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interchangability of scba bottles

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  • The nots so new FNG
    replied
    I have taken more time to review the actual NIOSH test procedure and the authority given to them to do this.

    They have authority to test only the complete assembly as provided by one manufacturer. They have, by law, no leeway to accept subassemblies provided by any other manufacturer, irregardless of the consquences. Basically, to be a NIOSH approved assembly, everything and I do mean everything has to be sole manufacturer supplied.

    What this means, you cannot change ANY part of the scba unit without violating NIOSH. You must get your batteries from the OEM manufacturer. You must get your cylinders from the OEM manufacturer. If you use extender belts for the waist belts - they must be OEM. Eyeglass inserts (including lenses) must be from the oem. Even RIT 'buddy breathing' hoses must be supplied by the manufacturer. This goes as far as any hardware such as screws used in the assembly process.

    In the documentation, NIOSH specificaly state that they cannot certify a subcomponent, provided by a sub contractor to the manufacturer submitting the unit for testing, even if its is identical in every way. It MUST come from one supplier.

    Is this really reasonable - well, no its not and even NIOSH has alluded to this. There is simply no area to allow for a question of functional requirements in the regulation they must follow. Its not that NIOSH isn't interested, its that they aren't allowed to delve into this. By the regulation that provides for the testing, the can only test assemblies as provided by single manufacturer. Until the regulation is updated, this can not change.

    So where does that leave everyone.

    If you do not use the SCBA exactly as given by the original manufacturer, you lose the NIOSH seal. Does the lack of a NIOSH seal matter - well, it depends on your state and OSHA rules. I personally believe that using non-OEM labelel cylinders (but made by the original supplier) would be viewed very differently that modifying the SCBA by using physically different parts.

    As for the question why department would even consider this - take a small department with 10 SCBA's. They have (at least) 20 cylinders for these. If you take an OEM cylinder to be around $1000 and the SCI to be around $500, then you are looking at a cost savings of $10,000. For that department, this question could be looked at as having several outcomes. They could go OEM, they could not have the $20,000 and lose SCBA's, they could go SCI and keep all of thier SCBA's, or they could go SCI and have money left to get TIC.

    The last option I gave above about getting a TIC might have great appeal to the adminstrators of said department. After all - every response about operational safety of using SCI vs OEM bottles said its a non-issue. Its only an administrative issue. To they - option A - administrativly no problem, option B - possible administrative headache but operationally, we now have a TIC which can have real impact.

    Leave a comment:


  • firepundit
    replied
    Originally posted by JTFIRE80 View Post
    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????
    Whether or not anyone on this forum can name such a department will have no bearing on the fact that you have openly recommended disregarding manufacturer's instructions and Federal certifications as well as "consensus standards " as Bob, used to call NFPA.

    Not very professional, in my opinion.

    I hope you are not in any position where you can expose your department to a law suit by the widow of someone you know. Then the real pros will be testifying in court.

    O.K. That was kind of harsh. But, there are other battles to be fought if you want to save money. Responsible ways.

    Leave a comment:


  • DeputyMarshal
    replied
    Originally posted by JTFIRE80 View Post
    But, you still can't answer the question that was asked. If you are not following the "code" or "law", then you are intentionally breaking it, plain and simple.
    First to fall, you mentioned 3 organizations. Only one of them creates laws and only indirectly at that.

    Secondly, intent requires knowledge. It's possible to break a law unknowingly with all the best intentions. There's a distinct difference between breaking the law unintentionally and doing so with the full knowledge of what you're doing.

    I can admit that my department doesn't follow every NFPA, NIOSH, OSHA, etc... regulation there is. Can you??
    Most don't. But then the ones that they're legally bound to follow are just the ones that are actually law. All of them should be following all of those and most certainly shouldn't be willfully breaking any of them.
    Last edited by DeputyMarshal; 04-12-2011, 08:19 AM. Reason: typo

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  • neiowa
    replied
    Originally posted by wvfire140 View Post
    are carins bottles niosh approved know
    They HAD NIOSH approval at the time when they made/sold/supported repair of their SCBA. When that stopped the NIOSH approval ended.

    So good on day Nogo the next.

    Luxfer and SCI are competitors, not relatives.

    Leave a comment:


  • JTFIRE80
    replied
    Originally posted by DeputyMarshal View Post
    I don't care to be a part of any that knowingly, intentionally, and regularly breaks the law. If you know they're intentionally breaking the law in one area, how many more ways are they doing it that you don't even know about? What kind of integrity does such a department and the people running it have?

    Sorry, I have no use for any department that unprofessional.
    But, you still can't answer the question that was asked. If you are not following the "code" or "law", then you are intentionally breaking it, plain and simple.

    I can admit that my department doesn't follow every NFPA, NIOSH, OSHA, etc... regulation there is. Can you??

    Leave a comment:


  • DeputyMarshal
    replied
    Originally posted by JTFIRE80 View Post
    For the naysayers out there, 1 question: Can you name one fire department that follows EVERY NIOSH, OSHA, NFPA, etc... code out there????
    I don't care to be a part of any that knowingly, intentionally, and regularly breaks the law. If you know they're intentionally breaking the law in one area, how many more ways are they doing it that you don't even know about? What kind of integrity does such a department and the people running it have?

    Sorry, I have no use for any department that unprofessional.

    Leave a comment:


  • JTFIRE80
    replied
    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????

    Leave a comment:


  • firepundit
    replied
    Originally posted by The nots so new FNG View Post
    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.

    Leave a comment:


  • Rescue101
    replied
    Originally posted by The nots so new FNG View Post
    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.

    Leave a comment:


  • The nots so new FNG
    replied
    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?

    Leave a comment:


  • wvfire140
    replied
    are carins bottles niosh approved know

    Leave a comment:


  • firepundit
    replied
    Originally posted by The nots so new FNG View Post
    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.

    Leave a comment:


  • DeputyMarshal
    replied
    Originally posted by The nots so new FNG View Post
    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...

    Leave a comment:


  • The nots so new FNG
    replied
    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.

    Leave a comment:


  • The nots so new FNG
    replied
    Originally posted by DeputyMarshal View Post
    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).

    Leave a comment:

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