Letter to All Interested Parties
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Issue Date: March 11, 2003
From: Roland J. Berry Ann, Branch Chief, Respirator Branch, National Personal Protective Technology Laboratory
Subject: Upgrade of Previously-Deployed SCBA Configurations to CBRN Approval Status
This letter is to inform manufacturers that NIOSH will immediately begin accepting extension of approval applications for the evaluation of components and procedures to upgrade previously-deployed (field-deployed) NIOSH-approved Self Contained Breathing Apparatus to CBRN-approved configurations. The purpose of this program is to:
- test and evaluate retrofit kits used to upgrade field-deployed SCBA
- assure upgraded SCBA's comply with approved CBRN SCBA configurations
- assure the quality of the components and procedures used to upgrade previous versions of the SCBA establish the CBRN-approved configuration.
NIOSH announced plans to begin accepting applications to test and evaluate self-contained breathing apparatus (SCBA) for use against chemical, biological, radiological, and nuclear (CBRN) agents in a December 28, 2001, NIOSH Letter to All Respirator Manufacturers. Since January 2002, NIOSH has been processing applications for CBRN SCBA approval in accordance with the requirements identified in the December 28, 2001, NIOSH letter. Approvals for CBRN SCBA have now been issued and applications for approval to this protection are expected to continue. Both manufacturers and users have expressed the desire and need to upgrade equipment placed in service prior to issuance of the CBRN approval. NIOSH believes the CBRN SCBA Retrofit Kits will greatly increase the number of emergency responders who are afforded the increased protection provided by the NIOSH-approved CBRN SCBA respirators. Because of this, NIOSH will immediately begin accepting applications to test and evaluate CBRN SCBA Retrofit Kits.
Requirements for the CBRN SCBA Retrofit Kit Program
- Retrofit of field-deployed SCBA to the CBRN protection must be performed by manufacturer-trained and authorized technicians, who ensure the upgrades comply with the approved CBRN-SCBA configuration, quality assurance and performance requirements.
- The CBRN SCBA Retrofit Kit must, as a minimum, contain the following:
- CBRN SCBA Retrofit Kit Instructions,
- Replacement components, parts, materials, and operation instructions required to upgrade the SCBA's configuration to the approved CBRN configuration level,
- Registration materials for recording SCBA information as required by the manufacturer,
- CBRN SCBA Retrofit Approval Label (See Attachment A).
- As a minimum, Retrofit Kit Instructions must include:
- Identification of minimum technician qualifications, i.e., who can perform the retrofit and the level of manufacturer training required.
- Information to identify specific SCBA models that are capable of being retrofitted to the CBRN SCBA configuration as determined by the manufacturer,
- Identification of the requirements for inspections and operational tests of the SCBA prior to performing the retrofit that are required to verify the SCBA complies with manufacturer quality and performance specifications for SCBA's eligible to be retrofit,
- Detailed procedures for replacing components, parts, and/or materials required to establish the CBRN SCBA configuration,
- Guidance concerning the CBRN SCBA operating instructions and differences from normal SCBA operating instructions,
- Post retrofit inspections and tests required to verify work has been performed properly and that the CBRN SCBA operation is in accordance with NIOSH, NFPA, and the manufacturer requirements. As a minimum, the post retrofit inspection and test must verify leak tightness of assembly and components, positive pressure (static face piece pressure), exhalation resistance, bypass function, remaining service life alarm operation, pressure gauge accuracy, and flow performance,
- Directions for installation of the NIOSH CBRN SCBA Retrofit Approval Label.
- The application must include the quality assurance provisions that will identify the resulting configuration and protections for each SCBA updated under the CBRN SCBA Retrofit Program.
- The application shall include two CBRN SCBA Retrofit Kits and two NIOSH certified NFPA 1981, 1997 Edition or 2002 Edition, compliant SCBA's. The installation of the CBRN SCBA Retrofit Kits may be performed by a manufacturer trained and authorized technician in the presence of NIOSH representatives or prior to submission, with a notarized statement certifying the CBRN SCBA Retrofit Kit requirements have been followed for installation of the submitted SCBA's. The two SCBA's should be supplied from a metropolitan fire department and must be representative of the oldest SCBA's remaining in service under the NFPA edition under which they were listed as compliant. The application is to include a description of the estimated frequency of use for the submitted SCBA's since the being placed into service, and how this has been determined to be typical of the model's normal firefighter usage. The submitted SCBA will be tested and evaluated to the special tests for Chemical Agent Permeation and Penetration Resistance Against Distilled Mustard (HD) and Sarin (GB) identified in the December 28, 2001 NIOSH letter.
Procedures for submitting an extension of approval application for procedures to upgrade previously-deployed (field-deployed) NIOSH-approved Self Contained Breathing Apparatus to CBRN-approved configurations are identified in Attachment B. The required NIOSH fee is $10,000.