NIOSH Asks For Public Comment On SCBA Life Extension - Call To Action!
NOW IS THE TIME TO MAKE YOUR VOICES HEARD - November 30th Deadline!!!!
The National Institute for Occupational Safety and Health (NIOSH) has posted an information statement regarding the approval of SCBA cylinder life extension to 30 years via Special Permit 16320. This SP has been issued to Digital Wave Corporation by the US Department of Transportation (DOT), who regulates the use and safety of pressure vessels in commerce.
The NIOSH information statement issued in August 2018 can be found at the below link:
As noted in this statement, NIOSH has published a docket seeking additional information and data about any safety problems documented by manufacturers or users, as well as any benefits offered by the service life extension program to end users. On October 1, 2018 NIOSH posted docket ID CDC-2018-0093 in the Federal Register seeking input from the public. Below is a link to this docket and public comment link:
Digital Wave Corporation, the value leader in SCBA cylinders, has helped fire departments save millions of dollars by life-extending expired or expiring SCBA cylinders. This technology allows for a cost effective and safe alternative to purchasing new cylinders. In addition to cost savings, this technology helps reduce landfill waste by limiting the number of discarded cylinders each year. There are currently thousands of life-extended cylinders safely being used in the market today.
With safety being of top priority, the DOT thoroughly researched the life extension process. The research program data that led to their SCBA life extension via Modal Acoustic Emission (MAE) can be found on their website (DOT Data Link). The MAE technology is also commonly used in many other market applications. These include testing of composite and metallic gas transport tubes, composite vessels used in life raft deployment, composite vessels used in stationary CNG/H2 fueling applications and composite vessels used in CNG/H2 fuel systems found in buses, trains, ships and automobiles. Each of these required approval from the DOT. MAE was adopted as a required inspection at time of manufacture and in-service for high pressure gas storage of Section X, Class 3 vessels by the American Society of Mechanical Engineers (ASME) and the National Board of Inspectors Code (NBIC). MAE is also used in many other diverse applications such as aerospace structural testing, mission critical pressure vessel research and spacecraft small particle impact detection.
The public has until November 30, 2018 to comment on the NIOSH docket. Of critical interest to NIOSH is to receive comments on the following questions:
1. Are users of DOT-CFFC cylinders that have been requalified for service life beyond 15 years, pursuant to the provisions of DOT-SP 16320, exposed to any elevated safety or health risk as a result of either the modal acoustic emission requalification testing itself or the service life extension? If so, identify the concern or concerns and provide substantive data, studies, references, and information to further characterize and/or quantify the concern.
2. Does the service-life extension offered by DOT-SP 16320 or the modal acoustic emission testing itself provide a benefit to either end users or institutional users (e.g., fire departments)? If so, please provide any relevant data, studies, references, or other corroborating information.
3. What factors do respiratory protection program managers consider in determining whether to replace an expiring cylinder with a new cylinder or requalify the expiring cylinder using modal acoustic emission testing?
4. In which industries and operations are modal acoustic emission-requalified cylinders currently being used?
We invite the public to share their comments and feedback. Click here to visit the webpage.