I see this practice, keeping cylinders in-service beyond their hydro due dates, and I just want to make everyone aware that although this practice may be complaint with 49 CFR Part 180, it sets up the Emergency Response Team (ERT) with a potentially serious Breathing Air (BA) issue during a response. There are two failures, both are quite common finds during our ER audits/assessments, that come together to set up an ERT with the potential issue…
Most facilities that have their own ERT, have very few responses that required the use of breathing air.
Even when the facility has all of their breathing air cylinders in a MI Hydro testing program per 49 CFR part 180, it is common practice to allow cylinders to remain in service past their 5-year hydro date. This is ALLOWED per the standard – they just can NOT be filled until they have been hydro’ed!!!
A lot of facilities will NOT perform the monthly inspections of their SARs/SCBA cylinders per the manufacturer’s protocols, and this allows these units to remain in service well after their Hydro due dates.
Normally, a monthly inspection will entail functional testing of the regulator and low air alarms which use some of the BA each month, and thus after 6-7 months of PROPER inspections, the cylinder will drop to less than 90% of a full charge and need to be topped off.
This “topping-off” would require the cylinder to be removed from service since the cylinder is past its Hydro due date; however, without having to top-off the cylinder, it stays in-service until a response. And then once the bottle needs to be refilled during the response, it can NOT be as it is past it’s hydro due date. This can leave the ERT in a bad spot with limited BA cylinders for their continued response.
We recently came across an ERT that had 70 BA cylinders in-service, of which 32 were past their hydro date. During a response, the facility would not be able to meet it’s own internal response plans after losing 32 cylinders from its inventory.
So although it may be permitted by 49 CFR Part 180 to use cylinders that are past their hydro due dates; it comes with a risks of running low or out of BA cylinders when they are needed most. The one thing that is clear…
No cylinder may be filled with a hazardous material and offered for transportation in commerce unless that cylinder has been successfully requalified and marked in accordance with this subpart.