Permits; Applications, Issuances, etc.: Hazardous Materials

Odyssey Design and Manufacturing, Inc., an engineering and manufacturing company, supports the proposed conversion rate and testing requirements provided they are based on objective performance standards rather than proprietary technology. They argue that the requirements should ensure that independent requalification facilities can perform the inspections to maintain industry capacity and prevent costs from increasing due to restricted service networks.

Mark Griffin expresses support for safety improvements but requests that the proposed testing requirements do not create a monopoly for original equipment manufacturers. He argues that the requirements should be performance-based and accessible to independent requalification facilities to ensure competition and supply chain resilience.

A representative of a company that owns and leases compressed gas tube trailers opposes the proposed action because it could effectively restrict recertification to the original manufacturer. The commenter argues that preserving a nationwide network of independent requalification facilities is essential for maintaining competition, reducing costs, and ensuring objective safety oversight.

The commenter expresses support for the technical progress of the proposed conversion rate and testing requirements, provided they do not create a monopoly for manufacturers. They argue that the PHMSA must ensure the new standards use objective, performance-based protocols that allow independent third-party facilities to compete and maintain supply chain resilience.