In the last couple of years we have come across a vicious and BADLY MISLEADING rumor that some facilities have fallen for and thus they have fallen out of compliance with OSHA/NIOSH/DOT in regards to their SCBA Cylinders.
FACT: There are studies that have been done by the U.S. Navy and PHMSA that demonsrate 15-year service life is very conservative and with a different type of testing, the cylinders service life could be safely extended.
LIE: A facility can adopt Modal Acoustic Emission (MAE) testing and extend their cylinders service life based on the test results.
There is a LOT MORE to these studies and we can NEVER wander away from the cylinder’s and/or the holder of the NIOSH approval “maintenance requirements”. Here is a look at the studies and how we got to this point. BUT BEWARE… we MUST STILL FOLLOW the cylinder manufacturer or the NIOSH certificate holder’s test frequency for their cylinders! We are NOT allowed to adopt Modal Acoustic Emission (MAE) as an alternative to Hydrostatic Testing WITHOUT WRITTEN APPROVAL from…
UPDATE: BEFORE we go any further I want to make it CLEAR… I am aware of some SCBA sales rep’s at distributors telling customers as a “selling point” that the 15-year life can be extended using MAE. This is being said to customers to sell the higher priced cylinders that come with a shorter service life. It is disgraceful and DANGEROUS. If you are seeing this, you are a SAFTENG member, so if you have questions that are not answered by my explanation and links below, PLEASE contact me or better yet contact the MANUFACTURER and get the facts drirectly from them. I am posting the “official” positions of MSA and Scott/3M below.
Back in the 2010 timeframe the U.S. Navy conducted a 3rd party study on their SCBA cylinders to determine if 15-years was the proper end-of-service-life for their cylinders. That study showed that ALL the Navy’s tested cylinders could have an extended service life. Then in 2017, the the U.S. Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) conducted their own study Modal acoustic emission (MAE) Examination Specification for Requalification of Composite Overwrapped Pressure Vessels (Cylinders and tubes) to determine if a new testing method would be acceptable and allow for extended service life of some SCBA cylinders. On October 5, 2017, PHMSA issued special permit 16320 (DOT-SP-16320) Third Edition, to Digital Wave Corporation. DOT-SP-16320 authorizes the extension of the cylinder original equipment manufacturer (OEM) 15-year service life for certain carbon-fiber reinforced aluminum-lined cylinders (DOT-CFFC) in 5-year increments, up to 15 additional years, for those devices that pass modal acoustic emissions (MAE) requalification testing. But here is the catch…
In accordance with the NIOSH regulation, 42 CFR 84, the self-contained breathing apparatus (SCBA) manufacturer holding the NIOSH approval establishes the SCBA service life, identifies cautions and limitations for use, and provides instructions for use and maintenance procedures. The SCBA manufacturer also has the responsibility as a NIOSH approval holder to maintain the NIOSH-approved quality control policies and procedures. SCBAs should be maintained and used in accordance with the labeling and users instructions. If used otherwise, they are NOT compliant with the NIOSH approval. This includes the extension of the OEM’s service life beyond the service life approved in the user instructions, and provided in supplemental informational inserts, on labels, and including safety precautions and warranty information. If a manufacturer chooses to apply SP-16320 to the NIOSH-approved SCBA configuration, the manufacturer must request a modification of approval from NIOSH, and seek approval of revised documentation.
Accordingly, respiratory protection program administrators and SCBA users with questions or concerns about the application of DOT-SP-16320 to NIOSH approved and deployed SCBA must review the user instructions, supplemental informational inserts, safety precautions, and SCBA warranty information provided by the NIOSH approval holder.
Without NIOSH review and approval of modified documentation, the use of MAE requalification testing to extend the service life of SCBAs that have reached the end of the service life indicated in the documentation provided by the SCBA manufacturer is not compliant with NIOSH approval for those devices.
Further questions can be addressed by the approval holder of NIOSH-approved SCBA with type CFFC originally marked with DOT-SP-10915, 10945, 11194, 13381, 13179, 13853, 14232, and 14339.
CLICK HERE for NIOSH’s Official Position
Here are some “official letters” from major manufacturers and the largest cylinder manufacturer regarding extended their product’s service life:
https://www.luxfercylinders.com/press-releases/luxfer-gas-cylinders-position-concerning-life-exte
https://www.3mscott.com/product-update/
