Last week I wrote about SCBA's being stored and used in low temperature environments and the special instructions that many manufacturers have developed (and require) the user to follow for such use. As usual, my article generated a lot of questions regarding SCBA's that are intended for "emergency use". So I thought it would be fitting to share my mental audit checklist I use when it comes to auditing a facility's emergency SCBA's. This may be old news to many, but based on the questions I have received some of this information may not be well known. All of these requirements can be found in 1910.134. I am sorry I am not able to do this for all countries, but keep in mind most industrialized nations have similar respirator requirements and if the country in which you are working does NOT, you should seriously consider implementing these OSHA requirements.
One of the most common deficiencies we find is related to
1910.134(h)(2)(ii) In addition to the requirements of paragraph (h)(2)(i) of this section, emergency respirators shall be:
1910.134(h)(2)(ii)(A) Kept accessible to the work area;
1910.134(h)(2)(ii)(B) Stored in compartments or in covers that are clearly marked as containing emergency respirators; and
1910.134(h)(2)(ii)(C) Stored in accordance with any applicable manufacturer instructions.
Why does OSHA require that "emergency respirators" be stored in covers that are clearly marked as containing emergency respirators? This is simply so that someone else does not use the respirators for purposes other than an emergency in order to ensure that the respirators will be maintained in a state of emergency readiness. I know it has happened to me before where we get to the emergency scene and we find that someone has helped himself or herself to our emergency equipment, most notably our SCBA's and failed to refill the bottles!!!! This is how I learned of this simple labeling requirement. I will also remind everyone of the low temperature storage requirements placed on us by the manufacturer(s) of most SCBA's; however, they have more storage requirements that need to be followed so be sure to check your user/owners manual(s).
Another widely unknown requirement is:
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.
What does this mean? It means that EACH MONTH, as we test the regulator and the low pressure alarm so as to comply with OSHA and manufacturer inspection requirements, we use up a small amount of air each month. Over several months of inspection/testing, it is only logical that the air pressure in the bottle will be reduced. OSHA has set the MINIMUM AIR pressure for emergency SAR's at 90% of the manufacturer's recommended pressure level. This means that we will have to "top off" our cylinders a couple of times a year EVEN WHEN THEY ARE NEVER USED. Many veteran OSHA CSHO's know the manufacturer's require these monthly regualtor and alarm tests and how they are to be conducted and therefore know that bottles that have sat idle for years and have never had to be topped off are NOT being inspected/tested PROPERLY EACH MONTH as required by BOTH the manufacturer and OSHA.
Many asked why 90%; where did OSHA come up with the 90%? Why not 95% or 75%? If we turn to the 1998 Preamble we can see OSHA's explanation as to why they set a minimum air supply at 90% for emergency SARs...
The final provision for recharging air and oxygen cylinders for SCBAs in paragraph (h)(3)(iii) is unchanged from proposed paragraph (h)(3)(i)(C). Although no commenters disagreed with this provision as proposed, a few commenters (Exs. 54-6, 54-220) asked OSHA to clarify the requirement that SCBA equipment be maintained in a fully charged state and recharged when the pressure falls to 90% or less of the manufacturer's recommended pressure level. By way of example, OSHA notes that if the manufacturer states that the cylinder is fully charged at 100 psi, the cylinder must be recharged when the pressure falls to 90 psi (i.e., 90% of the fully charged level). The 90 percent level was selected to ensure that sufficient air remains in the cylinder to allow emergency responders to perform their required duties in a contaminated or oxygen-deficient atmosphere and still have sufficient air available to escape from these conditions. The 90 percent level, and the requirement that cylinders be recharged once the pressure falls below 90 percent, was also recommended by the American Industrial Hygiene Association (Ex. 54-208).
I have a simpler explanation from a person who has spent thousands of hours using SAR's... The #1 limitation of an SCBA is the amount of air in the cylinder! By using a cylinder that is less than full, we are only making the #1 limitation a greater limitation.
Next - INSPECTION DOCUMENTATION for emergency use respirators is different than respirators that are "every day use". OSHA requires:
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.
So let's break this down:
1) we have to "certify" the inspection by DOCUMENTING:
- The date of the inspection,
- The name of the person who did the inspection,
- Any issues noted from the inspection, and the
- Required remedial action to correct the issues.
ALL of this DOCUMENTATION MUST then be tracked by a serial number or other means to identify the inspected respirator (including the breathing air cylinder). Now keep in mind that SCBA cylinders are NOT married to any one harness/regulator and thus it is IMPLIED that all our SCBA cylinders should have their own means of identification. So this means that EACH harness/regulator ensemble AND EACH cylinder must have some means to singularly identify them. For the cylinders I suggest using the manufacturer’s serial # that is prominently displayed on the cylinder, as this will be the number used to document the hydrostatic testing; so why have two different numbers associated with our cylinder testing/inspection program. The harness/regulator may not have a prominent serial number displayed and may require us to come up with our own labeling system. Make sure your means to label the harness ensemble is DURABLE, as these SCBA’s can see some extremely harsh environments. I have found that, while being EXTREMELY careful, etching a serial number onto a portion of metal on the harness ensemble works best. It does not have to look pretty – it just has to be legible and work! Also, make sure the harness number is visible with the cylinder in place as this makes the monthly inspection process more efficent.
I STRONGLY ENCOURAGE everyone to have an “Inspection SHEET” rather than using just an inspection tag like a fire extinguisher inspection tag. As stated above, we have to CERTIFY each inspection by DOCUMENTING FOUR (4) items and some of these items from time to time may require a substantial amount of writing and trying to do so on a tag like a fire extinguisher tag is just not conducive to a strong inspection and documentation program. I will take these inspections one-step further...
Include your SCBA's in your maintenance work order system (e.g. your CMMS). Treat each cylinder and harness/regulator like a piece of production equipment using it's serial number. Assign a 30-day PM schedule and include in the work-order the manufacture’s inspection instructions. I always just cut and pasted them from the users manual into the W.O. so it became part of every work-order issued and was my "maintenance procedure" for SCBA inspections (a little bit of PSM/RMP compliance assistance!!!). I could then track all my deficiencies and remedial actions using my W.O order system rather than creating a new inspection and documentation system. As for the cylinders, each cylinder would have another W.O. assigned for it's hydrostatic testing. This ensured that each cylinder would NOT miss it's hydro per the DOT required frequency. I also controlled who did the inspections to ensure that ONLY trained technicians could be issued the work order; so that when OSHA asked to see training records for those individuals who had conducted the monthly inspections I was ensured ONLY those who were trained completed any of the inspection work orders. Lastly I could sit at my desk and in less than 30 seconds audit the emergency SCBA inspection program! I even made these one of my safety leading indicators within my Process Safety Management Score Card and I did it all from my desk using the facility’s CMMS. Then I would assign one of my safety techs the monthly/quarterly task of conducting an audit (additional inspections) of the SCBA’s to ensure the monthly inspections were not being pencil whipped.
In closing, many may have already mastered these requirements, but our auditing and training experiences leads us to believe there are a large percentage of businesses that may not be meeting these basic storage and inspection requirements. I hope those that are just learing of these requirements will implement new , or revise their current inspection protocols to incorporate these requirements into their respirator and emergency management programs. If anyone has any questions please feel free to contact your local area OSHA office or me for assistance. Phone calls and e-mails to both OSHA and SAFTENG.net are FREE safety services!