Although it is clear that First does monitor CD, Erich's suggestion is the official path for rules change suggestion per numerous mentions in the Q&A. I think the Q&A response was poorly thought out. Poor definitions make the RI's job difficult and leads to different inspectors making different decisions. Shock absorbers use oil. Most COTS "Gas springs" use more than an minuscule amount of oil. Here is a
CD discussion on the Q&A.
In either case you are far more likely to pretzel the rod than to rupture the cylinder.