I recently came across an interesting situation that may be more common than I would have originally thought. I found this situation merely by being in the right spot at the right time. We were visiting the local Fire Department (FD) in order to participate in a critique of a response to a clients facility. After the critique was over I was talking “shop” with some of the FF’s and just happened to be standing out in their bays and noticed some irregularities regarding their breathing air compressor(s). The Captain noticed that I was intently looking at the set up and mentioned to the safety manager of the facility that if we could wait for a few more minutes that his bottles would be filled and we could take them with us. Then it dawned on me… the facility is NOT getting their Grade D breathing air from a commercial supplier nor are they using their own compressor – instead they are getting their local FD (who does not fall under OSHA) and who were obviously not meeting 1910.134(i). So if you are using your local FD to fill your breathing air cylinders, you may want to verify they are complying with 1910.134, specifically:
1910.134(i)(1)(ii) Compressed breathing air shall meet at least the requirements for Grade D breathing air described in ANSI/Compressed Gas Association Commodity Specification for Air, G-7.1-1989, to include:
1910.134(i)(1)(ii)(A) Oxygen content (v/v) of 19.5-23.5%;
1910.134(i)(1)(ii)(B) Hydrocarbon (condensed) content of 5 milligrams per cubic meter of air or less;
1910.134(i)(1)(ii)(C) Carbon monoxide (CO) content of 10 ppm or less;
1910.134(i)(1)(ii)(D) Carbon dioxide content of 1,000 ppm or less; and
1910.134(i)(1)(ii)(E) Lack of noticeable odor.
1910.134(i)(4)(ii) Cylinders of purchased breathing air have a certificate of analysis from the supplier that the breathing air meets the requirements for Grade D breathing air; and
1910.134(i)(4)(iii) The moisture content in the cylinder does not exceed a dew point of -50 deg.F (-45.6 deg.C) at 1 atmosphere pressure.
If your getting bottles filled by the local FD who uses a compressor, here are the requirements:
1910.134(i)(5) The employer shall ensure that compressors used to supply breathing air to respirators are constructed and situated so as to:
1910.134(i)(5)(i) Prevent entry of contaminated air into the air-supply system; (NOTE from me on this, if the intake to the compressors share a space with vehicles and their exhaust there is a PROBLEM with the set up!)
1910.134(i)(5)(ii) Minimize moisture content so that the dew point at 1 atmosphere pressure is 10 degrees F (5.56 deg.C) below the ambient temperature;
1910.134(i)(5)(iii) Have suitable in-line air-purifying sorbent beds and filters to further ensure breathing air quality. Sorbent beds and filters shall be maintained and replaced or refurbished periodically following the manufacturer’s instructions.
1910.134(i)(5)(iv) Have a tag containing the most recent change date and the signature of the person authorized by the employer to perform the change. The tag shall be maintained at the compressor.(HINT: this is an EASY item to look for when investigating if your FD is meeting OSHA requirements)
1910.134(i)(6) For compressors that are not oil-lubricated, the employer shall ensure that carbon monoxide levels in the breathing air do not exceed 10 ppm.
1910.134(i)(7) For oil-lubricated compressors, the employer shall use a high-temperature or carbon monoxide alarm, or both, to monitor carbon monoxide levels. If only high-temperature alarms are used, the air supply shall be monitored at intervals sufficient to prevent carbon monoxide in the breathing air from exceeding 10 ppm.
Keep in mind that if your facility can not document that the breathing air coming from the FD meets these requirements, OSHA will NOT go to the FD and issue them a citation; it will be issued to the facility. This is why I always encourage facilities to buy their Grade D breathing air from a reputable supplier and to even set up a breathing air “cascade system” so that they can fill their own bottles when needed. As I have pointed out before, Supplied Air Respirators will require FREQUENT topping off when they are inspected properly EACH month; so having in-house means to top off these bottles and fill bottles after each use just makes a facility more independent and COMPLIANT with OSHA’s minimum safety requirements. If the business just insist that they want to conitnue getting bottles filled by the local FD, then I would suggest a visit to the FD to ensure that the air your workers are breathing is GOOD BREATHING AIR!
PLEASE NOTE that in our brief examination of the FD’s breathing air system, they failed in all respects. This is a small town, but a great FD and so they asked for help in improving their breathing air quality for their FF’s (as well as the clients personnel). A quick call to the company who made their compressor/filling station was all it took. In less than a month, the issues were resolved, documentation was provided to the client and the two organizations are getting along once again. But please be aware, there have been ocassions where the FD tells the facility to take a long walk off a short pier and they can get their bottles filled elsewhere. BOTTOM LINE, we are responsible for the breathing air our employees breath, REGARDLESS of where we get the breathing air from!