In a recent FaceBook Group posting, a member asked about using one of the DOT Special Permits that allows DOT containers/cylinders that came with a 15-year service life to have their service extended to 30 years. I wrote about this very issue in September 2019, explaining the pitfalls of using one of these DOT Special Permits. Bottom line is that DOT allows the cylinders to be re-certified so they can be used for another 15 years; however, NIOSH issued a position paper on the matter and stated that the NIOSH approval was based on the manufacturer’s submitted documentation and any changes to the specs on an approved respirator would have to be submitted if the NIOSH approval was to remain valid. In short, using one of the DOT Special Permits voids the NIOSH Approval and thus the SCBA using one of these cylinders would NO LONGER be a NIOSH Approved respirator. I wondered if OSHA was finding this and if they had issued a citation for this and this is what I was provided…
From an OSHA State Plan – Maine 2019 Inspection of a Fire Department
Citation 1 Item 1
Type of Violation: Serious; $700
T.26Ch.28§2104(3): Self-contained breathing apparatus. The employer did not ensure the self-contained breathing apparatus cylinders used for structural firefighting complied with the original effectiveness as recommended by the manufacturer.
Multiple cylinders were found in use beyond the manufacturer’s established shelf life.
Acceptable and feasible methods to correct the conditions include but are not limited to:
Inspect all cylinders for compliance with the manufacturers’ requirements and remove non-compliant cylinders from service.
PLEASE SEE:
Can we extend the life of our SCBA cylinders using Modal Acoustic Emission (MAE) Examination