank Cars, Second Edition • P-18, Standard for Bulk Inert Gas Systems, Third Edition • P-21, Guidelines for the Development of Pre-trip Inspection Checklist and Reports for MC-338,

TC-338,TC-341, and CGA-341 Cargo Tanks, Third Edition • P-24, Guide to the Preparation of Material Safety Data Sheets, Second Edition • P-8.4, Safe Operation of Reboilers/Condensers in Air Separation Units (EIGA Doc 65/99),

Second Edition • PS-1, Odorizing Atmospheric Gases (Oxygen, Nitrogen, and Argon), Fourth Edition • SA-13, Safety Alert, Tube Trailer Rupture Disk-Elbow "Expulsion", Second Edition • SB-20, General Information on Quick-Connecting Couplings for Compressed Gas Service,

Second Edition • SB-27, Safe Use and Handling of Small Cylinders, Second Edition • SB-29, Prevention of Injury and Loss from Carbon Dioxide Delivery to Small Customer Sites,

Second Edition

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• TB-9, Guidelines for the Proper Handling and Use of the CGA 630/710 Series "Ultra High Integrity Service" Connections, Third Edition

• V-10, High Pressure Gas Trailer Connections, Third Edition • G-1.2, Acetylene Metering and Pipe Transmission (pending external copyright approval) • P-50, Site Security Guidelines, Second Edition (pending external copyright approval)

Reaffirmed

• SA-11, Safety Alert, Potential for Hidden Cryogenic Liquid Cylinder Contamination, First Edition

• SA-14, Safety Alert, Hazards of Compressed Gas Cylinders in the Magnetic Resonance Imaging (MRI) Environment, First Edition

• SA-15, Safety Alert, Gas Mixtures Containing Flammable and Oxidizing Components, First Edition

• SA-2, Safety Alert, Acetylene, Second Edition • SA-6, Safety Alert, Use of Nitrogen NF for Surgical Air Tools, First Edition • TB-19, Uses of Eddy Current to Detect Imperfections in Refillable High Pressure Vessels, First

Edition • V-6, Standard Cryogenic Liquid Transfer Connections, Fourth Edition

ISO

• ISO-5145-AMD1, Cylinder valve outlets for gases and gas mixtures—Selection and dimensioning - AMENDMENT 1: Cylinder valve outlets for gases for medical use, First Edition

• ISO-10297, Transportable gas cylinders-Cylinder valves-Specification and type testing, Second Edition

• ISO-10461-AMD1, Gas cylinders—Seamless aluminum alloy gas cylinders—Periodic inspection and testing-AMENDMENT 1, First Edition

• ISO-14245, Gas cylinders—Specifications and testing of LPG cylinder valves—Self-closing, First Edition

• ISO-15995, Gas cylinders—Specifications and testing of LPG cylinder valves—Manually operated, First Edition

• ISO-16148, Gas cylinders—Refillable seamless steel gas cylinders—Acoustic emission testing (AT) for periodic inspection, First Edition

• ISO-17268, Compressed hydrogen surface vehicle refueling connection devices, First Edition • ISO-20421-1, Cryogenic vessels—Large transportable vacuum-insulated vessels—Part 1:

Design, fabrication, inspection and testing, First Edition • ISO-20703, Gas cylinders—Refillable welded aluminum-alloy cylinders—Design, construction

and testing, First Edition • ISO-21013-3, Cryogenic vessels—Pressure-relief accessories for cryogenic service—Part 3:Sizing

and capacity determination, First Edition • ISO-21014, Cryogenic vessels—Cryogenic insulation performance, First Edition