Comment from Odyssey Design and Manufacturing, Inc.

Odyssey Design and Manufacturing, Inc. appreciates the opportunity to provide comments regarding Application No. 14951-M concerning the proposed conversion rate and revised testing requirements under 49 CFR §§ 173.301(f) and 173.302(a). Odyssey is an engineering and manufacturing company with extensive experience in the design, inspection, testing, repair, and regulatory compliance of pressure vessels and compressed gas equipment. Our comments are based on practical experience implementing inspection and requalification requirements within the hazardous materials transportation industry. Odyssey supports advancements that improve safety and the integrity of pressure vessels. At the same time, any approval of this application should ensure that the proposed testing methodology can be implemented by qualified requalification facilities throughout the industry and does not unintentionally limit inspection and maintenance activities to the original manufacturer or a small number of affiliated service providers. As PHMSA evaluates this application, Odyssey respectfully requests consideration of the following principles: **Performance-Based Requirements** Any approved testing methodology should establish objective performance requirements rather than rely on manufacturer-specific equipment, proprietary software, or closed systems. Qualified requalification facilities should be able to demonstrate compliance using technically equivalent equipment and procedures that achieve the required level of safety and accuracy. **Availability of Technical Information** Any inspection parameters, calibration requirements, acceptance criteria, or other technical information necessary to perform the required examinations should be reasonably available to all authorized requalification facilities. Equal access to this information is essential to maintaining a qualified and technically competent inspection network. **Compatibility with Established Inspection Practices** The proposed testing methodology should remain compatible with recognized non-destructive examination (NDE/NDT) methods and equipment that are commonly used throughout the cylinder requalification industry. Compliance should be based on meeting established technical performance requirements rather than exclusive access to proprietary technology. **Maintaining Industry Service Capacity** The ability of qualified independent requalification facilities to inspect and requalify pressure vessels is an important component of the hazardous materials transportation system. Restricting these activities to a single source or limited network of service providers could reduce available inspection capacity, increase transportation costs, extend equipment downtime, and create unnecessary burdens for cylinder owners and operators without a corresponding improvement in safety. Odyssey respectfully requests that any approval of Application No. 14951-M preserve the ability of qualified independent requalification facilities to perform the required inspections through open, performance-based technical requirements. This approach will maintain PHMSA's safety objectives while supporting a resilient national inspection infrastructure and continued regulatory compliance. Thank you for the opportunity to provide these comments.