Emergency Use Only SCBA and 90% Full

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This week, I conducted a 24-hr HAZMAT Tech course for a client.  The facility had purchased some new SCBA cylinders, and we noticed an odd difference between two of the cylinders.  One cylinder was manufactured in 2021, and one was manufactured in early 2022, just six months apart.  As I was covering the requirements for “Emergency Respiraors” to be 90% full BEFORE they can be used in an emergency, one of the students asked, “How do we do that?” The cylinder gauge he looked at would have had an experienced responder asking the same question!

Here is what OSHA’s standard states: (emphasis by me)

1910.134(h)(3)(iii) In addition to the requirements of paragraphs (h)(3)(i) and (ii) of this section, self-contained breathing apparatus shall be inspected monthly. Air and oxygen cylinders shall be maintained in a fully charged state and shall be recharged when the pressure falls to 90% of the manufacturer’s recommended pressure level. The employer shall determine that the regulator and warning devices function properly.

Here are the two cylinders.  Remember, the same manufacturer and manufactured just six months apart.  Can you see how the difference plays a role in the monthly inspection(s) to ensure the cylinders are 90% full?

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The cylinder on the left has “markings” on the gauge to make it easy for the inspector to ensure the cylinder is 90% full.  The cylinder on the right does not have the 90% markings.  These cylinders are 2216 psi cylinders, so when the first marking from FULL is 1500, there is a lot of opportunity for error with such a CRITICAL function of the emergency SCBA inspection. 

So what would you declare?  Is the cylinder on the right, below the 90% mark?

 

 

 

 

 

 

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