interchangability of scba bottles

[The nots so new FNG]

Do you really think there's a worthwhile cost savings from saving a few bucks buying unlisted generic cylinders and then mixing & matching them with brand name valve assemblies (either purchased or scavenged) which are now also unlisted as soon as you screw them into the wrong cylinder?

Seriously? And when an accident happens, as they always do, and the department is found in violation of fundamental OSHA regulation and open to expensive civil litigation for ndangering its members, will it be worth it? Will it be worth it to the individual who knowingly assembled the non-compliant unit for an illegal use? I don't think so.



The SCBA manufacturer does pay for the SCBA testing which certifies that the whole assembly as tested meets the NIOSH SCBA standards. They also hold the liability for the design if it's found to be flawed. They're the ones primarily at risk for any failure of the SCBA -- cylinder included.



Then I can only assume that you have no concern for your own exposure OSHA fines for willfull violations nor to both your personal liability nor your department's.

If you feels so strongly about this then, by all means, lobby to change the way NIOSH certifies compliance. But, until they change, it's foolish and irresponsible to suggest using generic cylinders for SCBA.

With all due respect - I believe you are ignorant on the mechanics and methods of how high pressure cylinders are made, tested and maintained.

The ONLY arguement I see for wanting an OEM cylinder is if there is a concern on the physical dimesions of the tank. IE - can it fit into the scba harness.

The Valve - is OEM. It is designed to mate with a cylinder made to a specific exemption standard (DOT paperwork).

The cylinder itself, irregardless of who makes it, must conform to the standard defined in the exemption paperwork. This governs things such as testing pressure, working pressure, hydro test procedures, threading and valve attachment, thread inspection and valve torque specs. There is lots more governing the working temperature, inspection procedures, defect tolerances etc but you get the jist of it.

Also - as a standard matter of maintence, valves are removed, inspected, serviced and replaced. This work is usually done by a Hydro shop so unless you explicitly ship everything back to the SCBA manufacturer - your arguements regarding this aspect are moot as well.

I am sorry - there a LOT of other industries using high pressure gas cylinders that don't have this requirement. Many understand that the key component to a high pressure gas cylinder is: A - the working pressure, B - the proper valve assembly and C - the physical dimensions. Manufacturer or reseller is not a criterea.

Many seem to take the NIOSH tested configuration to be absolute gospel and never to be altered without any common sense. As I said - you do realize that SCI is manufacture of almost all composite tanks in the US. You do realize who foolish it sounds to say only the SCI tanks who are branded and sold by XXX are safe to use. Its like saying the only light bulbs you can use in your Ford vehicle are the ones sold by Ford dealerships. If you want to stick to tanks - do you think hospitals only get tanks from the OEM for some of thier equipment or do you think they understand an AL 'D' tank is interchangeable irregardless of who you bought it from. Oh wait - most of those tanks are handled by gas suppliers who mix Luxfer and Catalina O2 tanks and don't worry about the stickers that may have been put on a tank for its 'certification' for use with a peice of equipment.

To those who don't see this - I pose this one more question. What battery do you use in your PASS device? Do you ensure that you use only the battery spec'd by the manufacture or do you use the commonly available 9V you can get readily? The NIOSH paperwork and SCBA paperwork (at least for MSA) requires the use of Duracell Procell batteries. If you don't use those, aren't you also in violation of the NIOSH rating???

You are right in one thing - as many people interpret the NIOSH test standards, using a tank outside the OEM stickered ones can make it a 'Non NIOSH' tested device. For many departments, mine included, the excess cost for meeting this is not worth it. An SCI tank is half the price of the MSA tank. For 20 tanks, that is 10,000. While some departments may not see that as a major cost, for many it is.

This is even further reinforced when you read the condition that says its OK to use a non-OEM tank under 'emergency' conditions. If its safe to do then, why is it not safe to do all of the time. I mean this is the case where we KNOW the user will enter an IDLH atmosphere right. This is the worst case scenario for its use and its safe enough then.

I don't fear this in a court of law. I believe you would have a VERY big uphill battle stating the brand of cylinder used in an SCBA was a causal factor. I don't believe the Jury would neccessarly agree with the SCBA manufacturers that the cylinder being SCI rather than MSA (and SCI) would in fact invalidate the NIOSH test - provided the the cylinder was made to spec. Again, we are talking cylinder only not cylinder and valve.

You are free to disagree and I don't personally care. I would expect to see this 'standard' adjusted in the next year or three as SCI is now selling tanks on the open market. Since they are the manufacturer, they have a lot of leverage with this. Honestly, if they wanted to be devious, they could move the MSA markings from the hydro label and it then it would be 'as tested' by MSA.

[WD6956]

Do you really think there's a worthwhile cost savings from saving a few bucks buying unlisted generic cylinders and then mixing & matching them with brand name valve assemblies.

Not to split hairs, but the difference between an SCI cylinder and one from Scott is not "a few bucks". For a 60 minute cylinder, It averages about $700. You can almost buy two 60 minute SCI cylinders for the price of one Scott.

For a 30 minute cylinder, the difference is about $300 each. Doing the math using the average price from a distibutor:

SCI: $600 each.
Scott: $900 each.

If you had $5,000 allocated for spare cylinders, you could get 8 SCI cylinders or 5 Scott's. Your money will go much farther.

[WD6956]

1/3 correct. There are three standards that are at play here NIOSH, OSHA and NFPA. Niosh standards are how SCBA are put together as a unit and how manufacturing must have the SCBA coming out of the plant. OSHA granted we all know their capabilities for levying a fine for not following a standard. BTW the SCBA fall under 1910.134. And NFPA

Thank you for the clarification.

[Rescue101]

The rules state the air bottle/tank/container/big round thing must be of the same manufacturer since they test the SCBA unit as a whole.

Personally - its BIG BS. This is a cash cow for the SCBA manufacturers. If it wasn't a cash cow, why then can the OEM tank manufacturer sell the same tank for 1/2 the price of the manufacturer?

I seriously question whether the 'difference' of that sticker would hold up in actual court proceedings. If the tank is made to the exact same specs (and marked as such by the DOT regs) and it uses a valve from the scba manufacuturer, it would he hard to prove a functional difference. You can't even claim an assembly difference since valves are removed every 5 years for hydro testing. You would even have a hard time proving that the NIOSH test result didn't apply. Remember - MSA/Scott does not do anything to the tank itself when they get it - if they did, it would invalidate the DOT exemption it was made under. They put thier valve on it, test the assembly and send it out. (SCI puts the NIOSH approval sticker on when they affix the DOT info). Its possible SCI puts the valves on (can't say either way).

I would not lose sleep using SCI bottles with MSA valves on MSA packs or SCI bottles with scott valves on Scott packs. For this to be an issue - a lot of VERY bad things would have to happen.

Yes they DO. T.C.

[Rescue101]

With all due respect - I believe you are ignorant on the mechanics and methods of how high pressure cylinders are made, tested and maintained.

The ONLY arguement I see for wanting an OEM cylinder is if there is a concern on the physical dimesions of the tank. IE - can it fit into the scba harness.

The Valve - is OEM. It is designed to mate with a cylinder made to a specific exemption standard (DOT paperwork).

The cylinder itself, irregardless of who makes it, must conform to the standard defined in the exemption paperwork. This governs things such as testing pressure, working pressure, hydro test procedures, threading and valve attachment, thread inspection and valve torque specs. There is lots more governing the working temperature, inspection procedures, defect tolerances etc but you get the jist of it.

Also - as a standard matter of maintence, valves are removed, inspected, serviced and replaced. This work is usually done by a Hydro shop so unless you explicitly ship everything back to the SCBA manufacturer - your arguements regarding this aspect are moot as well.

I am sorry - there a LOT of other industries using high pressure gas cylinders that don't have this requirement. Many understand that the key component to a high pressure gas cylinder is: A - the working pressure, B - the proper valve assembly and C - the physical dimensions. Manufacturer or reseller is not a criterea.

Many seem to take the NIOSH tested configuration to be absolute gospel and never to be altered without any common sense. As I said - you do realize that SCI is manufacture of almost all composite tanks in the US. You do realize who foolish it sounds to say only the SCI tanks who are branded and sold by XXX are safe to use. Its like saying the only light bulbs you can use in your Ford vehicle are the ones sold by Ford dealerships. If you want to stick to tanks - do you think hospitals only get tanks from the OEM for some of thier equipment or do you think they understand an AL 'D' tank is interchangeable irregardless of who you bought it from. Oh wait - most of those tanks are handled by gas suppliers who mix Luxfer and Catalina O2 tanks and don't worry about the stickers that may have been put on a tank for its 'certification' for use with a peice of equipment.

To those who don't see this - I pose this one more question. What battery do you use in your PASS device? Do you ensure that you use only the battery spec'd by the manufacture or do you use the commonly available 9V you can get readily? The NIOSH paperwork and SCBA paperwork (at least for MSA) requires the use of Duracell Procell batteries. If you don't use those, aren't you also in violation of the NIOSH rating???

You are right in one thing - as many people interpret the NIOSH test standards, using a tank outside the OEM stickered ones can make it a 'Non NIOSH' tested device. For many departments, mine included, the excess cost for meeting this is not worth it. An SCI tank is half the price of the MSA tank. For 20 tanks, that is 10,000. While some departments may not see that as a major cost, for many it is.

This is even further reinforced when you read the condition that says its OK to use a non-OEM tank under 'emergency' conditions. If its safe to do then, why is it not safe to do all of the time. I mean this is the case where we KNOW the user will enter an IDLH atmosphere right. This is the worst case scenario for its use and its safe enough then.

I don't fear this in a court of law. I believe you would have a VERY big uphill battle stating the brand of cylinder used in an SCBA was a causal factor. I don't believe the Jury would neccessarly agree with the SCBA manufacturers that the cylinder being SCI rather than MSA (and SCI) would in fact invalidate the NIOSH test - provided the the cylinder was made to spec. Again, we are talking cylinder only not cylinder and valve.

You are free to disagree and I don't personally care. I would expect to see this 'standard' adjusted in the next year or three as SCI is now selling tanks on the open market. Since they are the manufacturer, they have a lot of leverage with this. Honestly, if they wanted to be devious, they could move the MSA markings from the hydro label and it then it would be 'as tested' by MSA.

It is ALREADY in process. Since ALL Usa built airpacks come with a Luxfer or SCI cylinder, the only REAL difference,as you CORRECTLY stated, is in the label spun under the glass. It IS true that as it stands now,you have an unrated assembly with a generic SCI bottle even if it has Scott valve. SO, you have to make up your mind if you care to assume the liability or not. T.C.

[DeputyMarshal]

With all due respect - I believe you are ignorant on the mechanics and methods of how high pressure cylinders are made, tested and maintained.

I'm well aware of the process. That isn't the point. As I already wrote, if you object to the regulations as they stand, lobby the appropriate agencies to change them. Until they do change, however, it's a violation of OSHA regs to use generic cylinders with fire service SCBAs. Willfully violating those regs and getting caught will cost far more than is ever likely to be saved by taking shortcuts.

It's one thing to "look the other way" about a regulation that might only effect you personally, it's another to ignore regulations that affect other individuals as well as your whole deparment as an organization.

[The nots so new FNG]

I'm well aware of the process. That isn't the point. As I already wrote, if you object to the regulations as they stand, lobby the appropriate agencies to change them. Until they do change, however, it's a violation of OSHA regs to use generic cylinders with fire service SCBAs. Willfully violating those regs and getting caught will cost far more than is ever likely to be saved by taking shortcuts.

It's one thing to "look the other way" about a regulation that might only effect you personally, it's another to ignore regulations that affect other individuals as well as your whole deparment as an organization.

I'll ask one question. Can you cite a single instance where OSHA has made this citation for using a non-OEM bottle on an SCBA?

My department has been doing this for the past decade. Before my time on this department, we had had an a full blown OSHA investigation due to a serious injury and they did not seem to care about the bottles on our SCBA's. (an SCBA with non-OEM bottle was even involved). I was not a member when this happened so I will not comment on the details of the incident - only what I read in the reports. That report did not list a 'non-compliant' SCBA. It listed the make/model of SCBA and that it met NFPA 2002 standard.

No fines, just directives on how to correct other deficiences. The air bottles didn't make the list.

So - no, I am not losing sleep over using different bottles in air packs. (I think they were happy we had NFPA 2002 compliant air packs - there are departments near us that still don't have them - they have 1992 compliant packs).

[The nots so new FNG]

As an aside - SCI is part of Luxfer. Currently Luxfer makes the Al tanks and SCI does all of the composite tanks. They are one and same company as it pertains to the manufacturer information with DOT. You can tell this based on the 'arrow' manufactures symbol stamped on Luxfer and SCI tanks.

[DeputyMarshal]

I'll ask one question. Can you cite a single instance where OSHA has made this citation for using a non-OEM bottle on an SCBA?

No. And I'm not about to spend my time researching it. I do know that departments have been cited for mixing and matching branded cylinders which is a lesser violation of the same regulations. Either way, do you really want to hang your argument on the theory that, even though you know it's a violation, it's okay because hardly anyone gets caught?

My department has been doing this for the past decade.

Shame on them for playing games. No points for professionalism there...

[firepundit]

With all due respect - I believe you are ignorant on the mechanics and methods of how high pressure cylinders are made, tested and maintained.

With all due respect, it is not ignorance of how they are made but of case law. You will simply lose in court. Substitutions may be allowed in emergencies but knowingly subverting the NIOSH certification will lose. Other brands and styles are certainly allowed in an emergency, that is why they must have standard threads, CGA-347 or CGA-346. However, intentionally ignoring the manufacturer's recommendations greatly increases your exposure to a lawsuit.

And, while Sherwood might make most of the cylinder valves, not SCI or LUXFER, they supply proprietary valves to the SCBA builders; different o-rings, gauges, etc..

You can be as self-righteous as you want but will lose in court. So, don't go calling others ignorant when the lawsuits are already out there.

[wvfire140]

are carins bottles niosh approved know

[The nots so new FNG]

I will ask one simple quiestion.

First - we agree that as of now, the interpretation of the rules say you can't use non-oem cylinders.

Given that - what is the actual risk to an indivudual user who does use an SCBA with an SCI bottle instead of a SCOTT bottle but with SCOTT OEM valves? Not legal rules or departmental issue, but what is the actual risk to that single firefighter in his role.

Can you think of one?

[Rescue101]

I will ask one simple quiestion.

First - we agree that as of now, the interpretation of the rules say you can't use non-oem cylinders.

Given that - what is the actual risk to an indivudual user who does use an SCBA with an SCI bottle instead of a SCOTT bottle but with SCOTT OEM valves? Not legal rules or departmental issue, but what is the actual risk to that single firefighter in his role.

Can you think of one?

No.......as far as being operationally safe. T.C.

[firepundit]

I will ask one simple quiestion.

First - we agree that as of now, the interpretation of the rules say you can't use non-oem cylinders.

Given that - what is the actual risk to an indivudual user who does use an SCBA with an SCI bottle instead of a SCOTT bottle but with SCOTT OEM valves? Not legal rules or departmental issue, but what is the actual risk to that single firefighter in his role.

Can you think of one?

Operationally? None whatever.

[JTFIRE80]

Here is my take on this issue. I say use them. You may or may not get into trouble, mostly because it doesn't meet "regulation" or "code". Would they get used in my department? No, but I would use one.

For the naysayers out there, 1 question: Can you name one fire department that follows EVERY NIOSH, OSHA, NFPA, etc... code out there????