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.
CGA 2006 Accomplishments Page 2 of 6 ; 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.
CGA 2006 Accomplishments Page 3 of 6 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.
CGA 2006 Accomplishments Page 4 of 6 ; 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
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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
CGA 2006 Accomplishments Page 6 of 6 •
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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
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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