<font color="blue"> You wouldn't happen to have a reference to the welder-exemption would you?
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Sure. Here it is from the horse's mouth.
NFPA -- Read the last sentence on the page. There is one change in what I told you, which is the reference to the tank being labeled for the specific use. At the time all this started happening, there was no reference to how such use was to be authenticated, and I came up with the letterhead deal. I cleared it with my state inspector at the time - as long as I had the letter on file, I couldn't be punished for filling the tank. It wasn't up to me to determine the authenticity of the letter.
Now, however, they have apparently determined that a label is the ticket. My copy of the NFPA 58 is packed away until my barn is built. Maybe someone out there has a copy and can check to see if there are any specific requirements for the label. Everyone in the business knows what a fork lift tank looks like (the "industrial truck" tank mentioned in the article), but a welding cylinder looks just like any other cylinder.
I just found another link to an OPD fact sheet on the NFPA site. Here's a link:
OPD Fact Sheet What's interesting is that in discussing the exemption for horizontal cylinders, it's stated that they must have a label stating that the cylinder does not have an OPD, and that "anyone can make the label". The next paragraph states that welding cyliders must also be labeled, but does not specify who can make the label. I leave it up to you to make the interpretation, but, in the absence of any specific rule about the label, and with the "hint" in the preceding paragraph, I would judge that anyone could make the "Welding Gas" label, also. It seems clear that the purpose of the label is to warn the dispenser operator that there is no OPD valve and they should take the extra care necessary to fill the cylinder. They know how; all of the cylinders above 40# are exempt.
I would print up a label on the computer with fairly large font that says something like, "WARNING! THIS CYLINDER IS USED FOR INDUSTRIAL WELDING/CUTTING AND DOES NOT HAVE AN OVERFILL PREVENTION DEVICE (OPD). UNDER NFPA 58, THIS CYLINDER IS EXEMPT FROM THE OPD PROVISIONS." Then, tape it to the cylinder with clear sealing tape. Take a little time to center the wording and make it look official; that will make it easier if an operator is skeptical. Print out the fact sheet from the OPD site, and if that doesn't work, challenge them to get their copy of NFPA 58 - they have to have one.
They still have to be recertified after the first 12 years and every 5 years thereafter (if it was a visual certification), but as long as your cylinder does not leak, shows no evidence of having been in a fire, has no dents, has no rust pits deeper than surface rust (there is a standard), is painted in a light color, and still has the top and bottom collars, it will pass.