Comment from Antech Systems, Inc

Please accept these comments regarding Application Number 14951-M, which proposes a new conversion rate and updated testing requirements under 49 CFR §§ 173.301(f) and 173.302(a). While we support technical progress, PHMSA must ensure that these modifications do not create an anti-competitive monopoly on cylinder maintenance, inspection, and requalification. If the updated testing requirements rely on closed, proprietary protocols or manufacturer-specific equipment, they will effectively block independent third-party requalifiers from servicing these cylinders. To prevent a severe restriction on third-party service providers, we request that PHMSA enforce the following conditions before approval: •Prevent Manufacturer Lock-In: The approved testing protocols must use objective, performance-based standards. They must not mandate proprietary software, closed data access, or specialized manufacturer-locked hardware that prevents independent facilities from competing. •Guarantee Equal Access to Parameters: All critical testing and calibration parameters required by this modification must be made transparently and commercially accessible to any authorized requalification facility, not just OEM-affiliates. •Maintain Verifiable Industry Standards: The new conversion rate and testing methodologies must remain fully verifiable using standard, industry-accepted non-destructive testing (NDT) practices. Restricting high-pressure cylinder requalification to the OEM creates severe operational bottlenecks, hikes logistics costs, and disrupts the supply chain. Protecting the right of independent third parties to service these cylinders is vital to maintaining broad, resilient, and safe industry capacity. Thank you for your consideration.