Propane Tank OPD Exemption - Wanderlodge Owners Group

The above NO OPD sticker is available at;
http://www.pbase.com/image/75453477
What follows is a draft of an email and the reply to it, that I had sent to the National Fire Protection Association
(NFPA), concerning the problems that some Bluebird Wanderlodge owners including myself have encountered in
getting the propane tanks installed on our Bluebird Wanderlodge filled at some Propane filling stations
throughout the country.
I have also included in this file some excerpts and URL links from different web sites that concern this topic. I am
also in the process of having a sticker similar to the one above made, that can be placed in such a manner on
these tanks, so that the Propane filling station attendant can see that this code does not apply to the tank.
The spelling in Mr. Lemoff’s reply to my email enquiry, is his own. I have not edified the content other than to
highlight the text that refers to the Propane tanks installed on our Bluebird Wanderlodges.
Dear Mr. Finn,
This is in response to your question on NFPA 58, regarding filling of RV propoane fuel containers. The OPD exemption you
refer to applies to cylinders, and not permanenty installed engine fue and mobile containers. I refer you to Chapter 11, Engine
Fuel Systems. Paragraph 11.4.1.13 states: 11.4.1.13 Containers fabricated after January 1, 1984, for use as engine fuel
containers on vehicles shall be equipped or fitted with an overfilling prevention device.
11.4.1.14 Where an overfilling prevention device is installed on the container or exterior of the compartment and remote filling
is used, a double backflow check valve shall be installed in the container fill valve opening.
11.4.1.15 Where an overfilling prevention device is installed on an engine fuel container, venting of gas through a fixed
maximum liquid level gauge during normal filling shall not be required.
Any RV with a permanently installed propoane continer manufactured in 1984 or later will have an OPD installed, and can be
filled. Permanently installed continers manufactured before1984 are not required to have an OPD. To summarize, the OPD
requirements that have been publicised are for Cylinders only, and not for permanetly installed RV containers.
This correspondence is not a Formal Interpretation issued pursuant to NFPA Regulations. Any opinion expressed is the
personal opinion of the author, and does not necessarily represent the official position of the NFPA or its Technical
Committees. In addition, this correspondence is neither intended, nor should be relied upon, to provide professional
consultation services.
Very truly yours,
Theodore C. Lemoff
Staff Liaison
From: Maynard, Mary
Sent: Mon 3/5/2007 8:27 AM
To: NFPA58@nfpa.org
Subject: FW: RV PROPANE TANK CODES

From: IAMFLAGMAN@aol.com [mailto:IAMFLAGMAN@aol.com]
Sent: Sunday, March 04, 2007 9:44 PM
To: Maynard, Mary
Subject: RV PROPANE TANK CODES
My name is John Finn and I'm a moderator on an Internet forum for the Bluebird Wanderlodge Motorcoach
owners at; http://autos.groups.yahoo.com/group/wanderlodge/
One of the questions that comes up every so often is some of our members are having a difficult time getting
their over 40 gallon, not 40 pound sized propane tanks filled.
I have gone to your web site for the code:
http://www.nfpa.org/freecodes/free_access_document.asp
Review NFPA 58: Liquefied Petroleum Gas Code, 2004 Edition online
I can't find the actual section that covers what I understand is an OPD exemption for the propane tanks that are
horizontally mounted permanently on our Wanderlodge. I have found this information with a reference to THE
CODE on web sites such as;
http://www.npga.org/i4a/pages/index.cfm?pageid=534
Which says;
Q: I have a horizontal cylinder on my recreational vehicle. Are OPD's available for that kind of service? :
A: The 2001 edition of NFPA 58 (the LP-Gas Code) recognizes that horizontally oriented cylinders that were
manufactured prior to October 1, 1998, are unable to be retrofitted with the OPD's. As a result of this fact, the
Code now exempts these cylinders from having to be retrofit with OPD valves. Any such cylinder must have a
label affixed to it to inform the user and the refiller that an OPD valve is not installed.
Could you please tell me where to actually find this information in the code. I will then place the URL link to that
section of the code in our files for our members to read. I understand that I cannot copy and paste any portion of
the online version of the code, is there anywhere that I can obtain just that section of the code that pertains to
the tanks on our Wanderlodge's. We would like to carry a copy of this section with us, to show to the propane
suppliers that are refusing to fill our tanks without the OPD's installed.
Thank you very much for your assistance.
John Finn
Forum Moderator
Wanderlodges Owners Group
http://autos.groups.yahoo.com/group/wanderlodge/
'82 35FCRB
BLUEBIRD WANDERLODGES
TO VISIT THE "FINN'S INN EXPRESS" REMODELING ADVENTURE
GO TO;
http://www.pbase.com/image/24977457
HOPKINS, SOUTH CAROLINA

RV camping wisdom from the experts at KOA.
Important Information On Your RV Propane Tank
Is it time to retire your propane tank?
Beginning April 1, you will no longer be able to get your small propane tank refilled without an overfilling
protection device (OPD) installed.
This means anyone with a tank manufactured before Oct. 1, 1998 will have to have the tank valve unit replaced,
or purchase a new tank. The new rules apply to all small propane tanks with a capacity of from 4 pounds up to 40
pounds of propane. Those tanks are common on gas grills and recreational vehicles.
The overfilling protection device is being required in order to comply with national fire and safety standards.
There are limits on how much propane can be put into a cylinder. A properly filled cylinder will have a vapor
space left at the top to allow room for expansion of the liquid when a change in temperature occurs. The OPD is
a secondary means of insuring that cylinders are not overfilled.
The OPD is needed because overfilled cylinders, when subjected to warmer temperatures, create hazardous
conditions. The pressure relief value may open, discharging propane from the cylinder, or liquid propane may
enter your RV’s piping system, resulting in higher than normal pressures to appliances.
The OPD is basically a value that includes a float inside the tank that will automatically close the cylinder when
the proper level of propane is reached.
You can take your old propane tanks to a propane dealer to have an OPD installed, but due to the cost you may
be better off purchasing a new tank.
If you’re wondering if your current tank has an OPD installed, check the value. If the value has a triangular hand
wheel that is stamped with the letters OPD you have an approved cylinder.
http://www.koa.com/familyzone/camping101/articles/safety_540.htm

OPD's: Information for Consumers -
Questions & Answers
An Avenue to Greater Safety in the
Use of Propane
This information has been developed to create a better understanding relative to the introduction of a new safety
device designed to markedly increase the safe use of small propane cylinders. While an occasional
inconvenience may occur during the transition to a higher level of propane safety for gas grill tanks, etc., it is the
propane industry's desire that the OPD be recognized by consumers for what it really is...a notable advancement
for the safe use of the Exceptional Energy, Propane!
Here then, is a listing of answers to consumer's most commonly asked questions. The propane industry hopes
that this information will be helpful relative to the purpose and use of the overfilling prevention device.
The OPD
What is an overfilling prevention device?
What does the Code require?
How can an OPD be identified when it is installed in a cylinder?
Is an OPD intended to be an aid in the filling of a cylinder?
Is the requirement for OPD's a mercenary ploy by those in the propane industry to take advantage of consumer's
pocketbooks?
I have a horizontal cylinder on my recreational vehicle. Are OPD's available for that kind of service? :
Why do some propane retail marketers fill cylinders that would normally be required to be requalified and have
an OPD installed, whereas other marketers require the OPD to be retrofit on the cylinder before they refill it?
If the requirement for a cylinder to be equipped with an OPD is not a law in my state, then how can it be enforced
by a propane marketer?
What happens if the float breaks off?
In another state I recently had a cylinder filled for my deer hunting camp and they didn't mention anything about
an OPD. Are there laws different from this state?
Why don't they make one-time-use throw-away grill tanks?
Where can I have my tank requalified and a new OPD valve installed? If you will not requalify my tank, then where
can I buy a new one? Where can I dispose of my old tank?
Roofers and other commercial customers are trying to use OPD equipped tanks on torch applications and they
are not getting an adequate flow through the valve. What can we do about this?
Q: What is an overfilling prevention device?
A: As defined by the National Fire Protection Association's Pamphlet 58 - LP-Gas Code, 1998 Edition (Code), it
is...'A safety device that is designed to provide an automatic means to prevent the filling of a container in excess
of the maximum permitted filling limit.' Typically, the overfilling prevention device will appear as part of a
cylinder valve that is installed as a complete unit into the cylinder. The cylinder valve will have either a CGA 791
(ACME threads) or a CGA 810 (push-pull, quick disconnect) connection device.
Q. What does the Code require?
A. For propane cylinders* in the 4 lb. through 40 lb. propane capacity range, the Code requires for them to be
equipped with an OPD, as follows: New cylinders for vapor service which are fabricated after September 30,
1998; as cylinders are requalified after September 30, 1998 through March 31, 2002; effective April 1, 2002, before
a cylinder is filled. *All references to 'cylinders' applies to only those in the 4 lb. through 40 lb. propane capacity

ange. Also, the last page of this document contains information on the service life and inspection of cylinders.
Q: How can an OPD be identified when it is installed in a cylinder?
A: Listed (e.g. Underwriters Laboratories, Inc.) OPD's are easily recognizable by observing their unique trilobular
handwheel. The hand wheel is connected to the valve stem in a tamperproof manner for the purpose reducing
the possibility of putting a user at risk by an attempt to interchange an OPD handwheel on to a conventional
non-OPD valve. It should be noticed that the valve stem on a non- OPD equipped cylinder is not easily matched
with a standard trilobular OPD handwheel. Those who fill cylinders should take care in observing whether or not
a cylinder that appears to be equipped with an OPD, actually is.
Q:Is an OPD intended to be an aid in the filling of a cylinder?
A: The device is designed to only be a backup in the filling of a cylinder. With an OPD equipped cylinder, the
traditional procedures of filling by the weight or volumetric methods should be followed.
Note - Prior to the Code's requirement for the use of OPD's, early non-uniform valves were introduced into the
marketplace. Thousands of these valves had conventional hand wheels and were not marked as now required by
the UL listing. While the safety features of these early OPD valves is not being questioned, those who fill small
propane cylinders should be aware of these valves still being in service. In time, through normal attrition, these
first generation OPD valves will fade from use by attrition.
Q: Is the requirement for OPD's a mercenary ploy by those in the propane industry to take advantage of
consumer's pocketbooks?
A: This is a good question and deserves a direct answer which is...no. Those marketers who fill propane
cylinders for customers have had virtually nothing to do with the advent of the OPD. The term 'virtually' is used
as there were a few highly concerned and industry active propane marketers who became involved in resolving
issues which surrounded the advent of OPD's, including a reasonable time frame for the introduction of these
new safety devices into the marketplace.
Q: I have a horizontal cylinder on my recreational vehicle. Are OPD's available for that kind of service? :
A: The 2001 edition of NFPA 58 (the LP-Gas Code) recognizes that horizontally oriented cylinders that were
manufactured prior to October 1, 1998, are unable to be retrofitted with the OPD's. As a result of this fact, the
Code now exempts these cylinders from having to be retrofit with OPD valves. Any such cylinder must have a
label affixed to it to inform the user and the refiller that an OPD valve is not installed.
Q: Why do some propane retail marketers fill cylinders that would normally be required to be requalified and
have an OPD installed, whereas other marketers require the OPD to be retrofit on the cylinder before they refill it?
A: Propane marketers of integrity are those that care about the handling and use of cylinders that they refill,
knowing that the families of consumers deserve the best and safest service that can be offered. If a propane
marketer elects to do otherwise, that choice speaks for itself. Also keep in mind that some states or jurisdictions
have not adopted the 1998 or later editions of NFPA 58.
Q:If the requirement for a cylinder to be equipped with an OPD is not a law in my state, then how can it be
enforced by a propane marketer?
A: The Code is not adopted, state-by-state, on a uniform basis. In time, most states, if not all, will move to
enforce the OPD criteria which was first published in the Code's 1998 edition.
Q: What happens if the float breaks off?
A: If an OPD is determined to inoperable, it should be replaced.
Q: In another state I recently had a cylinder filled for my deer hunting camp and they didn't mention anything
about an OPD. Are there laws different from this state?
A. The Code is revised by the National Fire Protection Association every three years. Virtually all of the individual
United States of America have adopted the Code as their rules for propane applications, but not necessarily on a
uniform basis as to a particular edition. So, as the OPD requirements first appeared in the 1998 edition of the
Code, not all states have updated their propane rules to that edition. Again, it is expected that all cylinders in the
4 lb. through 40 lb. capacity range will eventually be equipped with an OPD.
Q: Why don't they make one-time-use throw-away grill tanks?
A: Propane cylinders are manufactured to a comprehensive specification of the U.S. Department of
Transportation. Because of these strict requirements, a throwaway grill tank service would increase consumer
cost to a level that would be unreasonable and impractical.

Q: Where can I have my tank requalified and a new OPD valve installed? If you will not requalify my tank, then
where can I buy a new one? Where can I dispose of my old tank?
A: The propane marketers serving your area should be a reliable source of information to answer questions
regarding the OPD.
Q: Roofers and other commercial customers are trying to use OPD equipped tanks on torch applications and
they are not getting an adequate flow through the valve. What can we do about this?
A: Some of the early OPD valves had an insufficient flow capacity for certain types of service such as
high-pressure torch applications. Market competition has resulted in OPD's becoming available that have
significantly greater rates of flow.
©NPGA 2002
http://www.npga.org/i4a/pages/index.cfm?pageid=534
The following draft of another email correspondence with Mr. Lemoff, is in reference to a similar problem with
the Propane filling station attendant that tells you that the tank on your Bluebird Wanderlodge, is too old and
needs to be re-certified. Again I have not edited the content of his email, but I have highlighted the sections that I
feel are pertaining to our Bluebird Wanderlodge’s.

Mr. Finn,
The propane containers permanently installed on RV’s are built to the ASME Boiler and Pressure Vessel Code,
and are not cylinders. There are no recertification requirements in the ASME Code.
This correspondence is not a Formal Interpretation issued pursuant to NFPA Regulations. Any opinion
expressed is the personal opinion of the author, and does not necessarily represent the official position of the
NFPA or its Technical Committees. In addition, this correspondence is neither intended, nor should be relied
upon, to provide professional consultation services.
Very truly yours,
Theodore C. Lemoff
Staff Liaison
From: IAMFLAGMAN@aol.com [mailto:IAMFLAGMAN@aol.com]
Sent: Monday, March 05, 2007 3:28 PM
To: Lemoff, Ted
Subject: Re: RV PROPANE TANK CODES
Mr. Lemoff,
I want to thank you for you prompt reply I found it very helpful and now I have another question that you may be
able to help me with.
Some of these same propane filling stations are refusing to fill the propane tanks on our older Bluebird
Wanderlodge's, by determining that the date of manufacture on the onboard tank is too old and it has to be recertified.
I have tried to contact propane dealers and rv repair facilities to have a re-certification done on my
onboard 44.5 gallon propane tank and I can't find anybody that knows anything about this topic. Can you please
help us find a source for the re-certification, or clear up any discrepancies with the code concerning this topic.
These onboard tanks on our Bluebird Wanderlodge's are used for heating, cooking and refrigeration purposes
and some have propane powered generators onboard, but they do not have any connection with the main
engine.
Thank you again,
John Finn
--------------------------------------------------------------------------------------------------------------------------------------------------------
If you would like to read the entire CODE , it can be viewed at the NFPA web site by first going to;
http://www.nfpa.org/aboutthecodes/list_of_codes_and_standards.asp
Then look under All NFPA Codes and Standards, then scroll down to find NFPA 58 Liquefied Petroleum Gas
Code, then click on NFPA 58. Next scroll down to Additional Information about this document: and click on
Preview this document. Next you will have to click on I AGREE under the Agreement. Next read through the
explanation of the document and then click on Open NFPA 58: Liquefied Petroleum Gas Code, 2004 Edition, now
a smaller drop down box will open temporarily until the actual NFPA 58 Liquuefied Petrolium Gas Code-2004
Edition opens up. Now you can use the controls at the bottom to page through the CODE and thoroughly
confuse your self, by trying to decipher the CODE for your self.
I have come to the conclusion that after reading these items, our propane tanks permanently installed on our
‘Birds do not fall under the codes for RV propane cylinders. I hope that this helps to resolve these issues.

John Finn
‘82FCRB WANDERLODGE