BY ROBERT E. DUNKEL II
In March, the National Institute for Occupational Safety and Health (NIOSH) completed its preincident inspection of the City of Worthington (OH) Division of Fire and EMS self-contained breathing apparatus (SCBA) maintenance program. It was the first such inspection for our department. We invited NIOSH to evaluate our department’s program and to make recommendations for improvement.
The evaluation consisted of interviewing fire department personnel associated with maintaining the SCBA, a review of the SCBA maintenance records, an evaluation of the compressed-air cylinder refilling station located in the fire station, and an examination of the mobile breathing air equipment.
Current SCBA maintenance programs are evaluated and compared with the respirator and SCBA maintenance requirements listed in the following recognized national standards:
- National Fire Protection Association (NFPA) 1404, Standard for a Fire Department Self-Contained Breathing Apparatus Program, 1996;
- NFPA 1500, Fire Department Occupational Safety and Health Program, 1997;
- Title 29, Code of Federal Regulations (CFR) 1910.134, known as “The OSHA Respirator Standard”; and
- American National Standards Institute, Inc. (ANSI) Z88.2 American National Standard for Respiratory Protection-1992.
These standards specify the minimum benchmark requirements all fire department respirator programs should strive to meet or exceed. Compliance with these standards is considered essential for maintaining SCBA in a condition that meets NIOSH certification requirements found in Title 42, Code of Regulations, Part 84, Subpart H, as well as NFPA 1981, Standard on Open-Circuit Self-Contained Breathing Apparatus for the Fire Service, 1997. Failure to maintain your SCBA in an approved condition voids the NIOSH approval until such time as each affected SCBA can be inspected, serviced, and returned to an approved condition.
RECOMMENDATIONS
Although the Worthington Fire Department SCBA maintenance program is quite good, the following areas were identified as those needing improvement to comply with the referenced national standards:
- Maintain records for each SCBA regulator, face piece, and cylinder at the department.
- Upgrade the department’s written standard operating procedures (SOPs) for managing various SCBA maintenance repairs and testing functions.
Procedures should be developed or expanded to address each of the following:
–SCBA maintenance training: Training requirements for all in-house and contract maintenance service personnel should be in writing.
–SCBA inspection: Develop SOPs to accompany existing periodic inspection checklists.
–SCBA maintenance: Duplicate or reference in department procedures SCBA manufacturer maintenance procedures.
–Air quality program: Develop written procedures to document the existing air quality program. The procedures should address compressor, purification system, fill station maintenance, and quarterly air sampling and analysis. Implement a record-keeping system.
–Recharging cylinders: Department SOPs should be conspicuously posted at the cylinder-refilling station and mobile refilling equipment.
–Record keeping: Document procedures for all record keeping.
–Identification of defective SCBA and removal from service: The department should ensure that its procedures specify how SCBA users are to identify and remove from service any SCBA in need of repair.
- Establish a preventive maintenance program to ensure regularly scheduled preventive maintenance is conducted on each SCBA at least annually.
Specific guidelines for determining and scheduling preventive maintenance actions can best be compiled with the assistance of the SCBA manufacturer. Follow the SCBA manufacturer’s recommendation for the frequency of complete overhaul. If the manufacturer has not provided recommendations, NIOSH recommends that SCBA assemblies be rebuilt every three years.
- Annually evaluate the effectiveness of the SCBA overall maintenance program.
These recommendations are based on the premise that all SCBA are life-saving devices that will perform only as well as they are maintained. Since they are expected to function and perform properly each time they are used, it is important that SCBA maintenance and inspection be given the utmost priority at the department level.
Copies of a peer review document, Respirator Maintenance Program Recommendations for the Fire Service, developed by NIOSH and published in the Fall/Winter 1997 issue of the Journal of the International Society for Respiratory Protection, are available on request from NIOSH. Included in the article are draft copies of generic standard operating procedures and record-keeping forms that will assist you in developing improvements to the overall SCBA maintenance program.
During the inspection, the NIOSH inspector also evaluated the oxygen-refilling station. Oxygen cylinders are typically refilled for use in oxygen resuscitators and other emergency medical equipment used to administer oxygen. OSHA Respirator Standard 29 CFR 1910.134 and NFPA 1404 do not specifically address these types of medical devices. However, safe handling practices dictate that the oxygen-refilling systems as well as the oxygen equipment be stored in a clean, dry, air-conditioned location that is locked to limit access only to those individuals who have been properly trained and qualified to work with oxygen equipment. All cleaning, repair, and refilling operations should be conducted using the appropriate special tools that are clean, maintained, and dedicated only for use on oxygen equipment.
NIOSH Fire Fighter Injury Report 98F-23, Oxygen Regulator Flash Severely Burns One Fire Fighter-Florida, and the joint FDA and NIOSH Public Health Advisory, Explosions and Fires in Aluminum Oxygen Regulators, both contain a number of recommendations on safe procedures for handling and filling portable oxygen cylinders. Both documents address special precautions that should be taken for oxygen cylinder filling stations. The Compressed Gas Association pamphlet CGA G-4 Oxygen (1996 revision), especially Chapter 4, and NFPA 53, Guide on Fire Hazards in Oxygen-Enriched Atmospheres, 1994, are also excellent sources of information on oxygen cylinder storage and safe handling procedures.
Our department’s SCBA and Safety Committee is currently integrating the NIOSH recommendations into our SOPs, maintenance procedures, and policies and expects to have this work completed by the end of the third quarter of this year.
Departments can request a preincident SCBA inspection by contacting the NIOSH Respirator Branch at (304) 285-5907 or by fax: (304) 285-6030.
ROBERT E. DUNKEL II is a 27-year veteran of the City of Worthington (OH) Fire and EMS, where he serves as captain and head of the Health and Safety Division. He is also an 18-year veteran and assistant chief of the Genoa Township Volunteer Fire Department. He has an associate’s degree from Columbus State Community College and a bachelor’s degree from the University of Cincinnati and is a graduate of the Ohio State Fire Chief’s Academy and the National Fire Academy Executive Fire Officer program. An Ohio state-certified instructor, he is an associate instructor at the Ohio State Fire Academy.
