What Records Does a Propane Cylinder RIN Holder Have to Keep?

A RIN holder needs both facility papers and daily cylinder test records. Keep daily records until the test period ends or the next requalification, whichever comes first. Under 49 CFR 180.215(c), records of welding or brazing repairs, rebuilding or reheat treatment stay at least fifteen years. Do not give every file the same disposal date.

By Bill Stomp · Last updated:

Which papers stay at the test location?

49 CFR 180.215(a) lists the facility papers. These include the current RIN letter and a pending renewal request when needed. It also lists required §107.805 notices, applicable rules, special permits and CGA or ASTM information. RIN is the DOT requalifier identification number.

What goes on the daily sheet?

Paragraph (b) lists the fields for each test method. They cover the cylinder’s identity, test results, what happened to it and who did the work. They also cover calibration records. That means records showing the test gear was checked. Failed and repeated tests need records too.

Read the full list with the person who runs the test station. A serial number and a “passed” box do not cover it. Check that person’s form against each field that applies.

How would I sort the records?

Keep the facility papers in one folder and daily sheets in another. Label both by test location. Give one person the job of checking that a finished test can be found. Those are filing suggestions, not new federal rules.

Questions and answers

Does this apply to a shop that only fills cylinders?

This answer covers the requalifier’s records. A fill-only shop should check which rules apply to its own work. Filling and requalification are different jobs.

Can the next test replace every old record?

No. The daily-record rule has its own clock. Welding or brazing repair, rebuilding and reheat-treatment records have the separate fifteen-year minimum. Check the record type first.

Next step

Compare a completed daily sheet with the rule’s full field list. Our cylinder requalification page explains the service scope.

Related: cargo-tank test dates, a different program. Return to the manuals and records questions.

General information, not legal advice. Check what applies with the responsible regulator and a qualified safety or legal reviewer. This page does not replace training or the procedures for your equipment.