IAFF Addresses SCBA Cylinder Interoperability
|December 2, 2005 The IAFF continues to monitor and address the issue of SCBA cylinder interoperability following questions and complaints received by the National Institute for Occupational Safety and Health (NIOSH) in regard to interchangeability of respirator subassemblies and unapproved modifications to NIOSH-certified respirators.
Through research, review and standard setting activities, the IAFF is identifying viable engineering solutions; however, this remains a complex issue with potentially serious implications for the first responder community.
While we believe that establishing interoperability between SCBA manufacturers presents the clear advantage of ensuring cylinder and valve compatibility, it is imperative that our members the predominant users as well as regulators and standard setting bodies, understand the ramifications, says IAFF General President Harold Schaitberger.
The U.S. Occupational Safety and Health Administration (OSHA) has used NIOSH and other OSHA regulations to establish minimum requirements for fire fighter respiratory protection. Upon investigation, some problems reported to NIOSH have been determined to be caused by user modification to certified respirators resulting in the modified respirator failing to perform as anticipated, thereby jeopardizing the respirator user. NIOSH respirator certification regulations state that approved respirators are those maintained in an approved condition and the same in all respects as those respirators for which a certificate has been issued.
In addition, the regulations permit NIOSH to only approve complete respirator assemblies and prohibit the approval of respirator subassemblies such as cylinders or air supply hoses. These requirements are intended to ensure that one manufacturer has overall control and responsibility for the integrity of its approved respirator. Such control reinforces the manufacturers liability for its product, including in this case its approved cylinder.
In some cases, even minor modifications to respirators can make significant changes in the performance of the respirator. Manufacturers that modify certified respirators must test the modification to determine if the respirator continues to meet the minimum requirements, and must submit the modifications to NIOSH. A user who modifies a certified respirator may not be able to determine whether a change will decrease respiratory protection. Several cases have been reported to NIOSH where unapproved modifications or use of unapproved subassemblies have resulted in respirator failures. Therefore, users of NIOSH-approved respirators are cautioned against interchanging subassemblies or making unapproved modifications to their respiratory protective devices.
Furthermore, employers that use components from other manufacturers on respirator equipment, including cylinders, are voiding the NIOSH approval for their respirators. Two OSHA standards [1910.156(f)(1)(iv) and 1910.120(q)(3)(x)] do permit the use of another manufacturers cylinders on SCBAs when deemed necessary to meet the tasks at hand. OSHA concession to this practice is only intended to be granted in emergency, lifesaving situations.
An example of an OSHA-allowed situation involves several different emergency response organizations to a hazardous incident requiring the use of SCBAs. As the cylinder supplies are depleted, the appropriate approved cylinder may not be available for a particular SCBA when an emergency or life-saving task is required. Rather than waiting until the appropriate cylinder is obtained, the employer may permit the use another manufacturers cylinder, provided it meets the specifications of the respirator manufacturer and has the same capacity and pressure rating. Although this temporarily voids NIOSH approval, OSHA believes the interchangeability of air cylinders is important enough to life safety during a specific emergency or life-saving task of emergency response members to permit it.
After the specific emergency is over, OSHA expects employers to return their SCBAs to their original NIOSH-approved condition. In emergency operations where there are no life-saving tasks or in non-emergency situations, OSHA expects SCBAs to be maintained and used in their approved condition again without another manufacturers cylinders. However, it is important to note that even though OSHA may permit this action, it still voids the NIOSH approval. Equally important, it violates the manufacturers instructions and voids any warranty or liability.
Currently, NIOSH and the National Fire Protection Association (NFPA) are reviewing proposals that would require all SCBA manufacturers to design their SCBAs so that cylinder and valve assemblies for all NFPA-compliant SCBAs can be interchanged with all other NFPA-compliant SCBAs.
The IAFF understands that the reasoning revolves around the potential for a major terrorist attack or other disasters requiring a multiple agency response. Under such scenarios, SCBA cylinders could theoretically be seamlessly exchanged as one resource, regardless of the SCBA manufacturer, provided that the cylinders are of like working pressure.
The obvious advantage of these proposals is to facilitate interagency responses and interoperability including fire department mutual aid in the event of a terrorist attack. It is important to note that the emergency response to the attacks on September 11, 2001, was not impeded by cylinder interoperability since the majority of all federal, state and local agencies responding to the World Trade Center in New York and at the Pentagon were using the same SBCA.
Additionally, following the initial response at the World Trade Center site, SCBA were not worn. However, it is possible that a major disaster in the future could occur in an area where cylinder interoperability could be an issue.
Ongoing issues related to SCBA cylinder interoperability include the implementation of a proposal requiring identical cylinders between manufactures in that much of the current inventory is largely incompatible with the interoperability mandate. There are more than one hundred different cylinder types in the field when you consider the cylinder materials (steel, aluminum, hoop wrap, composite, etc.) pressures (2216, 3000 and 4500 psi [interoperability only exists for cylinders of like pressure]) and time (30-, 45-, and 60-minute). In addition, there are currently three manufactures of cylinders (SCBA manufacturers do not make their own). Cylinder liners are non-standard in the cylinder industry and, consequently, a specific duration cylinder from one manufacturer may not have identical dimensions to the same duration cylinder from a different manufacturer.
This means that fire departments could face the significant expense of replacing hundreds of millions of dollars in SCBA products or components from a variety of suppliers. For fire departments that cannot afford to do so, interoperability within a single fire department is lost.
Further complicating the issue is the age of the fire departments current cylinder inventory as this creates a challenge for departments for at least the expected useful life of carbon cylinders which is currently 15 years. (Full steel and full aluminum cylinder life is even longer, as long as they are hydrostatically tested. By standardizing the cylinder liner, but maintaining the different pressures and duration, there would still be multiple cylinder types that would not be compatible or allow for interoperability.
If the intent of the current proposals for cylinder interoperability is that future purchases require compliance to the latest revision to NFPA 1981, Standard on Open-Circuit Self-Contained Breathing Apparatus for Fire and Emergency Services, or the NIOSH federal respiratory regulations 42 CFR Part 84, including cylinder interoperability, this could mean that many fire departments will find themselves in the position of buying new SCBA with cylinders that are incompatible with existing SCBA inventory.
This is among the worst possible scenario, because interoperability may not exist even within the fire department itself. And, it could likely take years to eliminate this issue within large fire departments. Of particular concern to the IAFF is that cylinder interoperability issues may stop or inhibit new product innovation with little or no real benefit to members.
With design driven requirements, new innovative cylinder or valve designs will not occur. For example, at least one manufacturers (and a number of others have similar innovations in the works) recent design innovation gives fire fighters a way to replace depleted SCBA cylinders in a fraction of the time previously required through a quick connect/disconnect cylinder valve. Most importantly, under the current NFPA 1981 standard, all manufacturers must equip each SCBA with a rapid intervention crew/company (RIC) universal air connection (UAC) male fitting to allow replenishment of breathing air to the SCBA breathing air cylinder.
The RIC UAC fitting must be permanently fixed in an approximately the same position on all SCBA. The RIC UAC allows for the refilling of cylinders either inside (allowing a rapid intervention team or rescue team to supply air to a downed fire fighter) or out of the emergency area allowing for a quick fill of the SCBA.
While the RIC UAC fittings do not address the sharing of cylinders between agencies, they do allow for the sharing of air by allowing for the opportunity to fill any approved SCBA cylinder, regardless of pressure, size or duration. Again, this is a recent requirement (2002 edition of standard), and will take years for all units in the field to have such a life-saving device, as well as a device that does afford interoperability.
This is a complex issue which still requires additional investigation and a good understanding of how fire departments use their SCBA in order to understand the impact on the fire fighter, says General President Schaitberger.
For additional information, views and positions on this issue, the National Fire Protection Associations Technical Committee on Respiratory Protective Equipment has developed a request for information in a technical note in their revisions to the current NFPA 1981 Standard.
This technical note will be published by the NFPA in the Committees Report on Proposals (COMMITTEE DOCUMENT 1981-FM06-TCC ROP). The IAFF is urging its membership to review the committee information in its entirety and provide input to this important NFPA Committee.