Comment from P-Leasing, Inc.

I am submitting the following comments regarding Application No. 14951-M. As a representative of a company that owns and leases compressed gas tube trailers, I have a direct interest in ensuring these assets can be safely, efficiently, and competitively requalified throughout their service life. While I support technological advancements that improve safety, they should not come at the expense of the long-standing regulatory framework that allows qualified independent requalification facilities to inspect and certify pressure vessels regardless of the original manufacturer. For decades, the Department of Transportation has relied on a nationwide network of authorized independent requalification facilities to perform periodic inspections. This system promotes safety through independent verification while ensuring adequate inspection capacity, competitive pricing, and broad service availability. Historically, DOT has not reserved cylinder recertification exclusively to the original manufacturer. My concern with Application No. 14951-M is that, although it does not explicitly prohibit independent requalification, it could effectively do so. If compliance requires proprietary testing methods, manufacturer-controlled software, restricted calibration data, or equipment available only from Hexagon Lincoln, then only the manufacturer would be able to perform the required inspections. This would create a manufacturer-controlled recertification process for Hexagon products. As an equipment owner, maintaining multiple qualified recertification options is essential. Tube trailers represent significant long-term investments, and owners should not be dependent on a single manufacturer for mandatory inspections. Restricting recertification to one provider could reduce service capacity, increase costs, create scheduling delays, and disrupt operations across the industry. Independent third-party requalification also serves an important safety function. It provides an objective assessment of whether a cylinder remains fit for service without any commercial interest in the outcome. Preserving this independent oversight helps maintain public confidence in the safety of the nation's compressed gas transportation system. Approving Application No. 14951-M without appropriate safeguards could establish a precedent allowing manufacturers to implement proprietary recertification systems that only they can perform. If adopted more broadly, this would significantly diminish the role of independent authorized requalification facilities and represent a fundamental departure from the principles that have historically governed DOT cylinder requalification. For these reasons, I respectfully request that PHMSA ensure any approval of Application No. 14951-M preserves the ability of qualified independent requalification facilities to inspect and recertify these cylinders. Any testing methods, software, calibration information, or specialized equipment required to perform these inspections should be made available to all authorized requalification facilities under reasonable and non-discriminatory terms. PHMSA can achieve the application's safety objectives without creating a manufacturer-exclusive recertification system. Thank you for your consideration.