Rebuttal to SCBA Stakeholders Life Extension Statements
Updated: Oct 12, 2018
The statements issued by stakeholders in the SCBA market have inaccuracies in them that must be addressed. The Department of Transportation, Pipeline and Hazardous Materials Administration (PHMSA) has an in-depth knowledge of extended life SCBA cylinders based on several years of studies and hundreds of cylinders tested that allowed them to make the determination that cylinders can be safely used beyond 15 years. The inaccuracies in stakeholders’ statements trivialize the work performed by DOT to help benefit the public.
Luxfer’s life extension statement, which is quoted in many SCBA manufacturers’ statements, can be found at the web address below:
Clarifications and corrections are provided below.
1. “Luxfer Gas Cylinders, the world’s largest manufacturer of carbon composite cylinders used in self-contained breathing apparatuses (SCBA), has not been involved with the new life-extension program”. Luxfer was invited to Digital Wave in 2013 and visited to observe the testing protocol. They eventually chose to not participate in the testing, with no explanation given.
2. “The special permit issued to Digital Wave specifically requires that the original special permit marking of each cylinder requalified by means of MAE testing be covered and replaced with “DOT-SP-16320””. This requirement was removed from DOT SP-16320 in October of 2017. No changes are made to any labeling, including special permit numbers and part numbers.
3. “Luxfer 15-year SCBA cylinders are designed and approved in the U.S. (Special Permit 10915) and Canada for a 15-year service life”. DOT approves the life of all cylinders that are transported over-the-road. In the original design document that SP 10915 cylinders were designed and manufacture to (DOT-CFFC Design Standard), a provision for 30-year life was provided. In granting SP 16320, PHMSA issued an approval that allows the life of these cylinders to be extended up to 30 years from the date of manufacture, as allowed per the DOT design document. DOT PHMSA grants these approvals, not the manufacturer.
4. “Luxfer cannot accept responsibility or liability for use of Luxfer-manufactured cylinders beyond the 15-year service life for which they were marketed, nor does the Luxfer cylinder warranty extend beyond 15 years”. Obviously Luxfer will not accept liability, nor warranty these cylinders, nor should they, as they have chosen to not participate in this life extension approval. Digital Wave, as any reputable business would, warranties their product and carries liability insurance per the market requirements. Digital Wave has been in the cylinder requalification business via seamless steel and aluminum DOT cylinders for 18 years, and our ultrasonic examination (UE) systems have inspected over 12 million cylinders – so Luxfer and Digital Wave are comparable in size when the total number of cylinders responsible for are looked at.
5. “30-year Luxfer SCBA cylinders already available’. If one reads the fine print, these are still 15-year cylinders, but could become 30-year cylinders with testing at specific service life intervals, identical to the protocols put in place for the DOT-CFFC cylinders that Luxfer chose not to exercise. To date, the only DOT approved 30-year cylinders are cylinders that are requalified via DOT SP-16320.
Digital Wave Corporation maintains a position of willingness to incorporate all key stakeholders in its effort to safely life extend DOT–CFFC cylinders. We feel that First Responder budgets should be used to increase the safety of personnel, not replace hardware that still meets all government requirements.
For more information:
Mark E. Anderson, Director Sales and Marketing, Digital Wave Corporation Telephone: 303-790-7559 | firstname.lastname@example.org
Dr. Brian Burks, VP Engineering, Digital Wave Corporation Telephone: 303-790-7559 | email@example.com
About Digital Wave Corporation:
Digital Wave Corporation is a privately held manufacturer of ultrasonic examination (UE) cylinder testing equipment, modal acoustic emission (MAE) testing equipment and a provider of associated inspection services. With applications worldwide, Digital Wave and its partners serve government and private clients in the compressed gas, pressure vessel and cylinder industries. Applications include all metallic and composite pressure vessels from low to ultra high pressure applications.