Safety equipment industry warns against going outside the official SCBA supply chain
Firefighters rely on their self-contained breathing apparatus (SCBA) to work properly during an incident. Their lives often depend on it. However, that dependability is threatened and compromised by a permit issued by the Pipeline and Hazardous Materials Safety Administration (PHMSA). That’s why fire departments should always stay within the official supply chain when procuring their SCBAs — and replacement cylinders.
Trying to stretch the lifespan of an SCBA cylinder beyond its intended 15 years is a bad idea, say, manufacturers. And that limit is not an artificial “planned obsolescence” cycle. Instead, the 15-year lifespan is based on strict engineering, testing, and regulatory approval.
SCBAs take a beating year after year. They’re exposed to temperature and weather extremes (even up to 500 degrees Fahrenheit!), flame and water, and a constant cycle of use and repeated pressurization that come with day-to-day life in the fire service. Those conditions put tremendous stress on SCBAs, and those stresses take a toll over time.
“DOT-CFFC carbon composite cylinders for use in SCBA have thin aluminum alloy liners of between 0.060” and 0.090” thickness at the side wall, depending on the size and design,” said Scott Anderson, Luxfer. “If a cylinder is repeatedly subjected to pressure cycles to failure, then it will fail by the fatigue of the liner. In normal circumstances, the fatigue life of the cylinder is very conservative and well beyond the limits of use in SCBA service. However, if the liner is corroded, the number of fatigue cycles is severely reduced before failure by leakage. While a leak in the cylinder does not pose a threat of cylinder rupture, it can have severe implications if a firefighter loses air capacity and may run out of air during an operation.”
The SCBA has only one purpose: to keep a firefighter alive when the air in or around an incident is unsafe to breathe — whether due to smoke, heat, or other toxins and hazards — the SCBA enables the firefighter to breathe safe air from the cylinder and stay on task.
Pushing an SCBA cylinder beyond its 15-year certified lifespan puts the firefighter’s life at risk. Period. SCBA is designed for long lifecycles, and no regulations currently prevent their use beyond 15 years. Annual testing by authorized technicians helps to ensure the safety and integrity of the back frame, harness, pneumatics, and electronics components of the SCBA; however other components like the cylinder have different standards and regulations that define their lifespan.
The International Safety Equipment Association (ISEA) strongly recommends against procuring or using an SCBA cylinder that claims to be certified or requalified for extended use. In addition, beware of any stickers on the equipment that shows approval of reuse beyond the original 15-year limit. The manufacturer’s warranty is void beyond 15 years.
Further, the National Institute for Occupational Safety and Health (NIOSH) requires that the following “Cautions and Limitations” text be included on the product approval label: “Never substitute, modify, add or omit parts. Use only the exact replacement parts in the configuration as specified by the manufacturer.”
If an SCBA manufacturer is silent on or does not specifically allow the use of Modal acoustic emission (MAE)-requalified cylinders on an SCBA, such use violates OSHA regulations and voids the SCBA’s NIOSH certification. Specifically, the use of an MAE-requalified cylinder and/or a replacement valve on the cylinder violates OSHA regulations 29 CFR 1910.134(h)(4) and 1910.134(i)(9). Moreover, the use of a “rebuilt” cylinder valve voids the SCBA’s NIOSH certification.
The use of MAE-requalified SCBA and replacement cylinders are also problematic via National Fire Protection Association (NFPA) standards. See in particular NFPA 1500, Standard on Fire Department Occupational Safety, Health and Wellness Program, 2018 Edition (§ 7.10.1 and § 18.104.22.168); and NFPA 1852, Standard on Selection, Care, and Maintenance of Open-Circuit Self-Contained Breathing Apparatus (SCBA), 2019 Edition (§ 4.9 Technical Authorization — § 4.9.1).
PHMSA, part of the U.S. Department of Transportation, issued a special permit (DOT-SP 16320) in 2017 authorizing 15-year carbon-fiber reinforced, aluminum-lined compressed gas cylinders to be requalified for up to an additional 15 years in five-year increments. Users should note that the special permit states under the “Purpose and Limitations” that “The safety analysis performed in the development of this special permit only considered the hazards and risks associated with the transportation in commerce.”
Modal acoustic emission (MAE) testing was developed in the early 1990s and was allowed by PHMSA in 2015. The agency invested heavily in research in this area. However, ISEA has written to and met with PHMSA to explain why MAE is problematic for SCBA and why extending an SCBA or replacement cylinder beyond the manufacturer’s and PHMSA-approved original 15-year lifespan is dangerous. It also voids the original approval of the SCBA itself, potentially exposing the owner to liability.
It’s important to note that PHMSA’s Office of Hazmat Safety is responsible for ensuring the safe movement of hazardous materials by all modes of transportation. In fact, the agency does not have regulatory authority over SCBA.
As ISEA explained to PHMSA in an extensive 2019 letter: “There is a balanced regulatory structure for the safety of SCBA users and for the manufacturing, use, and maintenance of these devices. This structure includes OSHA, NIOSH, the National Fire Protection Association (NFPA), and notwithstanding DOT-SP 16320, PHMSA. In short, DOT-SP 16320 is a non-native invasive species harming the SCBA users in this safety and regulatory ecosystem.”
NIOSH made clear in February 2019 that without NIOSH review and approval, the use of MAE requalification testing to extend the service life of SCBAs is not compliant with NIOSH approval for those devices.1” (See footnote for full statement.)
MAE testing doesn’t identify certain types of imperfections that could compromise a cylinder’s integrity. However, cracks and other anomalies inside the tank can develop with repeated heavy-duty wear and tear.
Cylinders tested using the MAE process, as specified in DOT-SP 16320, cannot assess the full integrity of the cylinder for the demanding use seen in the fire service. MAE-testing outlined in DOT-SP 16320 does not evaluate the integrity of the aluminum liner. Yet the liner is exactly where failure occurs. In addition, visual inspection using CGA 6.22 will not catch cracks invisible to the eye but large enough for breathing air to escape.
Firefighting Profession’s Perspective
The IAFF wrote to NIOSH in 2018 expressing concern about USDOT’s special permit to Hexagon Digital Wave, allowing the company to extend the service life of certain carbon-fiber reinforced aluminum-lined cylinders.
In that letter, IAFF stated: “Our concerns center around the weight of the evidence that modal acoustic emission (MAE) testing can reliably predict whether or not a catastrophic cylinder failure will occur… Additionally, failure parameters for possible micro-fractures that may appear in the carbon fiber material wrapping would need to be determined. Currently, we are unaware of any peer-reviewed literature describing the methodology for determining these parameters.”
The IAFF added that, in addition to the high temperatures to which SCBAs might be exposed during firefighting incidents, as noted earlier, cylinders are typically stored for long periods at their rated pressure, sometimes at environmental extremes, which creates more strain on the vessels.
“These environmental conditions create stress on the interface area between the aluminum lining and the carbon fiber wrap,” IAFF’s letter explained. “Any detection of loss of this interface would be grounds for concern. Again, we are unaware of any peer-reviewed literature examining the MAE testing’s ability to detect this stress… At this time, the scientific and legal parameters have not been fully established for us to support extended service life for SCBA.”
For those in the fire service seeking a 30-year cylinder that’s safe, legally, and regulatorily compliant, a 30-year cylinder is available from Luxfer under permit DOT-SP 14232.
• Compared to 15-year cylinders, this 30-year cylinder has thicker carbon-fiber walls and a liner that can withstand more charging cycles.
• Buyers should note, however, that the special permit awarded to Luxfer for a 30-year cylinder requires a test at the halfway point.
When in doubt, or if you have more questions, always feel free to reach out to your SCBA manufacturer. They will be happy to answer any questions you have about your equipment.
Dan Glucksman is Senior Director for Policy at the International Safety Equipment Association (ISEA) where he leads the organization’s legislative and regulatory programs. Mr. Glucksman also contributes to ISEA’s standards development and member engagement programs.
1 “Without NIOSH review and approval of modified documentation, the use of MAE requalification testing to extend the service life of SCBAs that have reached the end of the service life indicated in the documentation provided by the SCBA manufacturer is not compliant with NIOSH approval for those devices.”
2 Compressed Gas Association, CGA C-6.2-2019, “Visual Inspection and Requalification of Fiber Reinforced High-Pressure Cylinders – 8th Edition”