Review - S 2320 Introduced – Foreign Cylinders

Last month Sen Moreno (R,OH) introduced S 2320, the Compressed Gas Cylinder Safety and Oversight Improvements Act of 2025. The bill would require DOT to establish additional regulations relating to the approval of foreign manufacturers of cylinders used in the transport of hazardous chemicals. There is no new spending authorized by this legislation.

This bill is identical to S 1632, the Compressed Gas Cylinder Safety and Oversight Improvements Act of 2023, that was introduced by then Senator Vance (R,OH) in May of 2023. More importantly, it is nearly identical to HR 1182 that was passed in the House on June 9^th, 2025. The only difference between this bill and the House bill is the web site location where DOT would be required to maintain a list of approved foreign cylinders; DOT website for this bill and PHMSA website for the House bill. Since the PHMSA web site is part of the DOT website, this is a less than significant difference. There was one other minor difference, this bill corrected a typographical error in the opening sentence of §2(g), correcting the 49 USC reference to read §107.807(c) instead of the subsection (d) found in both the House bill and earlier Senate versions {BTW: there is no subsection (d) in that USC Section}.

Moving Forward

Moreno and his sole cosponsor {Sen Baldwin (D,WI)} are members of the Senate Commerce, Science, and Transportation Committee to which this bill was assigned for consideration. This means that there could be sufficient influence to see the bill considered in Committee. I suspect that the bipartisan support this bill received in the House would also be seen in the Senate. The Committee, however, will not have to act for this bill to be considered by the full Senate, or more appropriately the House version of the bill. Having said that, this bill would have to be considered under the unanimous consent process or as part of a larger bill, since this bill is just not politically important enough to take up the Senate’s time if it were considered under the regular order.

 

For more details about the provisions of this bill, see my article at CFSN Detailed Analysis - https://patrickcoyle.substack.com/p/s-2320-introduced-foreign-cylinders - subscription required.