interchangability of scba bottles

[DeputyMarshal]

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.

[JTFIRE80]

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??

[neiowa]

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.

[DeputyMarshal]

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.

[firepundit]

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.

[The nots so new FNG]

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.

[firepundit]

Well, what do you know:

http://www.cdc.gov/niosh/docket/revi...1/default.html

NIOSH is currently taking public comments on 42 CFR Part 84 until the end of the month. Follow the link and let them know your thoughts.

[Capt387]

Well, what do you know:

http://www.cdc.gov/niosh/docket/revi...1/default.html

NIOSH is currently taking public comments on 42 CFR Part 84 until the end of the month. Follow the link and let them know your thoughts.

Where do you get that? It plainly states directly in the link:

Public Comment Period
Interested persons or organizations are invited to participate in this process by submitting written views, recommendations, and data. Written comments on the document will be accepted through March 31, 2011 in accordance with the instructions below. All material submitted to NIOSH should reference Docket Number NIOSH-221. All electronic comments should be formatted as Microsoft Word and make reference to docket number NIOSH-221.

Comments will be accepted until 5:00 p.m. EDT on March 31, 2011

[firepundit]

Where do you get that? It plainly states directly in the link:

My bad. Should have been paying better attention.

[Rescue101]

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.



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.

The question was: DOES YOURS(follow ALL nfpa.Niosh and Osha)? T.C.

[DeputyMarshal]

The question was: DOES YOURS(follow ALL nfpa.Niosh and Osha)? T.C.

The answer is that it's an irrelevant question.

But, it if it'll make you feel any better: Of the three, OSHA is the only one that has regulatory authority. To the best of my knowledge, my department isn't intentionally violating any OSHA regulations.

[JTFIRE80]

Like I said in my original post, I would not use them in my department. I was simply pointing out the fact that there is no one out there that can follow every rule, regulation, standard, code, etc...

That said, I always look at the worst case scenario. If it goes to a lawyer, like almost anything can anymore, you will lose hands down. As was mentioned about the "consensus standards" (NFPA), you won't get a fine, but very well lose in a potential civil suit. In the eyes of the law, weather you know or don't know you are going against what is the consensus standard, you will be found at fault. Try to claim ignorance (which IMO is an excuse for laziness), and you will again be spanked.

Wasn't trying to start an argument, just stating that there are many different Acronym's that we should be following, but we can't follow them all.

[Rescue101]

The answer is that it's an irrelevant question.

But, it if it'll make you feel any better: Of the three, OSHA is the only one that has regulatory authority. To the best of my knowledge, my department isn't intentionally violating any OSHA regulations.

Not really. The point is VERY few depts are in 100% compliance will ALL rules and reccomendations. Mine included. Now the cylinder issues is another can of worms entirely but it still leads back to the big three regulatory agencies. T.C.

[RFDACM02]

There seems to be two issues here.
1. Can any other bottle be used with an SCBA other than the ones specifically tested and approved by the manufacturer?
Answer: Yes, in an emergency any replacement bottle certified for SCBA use may be used. This means the SCBA must start with an approved bottle in it and go back into service on the truck with an approved bottle. This alone proves some willingness of the regulatory bodies to accept another certified bottle for use. Otherwise there would be no interchangeability rules. One might be questioned as to whether buying spare bottles from another brand/not tested specifically with your SCBA, constitutes the emergency. I believe they intended the emergency to be for mutual aid situations.

2. Can a bottle be purchased without a valve and have the valve installed and be used as the same as the bottle tested with the SCBA system?
Answer: No. How can the manufacturer be responsible to guarantee the bottle if someone, other than their authorized service tech, installs the valve. Even when you use the same exact components (SCI bottle and Scott valve) if you're not certified to install the valve by Scott (an your aren't cause they don't allow it) then the bottle is not approved. In fact I think you'd fail to meet the second bottle emergency exception as well as the bottle itself wouldn't meet any SCBA manufacturers spec if they didn't certify the installation.

That's my take after asking these questions of many people over the years.

[JTFIRE80]

RFDACM02, for the most part spot on. Most manufacture's however, do train fire departments to be technicians for their respective brand. I am an MSA tech for my military unit. My fulltime employer also has about 15 firefighters that are indeed Scott technicians. This is usually done with larger departme ta where it is more cost effective to handle it, instead of sending items out all the time.