Let's start with a quick quiz to test our knowledge of the manufacturer's expectations of their equipment.

1) What are the three (3) different types of inspections that an Emergency SCBA must under go?

Bonus Question related to #1:  Name the inspection/testing frequency for an SCBA cylinder that is composite fiber wrapped?

2) What test must be conducted on a LEVEL A suit on an annual basis?

Bonus Question related to #2: How long must this test last?

3) What test/inspection is required on our sample pumps used with colormetric tubes?

Bonus Question related to #3: What is the frequency of this test/inspection?

Did you make a 100%?  Or did I spark your curiosity?  If your curiosity is sparked, I hope you enjoy this article and mostly I hope it helps your team's response readiness.

I am a big fan of setting up my ER equipment in my Centralized Maintenance Management System (CMMS).  Am I crazy?  Well some say yes, as it is not required by OSHA or EPA.  Not so fast on the “OSHA/EPA does not require it” statement!  Yes, it is true OSHA/EPA inspectors will not ask to see your CMMS contents, but they will ask for your inspection records of your ER equipment!  With an extensive response capability, it is nearly impossible to maintain a high level of compliance when using the old paper system we have used for 30+ years!

Can anyone guess how many inspections there could be just within the Emergency Response Plan?  My last facility where I had 12 covered processes with flammable liquids, flammable gases, and toxics, we had over 1,000 items that required a monthly inspection.  Another 200 required a quarterly inspection and another 70 that required an annual inspection/test.  PLEASE keep in mind that EACH ONE of these inspections is SPECIFICALLY REQUIRED by OSHA or EPA and/or the manufacturer of the equipment (which OSHA will hold us to meet these manufacturer recommendations).  With all of these required inspections and with today’s technology it just makes good business and compliance sense to have these inspections/tests integrated into our CMMS.

How many would agree with me when I claim that for each inspection done, by on-site personnel or contractors, there needs to be a written procedure?  Now I call these MI procedures and have them in my Mechanical Integrity maintenance procedure system so that they are reviewed annually and are controlled documents.  I use my CMMS work order system to publish my procedures when a work order is issued and they even contain a checklist for each piece of equipment so that the inspector is signing off on each line item of the checklist.

So what types of equipment should be in our ER Preventive Maintenance Program and what are the frequencies?  PLEASE remember this is NOT meant to be an ALL inclusive list as some facilities will have more equipment than this and some will have only a few items, but this article is meant to be a starting point for those looking to improve their response readiness.

As I said, this is just a sampling of the emergency equipment that may be found at a facility that has an active ER team.  Now I would like to discuss some of the specifics of these tests and inspections.  All too often we find that facilities are doing “visual inspections” on PPE when MUCH MORE is required.  For example, what is required for our Emergency SCBA’s each month?  Is this just a visual inspection?  Absolutely not!  A visual inspection will NOT even meet the minimum requirements set in 1910.134, which by the way include:

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

1910.134(h)(3)(i)(C) Emergency escape-only respirators shall be inspected before being carried into the workplace for use.

1910.134(h)(3)(ii) The employer shall ensure that respirator inspections include the following:

1910.134(h)(3)(ii)(A) A check of respirator function, tightness of connections, and the condition of the various parts including, but not limited to, the facepiece, head straps, valves, connecting tube, and cartridges, canisters or filters; and

1910.134(h)(3)(ii)(B) A check of elastomeric parts for pliability and signs of deterioration.

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.

1910.134(h)(3)(iv) For respirators maintained for emergency use, the employer shall:

1910.134(h)(3)(iv)(A) Certify the respirator by documenting the date the inspection was performed, the name (or signature) of the person who made the inspection, the findings, required remedial action, and a serial number or other means of identifying the inspected respirator; and

1910.134(h)(3)(iv)(B) Provide this information on a tag or label that is attached to the storage compartment for the respirator, is kept with the respirator, or is included in inspection reports stored as paper or electronic files. This information shall be maintained until replaced following a subsequent certification.

And one more I like to add to my inspection checklist is…

1910.134(h)(2)(ii)(B) Stored in compartments or in covers that are clearly marked as containing emergency respirators;

So do I now have you convinced that a written procedure and checklist, as well as training, are necessary for these inspections?  Also PLEASE take notice of the OSHA requirement in 1910.134(h)(3)(iv)(A) that requires a serial number or other means of identifying the inspected respirator.  In reality, both the cylinders and the harness/regulator need to have their own ID #’s as cylinders and harnesses/regulators are interchangeable.  We must also maintain this documentation with the respirator or in electronic files (e.g. CMMS).  There is also a HUGE advantage of using the CMMS, as we can actually trend the inspection data and identify downward trends before failure of the SCBA; this is very hard to do and very time consuming when done by paper.

Here is an auditing trick for you auditors reading this…

if a facility has SCBA’s but does not have a breathing air compressor to fill cylinders, ask when the last time the cylinders were filled.  If they say over 6-8 months ago, there is a VERY GOOD chance the inspections are NOT meeting the OSHA or Manufacturer’s requirements.  We know this because when the monthly inspection is done per the standard and manufacturer requirements we use a small amount of cylinder breathing air each time.  After about 6 -8 months, the cylinder pressure will drop below the 90% mark (OSHA minimum) and will require a top-off to get it back to its full charge.

As for a written procedure, I highly recommend that you use the SCBA manufacturer’s operations/maintenance manual instructions.  We can just rely on a copy of the operation/maintenance manual being with the unit(s) or as I liked to do, cut and paste and put the information into my CMMS MI procedures.  I absolutely feel that an inspection checklist with the specifics for each line item be included so that the inspector has CLEAR guidance on PASS/FAIL criteria for EACH item being inspected.

Along these same lines, we have to have some type of reminder (the reminder is not a code requirement!) so that we do not miss a cylinder hydro test date.  These hydro tests are often overlooked by the users, but rest assured most OSHA CSHO’s know this!!!  By assigning a cylinder part number to each cylinder we can easily assign that cylinder a 3 or 5 year test schedule as required, based on the type of cylinder.  But speaking from experience, we need to make sure all of our cylinders do NOT come due for their test in the same month!  We want to stagger these, as often times for those remote facilities, these hydro tests will require us to ship the cylinders to a testing facility which will add time the cylinder is out of service.  We want to maintain at least 6 SCBAs and spare cylinders in service at all times as the bare minimum, so we just don’t want to be caught with the need to get all of our cylinders tested within the same month.  For facilities with dozens and dozens of SCBA’s and many spare bottles, many of different construction, I always had my cylinders staggered where each month I had 2-3 cylinders out of service for hydrotest.  But I will admit, with 50 spare cylinders of three different types of construction and three different hydrotesting schedules it would have been impossible to maintain 100% compliance with these hydro test.  Often times, we had no idea which cylinder was at which location, so we would have to go find the cylinder.  With the CMMS, we assigned the Work Order to the location and when the inspector identifies the cylinder #, he/she knows then that the cylinder is due for it’s hydro and as part of their monthly inspection, they change the cylinder out with one that had just been hydro’ed and then we have the cylinder due for it’s test ready to be shipped.

Here are some examples of a manufacturer inspection/testing procedures:

DuPont Level A Suits (not an endorsement of Dupont products – but it is the only suit I will wear!)

PLEASE note that DuPont has changed their schedules!!!!  Pressure test (they call it “inflation test) is no longer required upon receipt (although I still recommend it) and annually, but now it is AFTER EACH USE and annually.  They also require us to change the Level A suit exhaust valve(s) every two years.  Is everyone who uses the DuPont bran Level A suits meeting this schedule?  We should number our suits and have them in CMMS as well so that we can track which suits have been through their annual pressure test and when they are due for their valve replacement.  I would also like to add that these pressure tests are very specific and require some special equipment and fittings.  CLICK HERE to see the DuPont Test kit pressure testing procedures.  AN IMPORTANT NOTE regarding LEVEL A suits - all of the brands that I know and train with NOW RECOMMEND the suits NOT be used after FIVE (5) years of service.  This is a "manufactuer's recommendation" for the maintenance of thier product and those of us in the PSM/RMP world know this means it is NOT just a recommendation, but a mandatory deadline.  Much like compostite SCBA cylinder now have a 15-year expiration schedule, regardless of thier hydro test results!

Scott SCBA (not an endorsement of SCOTT products, but it is my preferred brand, although MSA is right behind SCOTT).

REGULAR OPERATIONAL INSPECTION

The following procedure shall be used when you first receive the respirator and for daily or periodic inspection of the respirator. Respirators in regular use must be inspected at the start of each use period and during cleaning after each use. Respirators maintained for emergency use must be inspected as frequently as required to assure the respirator

will function properly when required. The US Labor Department (OSHA), pursuant to 29 CFR 1910.134, requires at least monthly inspection of respirators maintained for emergency use. NIOSH recommends an inspection for cylinder pressure at least weekly. The condition of storage at your location or the regulations which apply to your respiratory protection program may require more frequent periodic inspections.

IF ANY DISCREPANCY OR MALFUNCTION IS NOTED DURING THE INSPECTION, DO NOT USE THE RESPIRATOR. REMOVE THE RESPIRATOR FROM SERVICE AND TAG IT FOR REPAIR BY AUTHORIZED PERSONNEL.

INSPECTION OF THE RESPIRATOR

1. Inspect the complete respirator for worn or damaged components.

a) Inspect hoses and rubber parts which exhibit cracking, splitting, or brittleness.

b) Inspect harness webbing for cuts, tears, abrasion, fraying, or indication of heat of chemical damage.

c) Check all buckles and fasteners for proper operation.

d) Check the cylinder retention system for damage and for proper operation.

e) Verify that the respirator has been properly cleaned.

2. Inspect the Pressure Reducer for damage.

a) Verify that the Pressure Reducer is clean and that all vent holes on the Pressure Reducer are clear and free of obstructions.

b) Verify that the Pressure Reducer is securely mounted to the quarter-turn mount on the backframe.

3. Remove the breathing regulator from the facepiece by pulling back on the regulator retaining latch and rotating the regulator ¼ turn. Inspect the breathing regulator for damaged or missing components.

a) Verify that the regulator gasket is in place around the outlet port of the regulator. Inspect the gasket for rips or damage that may break the seal.

b) Verify that the purge valve (red knob) is not damaged and turns smoothly one-half turn from stop to stop.

INSPECTION OF THE BREATHING AIR CYLINDER

1. Visually inspect breathing air cylinder and valve assembly for physical damage such as dents or gouges in metal or in composite wrapping. Cylinders which show physical damage or exposure to high heat or flame, such as paint turned brown or black, decals charred or missing, pressure gauge lens melted or elastomeric bumper distorted, and cylinders which show evidence of exposure to chemicals such as discoloration, cracks in the cylinder or the composite wrapping, peeling of the outer layers of the composite wrapping and/or bulging of the cylinder wall, shall be removed from service and emptied of compressed air.  Publications on compressed gas cylinder inspection procedures are available from Compressed Gas Association Inc., 1725 Jefferson Davis Hwy., Suite 1004, Arlington, VA 22202 (703-412-0900).

2. Check the latest cylinder hydrostatic test date to ensure it is current. The date of manufacture marked on the cylinder is also the date of the first hydrostatic test. All breathing air cylinders used with SCOTT ACS SCBA’s must be visually inspected regularly and hydrostatically tested at the required intervals by a licensed cylinder retester. Intervals for hydrostatic testing are established in the appropriate US Department of Transportation (DOT) specification or applicable DOT exemption, or in the appropriate Transport Canada (TC) Permit of Equivalent Level of Safety. Refer to the current revision of Safety Precautions for AIR-PAK Cylinders, SCOTT P/N 89080-01, available on request from SCOTT Health

and Safety. Composite fiber overwrapped cylinders must be tested up to their maximum life which, at the time of the publication of this instruction, is 15 years from the date of manufacture. It is the responsibility of your organized respiratory protection program to arrange for visual inspection and hydrostatic testing of cylinders by a licensed retester.

3. Check for damage of the cylinder valve hand wheel and the threads on the cylinder valve outlet.

4. Check the relief valve (burst disc) for damage or dirt.

5. Check the cylinder pressure gauge for “FULL” indication. If cylinder pressure is less than “FULL,” replace with a fully charged cylinder.

INSPECTION OF THE FACEPIECE

Examine the facepiece assembly for damaged or worn components.  The facepiece must be complete and in serviceable condition with no worn, loose, or damaged components.

Inspect the facepiece as follows:

1. Inspect the facepiece seal and other rubber components for deformation, wear, damage, or cracks.

2. Inspect the lens for cracks, gouges, scratches, or any condition that could impair the operation of the facepiece or the user’s vision.

3. Inspect the lens frame or bezel for damage such as cracks or distortion.

4. Check that all lens frame retainers or bezel screws are present and installed correctly.

5. Check that all harness anchors are present and operating properly.

6. Inspect the head harness for correct installation with all straps oriented correctly.

7. Inspect the head harness for damage or worn components.

8. Inspect the voicemitters for dents or damage. Verify that the voicemitters are properly installed and secure in the voicemitter ducts.

9. Inspect the nose cup for cuts or damage. Also look for any signs of damage to the facepiece port side of the nose cup where the regulator attaches.

10. Check that the nose cup is properly seated between the flanges of the voicemitter ducts. See FIGURE 4.

11. All SCOTT facepieces used with this respirator may be fitted with a nose cup. Verify that the Nose Cup is properly installed for the model of facepiece being used. A Nose Cup is standard on the SCOTT AV-2000®, Weld-O-Vista, and AV-3000® full facepieces.

a) SCOTT AV-3000 Facepieces are available with two different styles of nose cup: a BLACK Nose Cup which fits behind the face seal, and a GRAY Nose Cup which fits in front of the face seal. The BLACK Nose cup must be fitted BEHIND the Face Seal as shown in FIGURE 5. The GRAY Nose Cup must be fitted IN FRONT OF the Face Seal as shown in FIGURE 6.

b) The AV-2000 and the Weld-O-Vista, the Nose Cup always goes BEHIND the face seal REGARDLESS of the color of the nose cup. See FIGURE 7.

12. Verify that the facepiece is clean.

13. Adjust the head straps to the full outward position.

OPERATIONAL INSPECTION

1. Fully depress the center of the air saver/donning switch on the top of the regulator and release.

2. Slowly open the cylinder valve by fully rotating knob counterclockwise.  The whistle alarm shall actuate and then stop. There shall be no airflow from the facepiece

3. Don the facepiece or hold the facepiece to the face to effect a good seal. Inhale sharply to automatically start the flow of air. Breathe normally from the facepiece to ensure proper operation.

4 Remove facepiece from face. Air shall freely flow from the facepiece.

5. Fully depress the center of the air saver/donning switch on the top of regulator and release. The flow of air from the facepiece shall stop.

6. Rotate purge valve 1/2 turn counterclockwise (pointer on knob downward). Air shall freely flow from the regulator.

7. Rotate purge valve 1/2 turn clockwise to full closed position (pointer on knob upward). Airflow from regulator shall stop.

8. Push in and rotate cylinder valve knob clockwise to close. When cylinder valve is fully closed, open purge valve slightly to vent residual air pressure from system. The whistle alarm shall actuate as the pressure drops below approximately 1/4 full. When airflow stops, return purge valve to the fully closed position (pointer on knob upward).

Draeger and Sensidyene Tubes

Do your responders use Draeger or Sensidyne tubes in their recon responses when trying to determine the chemical involved?  If you have these in your equipment inventory, did you know that the tubes have expiration dates? If you knew this, consider your knowledge advanced, as the number of challenges I get regarding this still amazes me (even when the expiration date is stamped on the tube container).  Now for the $64,000 question… when was the last time you had the sample pump calibrated?  No I am not joking!  Here it is straight from the manufacturers: 

Sensidyne CLICK HERE,

Drager CLICK HERE. 

Although it is not made clear by either manufacturer as to the frequency of these calibration/test, the product reps will admit when pushed for a frequency that it should not extend beyond one year.  BE VERY CAREFUL believing the brochures, as BOTH of these brands claim “no calibration” of their pumps.  I have not bought any of their pumps in the past 5 years, so maybe their new pumps actually require no calibration, but I would be very hesitant to believe a device used to measure chemical concentrations would not require any type of calibration at some set frequency.

How many of us can say our Emergency Response PPE inspection/testing program is this thorough?   I kid you not, this is what is REQUIRED of us when we have an emergency response team that falls under 1910.120!  We may use different brands, but if the brand sells products that are NIOSH certified respirators and Level A suits that meet ASTM testing requirements, these types of inspections and testing will be REQUIRED at the stated frequencies.    

Lastly, PLEASE ensure that those employees or contractors that will be doing these inspections have been trained in the inspection/testing procedures.  When things get ugly after an incident involving emergency responders, OSHA will get serious about these inspections and will want to see the qualifications of those doing the inspections and testing.  Be VERY careful hiring a contractor and thinking the contractor can do these inspections better than our own personnel.  Some contractors have a lot of experience with certain brands and ZERO EXPERIENCE with your brand(s), so be sure to evaluate the contractor’s capabilities based on your needs.  I was never a big fan of contracting out the monthly inspections, as I have always felt that having the people who will rely on the equipment should have some level of accountability in their inspection and readiness.  Now when it comes to the hydro testing, flow testing, foam testing, etc. it is imperative that we use highly qualified personnel and often times it is just to prohibitive to maintain the equipment and training in-house so it makes sense to use qualified contractors for these tests.

Hope this article has sparked some interest and helped you identify some opportunities for improvement in your emergency response readiness.