NFPA 58-2020 Edition

Liquefied Petroleum Gas Code

TIA Log No.: 1483
Reference: 7.2.2.2, 7.2.2.7, 7.2.3.9(3) and A.7.2.2.7
Comment Closing Date: March 12, 2020
Submitter: Jean McDowell, McDowell Owens Engineering, Inc.
www.nfpa.org/58

1. Revise 7.2.2.2 to read as follows:

7.2.2.2 When noncompliance with Section 5.2 or Section 5.9 is found or it is determined in
accordance with 7.2.2.7 that the container will not be filled, the container owner and user
shall be notified in writing.

2. Delete 7.2.2.7 and renumber subsequent sections accordingly as shown below:

7.2.2.7* Defects.
(A) Prior to filling cylinders with CGA 791 and CGA 793 connections, the face seal shall be
examined for defects.
(B) If a defect on the face seal is found, the cylinder shall not be filled.
7.2.2.87 …
7.2.2.98 …
7.2.2.109 …
7.2.2.1110 …
7.2.2.1211 The requirements of 7.2.2.109 shall not apply to containers that comply with 5.2.9
and are included in the flight log of a hot air balloon.
7.2.2.1312 ….
7.2.2.1413 …
7.2.2.1514 …
7.2.2.1615 …
7.2.2.1716 …
7.2.2.1817 …
7.2.2.1918 …

3. Revise the cross reference in 7.2.3.9(3) to read as follows:

7.2.3.9 Where cargo tank vehicles are filled from other cargo tank vehicles or cargo tanks,
the following requirements shall apply:
…
(3) Cargo tanks shall comply with the requirements of 7.2.2.98.
…

4. Delete A.7.2.2.7 and the associated Figure A.7.2.2.7 as shown below:

A.7.2.2.7 CGA 791 and 793 connections are primarily used on consumer LP-Gas equipment.
Both connection designs employ the use of a face seal to seal the male and female sides of the
connection before gas flow occurs. Damage to the face seal (e.g., cracking, gouging, tearing,
roping) affects the sealing surfaces and could result in a leak. Examples of cracking,
gouging/tearing, roping, and filling double seal are shown in Figure A.7.2.2.7.

The CGA 791 and 793 connections as manufactured do not permit the replacement of the face
seal, and the face seal design is not the same for all manufacturers. Therefore, if the face seal
has been compromised, the cylinder should not be filled.
Substantiation: This new NFPA Standard, 7.2.2.7(A)(B), has the intent of substantially
reducing the potential for incidents due to a damaged face seal in CGA 791 and CGA 793
connections. The wording is asking the inspecting party to be able to analyze imperfections or
abnormalities that impairs quality, function, or utility, by definition, which can be interpreted
to include proper material composition as well as assembly and design which are not visible.
Yet the inspecting party is expected to identity a “defect”. This new NFPA Standard is vague
and not enforceable and therefore in conflict with intent and purpose. Annex A, Figures
A.7.2.2.7 “Examples of Defects” are clearly and are described in A.7.2.2.7 text as “Damage”.
Therefore, 7.2.2.7 should be deleted, and a Task Group established to review proper
procedures and methodology for the inspection to take place that fulfills the intent of the
standard and identifies “Damage” rather than “Defect” which may be included in “Damage”.
The examining party should not be tasked with affirming as stated in NFPA 58, 3.3.19, “that
the product design complies with specific requirements”.

Emergency Nature: The standard contains an error or an omission that was overlooked
during the regular revision process. The NFPA Standard contains a conflict within the NFPA
Standards or within another NFPA Standard. The proposed TIA intends to offer to the public
a benefit that would lessen a recognized (known) hazard or ameliorate a continuing dangerous
condition or situation.

The new standard 7.2.2.7 is vague as to determination of “Defects” which may constitute the
identification of imperfections or abnormalities that impairs quality, function, or utility, by
definition, which can be interpreted to include proper material composition as well as
assembly and design which are not visible. If 7.2.2.7(A) is impossible to fulfill it is likewise
impossible to enforce. The intent of 7.2.2.7 is paramount in the prevention of accidents but
must be properly defined and stated. It should be removed and a Task Group formed to
establish proper procedure and methodology.

Anyone may submit a comment by the closing date indicated above. Please identify the TIA
number and forward to the Secretary, Standards Council. SUBMIT A COMMENT