Emergency Escape Breathing Apparatus (EEBA) have been around my entire career and I have used the mouth-bit style and the supplied air bag-over-the-head style. Actually, I have never had to use one, but I had them at my facilities when I was a Safety Manager in the chemical and semiconductor industries. So I have learned to hate these devices! One day I suggested we remove them from service and never have I seen a group of managers come together to adamantly state NOOOOO! But they had no skin in the game as the Safety Team managed all of the requirements for these devices, and for years I was doing it WRONG. As soon as I learned what was needed and laid out all we had to do to merely comply with OSHA minimums and Manufacturer’s requirements, their view of these devices changed quickly.
I am going to bet that some of you that read this article, will also be looking for a way to “recycle these devices”. From their application to their storage, to actual use, training, and inspection/testing most see little value in these devices. Unfortunately, these devices are nothing more than a “makes me feel good” paperweight at most facilities. So let’s see all that has to be done to have this type of respirator and the frequencies we have to perform these tasks to just comply with OSHA minimums and the manufacturer(s)…
First and foremost, OSHA does NOT require anyone to have this style/type of respirators. Like all respiratory protection, the need necessitates the style/type respirators we provide. OSHA merely states in 1910.134 that if we decide to have EEBA, we must meet the following:
OSHA defines an Escape-only respirator as a respirator intended to be used only for emergency EXIT.
In other words, they are NEVER to be used to enter a hazardous area while the area has a chemical hazard present.
As we know, ALL respirators used in the workplace, except those used on a “voluntary basis”, MUST be NIOSH-certified; this goes for EEBA’s as well!
1910.134(d)(2)(ii) Respirators provided only for escape from IDLH atmospheres SHALL BE NIOSH-CERTIFIED FOR ESCAPE FROM THE ATMOSPHERE IN WHICH THEY WILL BE USED.
Here’s a doosey!!!! How many facilities will have their employees medical qualified if they are assigned to a role that is required to utilize an EEBA?
1910.134(e)(5)(i) The following information must be provided to the PLHCP before the PLHCP makes a recommendation concerning an employee’s ability to use a respirator:
1910.134(e)(5)(i)(A) (A) The type and weight of the respirator to be used by the employee;
1910.134(e)(5)(i)(B) The duration and frequency of respirator use (including use for rescue AND ESCAPE);
This last mention by OSHA is very telling in how these EEBAs are to be utilized in a workplace:
1910.134(h)(3)(i)(C) Emergency escape-only respirators shall be inspected BEFORE BEING CARRIED INTO THE WORKPLACE FOR USE.
Ever wonder why OSHA uses that phrase and inspection frequency? These EEBA’s do NOT fall under the “30 Day” emergency respirator inspection frequency because they are NOT intended to sit on a shelf awaiting use. These devices are FULLY INTENDED to be assigned to workers who will be entering areas of a workplace where they could be trapped due to a chemical release. So our SCBA’s that are DESIGNATED for EMERGENCY USE ONLY have to be inspected at least every 30 days:
1910.134(h)(3)(i)(B) All respirators MAINTAINED FOR USE IN EMERGENCY SITUATIONS SHALL BE INSPECTED AT LEAST MONTHLY and in accordance with the manufacturer’s recommendations, and shall be checked for proper function before and after each use; and
but our EEBA’s may end up being inspected daily, depending on their frequency of use.
1910.134(h)(3)(i)(C) Emergency escape-only respirators shall be inspected BEFORE BEING CARRIED INTO THE WORKPLACE FOR USE.
So even OSHA is calling these EEBAs out as an entirely different “emergency respirator” that has a different inspection frequency. But 95% of the facility where these EEBAs are in use, they are managed just like the Emergency SCBA’s when it comes to inspection frequency.
So what does it mean when OSHA says “inspected before being carried into the workplace”?
In the plants where they are used per manufacturer’s instructions, these devices were ONLY issued to workers whose work would put them in a situation where their egress could be hampered by a chemical release. The easiest example is “workers on scaffolding in a Chem-Op”. These workers (contractors included, but they were required to have their own EEBAs) would be assigned an EEBA as part of the Safe Work Permitting. The EEBA would also be inspected during the SWP’ing. Once issued, the worker(s) were required to wear the unit (not deployed) on their body at all times. This is why so many of these SAR EEBAs come with a padded cross over the shoulder strap. Some exceptions could be made by the RPIC/Permit Approver that would allow them to position them near-by once they reached their working level, but we had a hard-fast rule that your EEBA had to be within 3′ of your reach at all times (Don’t ask me where that come from, but I have seen 3-5′ be the rule for distance when the device is not on your person). When the worker(s) exited the area of concern, they would close their permit and return the EEBA(s) to the RPIC/Permit Approver. This is how these EEBA’s are intended to be used. In my world, they were NOT, in NO WAY imaginable, intended to be posted/stationed in areas of concern. If the device is NOT on your person when the event occurs and you have to travel to it; it really makes no sense that you would travel to a device, don it in the area of concern, before you exit from the area. In other words, you should NEVER have to “travel to get the device” before you exit yourself from the area of concern.
Here is the language from the manufacturer’s operating instruction manual and you should take note that the manufacturer DOES allow for placing the devices in the area(s) of concern, but with some additional requirements, as discussed below.
(emphasis by me)
PRE-USE ASSURANCE CHECKS
BEFORE CARRYING THE EEBA INTO AN AREA WHERE AN EMERGENCY MAY ARISE, or before starting work in such an area where the EEBA is stored for standby or emergency use, the following precautionary checks should be made:
1. Check for signs of damage.
2. Check to be sure that the pressure gauge registers full.
3. Check to make sure that the pressure reducing valve is securely screwed into place onto the cylinder valve.
4. Check the air supply hose to verify that it is firmly attached to the barbed fittings on each end and that it is free of any cracks.
5. Check to be sure that the hose fitting at the hood is securely screwed into the air flow disperser flange.
So this manufacturer, probably the most common EEBA used in the USA, suggest that we carry them into the area of concern, but if the units are already stationed there, we must inspect them EACH TIME WE WORK IN THE AREA, not just every 30 days.
If we station them in the area of concern, ONCE the worker(s) enter the area, they would inspect them and don them, rather than obtaining them from an area outside the area of concern and carrying them in. Bottom line, these devices are NOT intended to sit in a cabinet until we need them – they are fully intended to be on our person for immediate use.
This should be obvious, but unfortunately, this is one of our top audit findings regarding EEBA’s… If there are 10 workers assigned to the area of concern and we store our EEBA in the area, how many EEBA’s would need to be in the area of concern? What if the facility has “stationed their EEBA” in strategic locations and in doing so put five (5) EEBAs at each location? But there are 10 workers in the area of concern! Each worker must be assigned their own EEBA for entry into the area of concern.
How many have looked up the temperature limitations on their EEBA’s?
The brand I am using has a limitation of 0°F for the coldest temps these devices can be stored and/or used in. So storing these devices outside in some locations may pose a problem with complying with OSHA:
1910.134(h)(2)(ii)(C) Stored in accordance with any applicable manufacturer instructions.
From the operating instruction manual:
With its portable, lightweight air cylinder and compact carrying bag, the EEBA is easily carried by the user until a life-threatening atmosphere is encountered, and is then easily operated for an emergency escape.
One of the manufacturer’s limitations when storing the devices in the area of concern is the “pre-planning” to ensure the correct model is provided based on the amount of time it may take to safely escape the area of concern.
The EEBA may also be stored in standby locations, in areas where a life-threatening atmosphere may develop—ready for emergency escape use by persons working in the area—but ONLY if such persons are TRAINED TO USE PRE-PLANNED ESCAPE ROUTES of 5-minutes or shorter duration for Models 845 and 855 or 10-minutes or shorter duration for Model 850.
Another logical manufacturer limitation, based on the available air:
- Do NOT use the Model 845 or 855 where the escape route will take more than 5-minutes to exit from the life-threatening atmosphere.
- Do not use the Model 850 where the escape route will take more than 10 minutes to exit from the life-threatening atmosphere.
- After 5 minutes, for Models 845 and 855, and after 10 minutes for a Model 850, the air supply will be exhausted, leaving the user without an adequate supply of breathable air. If still in the life-threatening atmosphere at that time, the user will be exposed to the risk of serious injury, illness or death.
Talking about “periodic inspections”, OSHA does not require any for these EEBA’s; however, this manufacturer DOES:
PERIODIC MAINTENANCE
Each week, and more frequently if possible, the air cylinder pressure gauge should be checked to assure that the unit is completely FULL. Any units showing less than FULL should be removed from service, recharged, and checked for leaks.
So OSHA could use this requirement and cite:
1910.134(h)(3)(i)(B) All respirators Maintained for use in emergency situations shall be inspected at least monthly AND IN ACCORDANCE WITH THE MANUFACTURER’S RECOMMENDATIONS, and shall be checked for proper function before and after each use; and
This next one is one that I got cited for early in my career. It is the annual flow-test of the unit. It is a very simple test, but when you have hundreds of these units across a 400-acre facility, it takes a lot of time and effort to gather, test, refill, and re-issue these EEBAs!
EVERY TWELVE MONTHS an operational test should be conducted to assure that the unit is functioning properly. This test consists of operating the unit and using a stopwatch to time the duration of air flow. If the air flow stops in less than 5 minutes for Models 845 & 855 or 10 minutes for Model 850, when starting with a full air cylinder, the unit should be taken out of service and the pressure reducing valve replaced.
The last annual requirement is to verify the bottle is within it’s Hydro Date. Yep, these cylinders are exactly like our SCBA cylinders (albeit smaller) and they have to be pressure tested using hydrostatic test methods at the same frequencies as our SCBA type bottles. We did this inspection of the hydro date stamp as part of the annual flow test, as it is a requirement that a cylinder’s test date be verified before filling a bottle!
EVERY YEAR verify the hydrostatic test date stamped on the air cylinder crown. Aluminum cylinders are to be hydrostatically tested every five years in accordance with their exemption. See D.O.T. 6498; in Canada, see CTC-SP922. For information on visual inspection of high-pressure aluminum cylinders, see Compressed Gas Association Publication G-6-1.
What do we normally see?
1) These EEBA’s are not included in the facility’s written respiratory protection program
2) These EEBA’s are not included in the annual respirator training. During interviews with the personnel, we may find 1-2 out of hundreds that have actually deployed one and donned it, but it was usually at a previous employer or in the military! I have yet to find a facility that has actually required ALL workers who would be expected to use an EEBA to demonstrate their ability to properly deploy and don the unit within the 15 seconds as stated by the manufacturer!
3) The units are not being inspected at any frequency, much less weekly
4) The units are not being flow tested annually
5) Cylinders/bottles are usually way past due on their Hydro – often times having NEVER been tested since their date of manufacturer. What’s odd, the SCBAs at these facilities and their cylinders are being managed perfectly, but these EEBA just fell thru the cracks
6) The facility is unable to provide any type of assessment to defend the model (e.g. usage time available) chosen
7) The facility is not issuing the units for areas of concern and when the EEBAs are stationed in these areas, personnel are not assigned their own EEBA when working in the area
8) Our friends in the Northern part of the country and Canada, almost always seem to want to store some units outside and in the winter time they are almost certain to exceed the minimum temp of 0ºF limit
If we are going to have these devices in our workplace and we are conditioning personnel to believe they will function when they need them, then we MUST use them properly, train ALL personnel on how to properly use them, and then inspect/maintain them to ensure they are ready when needed. Other than that, we should be giving them away at the next bass tournament as “boat anchors”!