Those of you that have been reading my materials for the past 20+ years know that I can be rather extreme when it comes to critical safety items such as SCBA’s used in IDLH atmospheres. I make no apologies for my positions and my directness – heck I think more of you need to be like me rather than I need to “take a chill pill and join the team” (advice I get often). But my “extreme positions” have caused issues in the past when clients desire to meet the OSHA minimums on their High-Risk work, such as wearing an SCBA in an IDLH atmosphere (or even a potential IDLH atm). I began my journey in this profession as a firefighter and in our FD we had a state of the art (at the time) breathing air system since we were home to the region’s HAZMAT team as well. With this system came procedures, quality inspections, maintenance, siting of the compressor, etc. – heck PSM was not even being discussed at this point in time, but who knew that NFPA was ahead of the game in using the same practices for their breathing air compressor requirements! And here is where I pass over into another universe for safety… from OSHA minimums to NFPA best practices
SAFETNG Note: In my advanced PSM/RMP audits (and ERT reviews) I hold the facility responsible for adopting NFPA 1989: Standard on Breathing Air Quality for Emergency Services Respiratory Protection as I believe it is appropriate to use a RAGAGEP to fill in the gaps that OSHA standards do not provide the necessary level of details to ensure the highest level of safety.
But I have, for years, always required that the breathing air quality be sampled and tested quarterly and the results posted at the breathing compressor. I have even gone as far as warning facilities (and written about this) to be very careful as to where and who is filling their bottles as some fire departments in some states do not even fall under OSHA so they may have a compressor but it is not being maintained properly – thus possibly exposing your workers to unsafe breathing air! And to be honest, I could have sworn that the previous 1910.134 version had these NFPA testing and posting requirement(s) in it; although I have not been able to find proof of this yet.
So what does NFPA 1989 require and what should we be doing to ensure our workers are breathing Grade D breathing air while donned in a Supplied Air Respirator?
(emphasis by me)
5.1 Regular Periodic Testing.
5.1.1* The organization shall take at least four breathing air samples per year. Samples to meet this requirement SHALL BE TAKEN WITHIN 90 DAYS ± 5 DAYS OF EACH OTHER. The organization shall submit such samples to an ACCREDITED TESTING LABORATORY that meets the requirements specified in Chapter 4.
5.1.2 Breathing air samples shall be submitted to an accredited testing laboratory that meets the requirements specified in Chapter 4 whenever contamination of the compressed breathing air system, the stored compressed breathing air, or breathing air in an SCBA breathing air cylinder is suspected.
5.1.3 The accredited testing laboratory shall test the samples for breathing air quality levels as specified in Section 5.6.
5.1.4* The organization shall MAINTAIN DOCUMENTATION FROM THE ACCREDITED TESTING LABORATORY OF THE RESULTS OF ALL AIR SAMPLE TESTS for a period of NOT LESS THAN FIVE (5) YEARS.
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5.5 Air Samples.
5.5.1* The quarterly breathing air sample shall be obtained directly AT THE POINT OF AIR TRANSFER FROM THE BREATHING AIR SYSTEM. The point of air transfer shall be any CGA 346/347 or SCBA-specific connection where breathing air cylinders are filled.
5.5.1.1 Samples from cryogenic air systems shall be obtained at the point specified by the cryogenic air system’s operating instructions.
5.5.2* When changing the breathing air system’s purification components, TWO AIR SAMPLES SHALL BE TAKEN as required by 5.2.1.1.
5.5.2.1 One air sample shall be taken BEFORE CHANGING THE PURIFICATION COMPONENTS, and the second air sample shall be taken AFTER CHANGING THE PURIFICATION COMPONENTS.
5.5.2.2 Air samples shall be taken DOWNSTREAM FROM PURIFICATION COMPONENTS AND PRIOR TO OR BYPASSING ANY AIR STORAGE DOT CYLINDERS or ASME receivers if mechanically possible.
5.5.2.3* When system design does not allow for sampling per 5.5.2.2, all storage shall be drained and samples shall then be taken from the closest CGA 346/347 or SCBA-specific connection.
5.5.3* Compressed breathing air shall be allowed to FLOW THROUGH THE FILL HOSE FOR AT LEAST 1 MINUTE PRIOR TO COLLECTING THE SAMPLE, only when the fill whip connection fitting is visibly free of foreign material, such as oil, particulate, and water. The sample shall be collected.
5.5.4 Where sampling apparatus cannot be operated correctly inside of the containment fill station, a remote fill hose or designated air sampling port shall be permitted to be used instead of the containment fill station.
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5.7 Posting Requirements.
5.7.1 The accredited testing laboratory shall provide QUALITY ASSURANCE SIGNAGE FOR ALL BREATHING AIR SYSTEMS utilized by the AHJ.
5.7.2 All worded portions of the sign SHALL BE AT LEAST IN ENGLISH.
5.7.2.1 The quality assurance sign shall bear the following compliance statement legibly printed, and ALL LETTERS AND NUMBERS SHALL BE AT LEAST 25 MM (1 IN.) in height:
THIS BREATHING AIR HAS BEEN TESTED TO THE REQUIREMENTS OF NFPA 1989, 201X EDITION.
5.7.2.2 The quality assurance sign SHALL ALSO STATE THE FOLLOWING, and ALL LETTERS AND NUMBERS SHALL BE AT LEAST 12 MM (1∕2 IN.) IN HEIGHT:
COMPRESSED AIR SOURCE IDENTIFICATION — NEXT SAMPLE DUE ON OR BEFORE [date]
5.7.3* The authority having jurisdiction (AHJ) shall POST THE QUALITY ASSURANCE SIGNAGE IN A CONSPICUOUS LOCATION WITHIN 1.8 M (6 FT) OF THE COMPRESSOR AND/OR ANY STORAGE CYLINDERS USED TO RECHARGE EMERGENCY SERVICES SCBA OR AS A SUPPLIED AIR SOURCE.
So could OSHA hold a PSM (or EPA with RMP) facility accountable for meeting NFPA 1989? That’s for the lawyers to debate, but rest assured if OSHA was to find that the workers were breathing air that did not meet Grade D breathing air they would cite 1910.134(i)(1)(ii)