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NIOSH Conformity Assessment Notice

Subject: Summary of the Federal Register comments concerning the Department of Transportation Special Permit 16320

NIOSH CA 2019-1016
May 2019

1 – Summary

On October 1, 2018, NIOSH published a request for information (RFI, Federal Register) concerning the Department of Transportation (DOT) special permit (SP) 16320 issued to Digital Wave Corporation (DWC). SP 16320 uses Modal Acoustic Emissions (MAE) testing to extend the service life (requalification) of carbon-fiber reinforced aluminum-lined cylinders (CFFC). The intent of the RFI was to obtain information about the potential impact of SP 16320 on CFFCs used with NIOSH-approved self-contained breathing apparatus (SCBA). The public comment period for the RFI closed on November 30, 2018.

The comments included 15 general comments, and 7 sets of comments addressing one or more of the four questions included in the RFI. Users and those representing user groups provided general comments in support of using SP 16320 to extend the service life of the 15-year CFFC, especially based on cost. Several commenters indicated the safety of the approach must be ensured and implied NIOSH provide this assurance. SCBA manufacturers generally did not support the use of cylinders requalified for use beyond their 15-year service life. SCBA manufacturers stressed the use of these requalified cylinder voids the product’s warranty and possibly the NIOSH approval since third party MAE requalification is not in the manufacturer’s supply chain and out of the NIOSH Approval Holder’s control.

NIOSH’s analysis and review of these comments resulted in the validation of the NIOSH Respiratory Protective Device Information Notice [NIOSH CA-2018-1006] included in the Federal Register Notice (FRN). NIOSH revised the notice in February 2019 to include an update about the completion of the FRN and the referenced supplemental information outlined in ACTION 1, below.

3 – Background and Supplemental Information

4 – References

Approval of Respiratory Protective Devices, 42 C.F.R, Part 84

December 28, 2001 NIOSH Letter to All Interested Parties, Acceptance of Applications for the Testing and Evaluation of SCBA for use Against Chemical, Biological, Radiological and Nuclear Agents

NIOSH Statement of Standard, SCBA with Chemical, Biological, Radiological and Nuclear Protection used to Protect Emergency Responders Against CBRN Agents in Terrorist Attacks

Federal Register, Docket No. CDC-2018-0093-NIOSH-320, Document No. 2018-21256, p. 49388-49389, October 1, 2018.

References cited or provided in response to the RFI:

Pipeline and Hazardous Materials Safety Administration (PHMSA) New Cylinder Special Permit Maintains Safety Standards While Offering Cost Savings to First Responder Industry
The Compressed Gas Association publication CGA -C22 Water Corrosion of Composites Cylinders with AA6061 Liners.

1910.134 OSHA Personal Protective Equipment, Respiratory Protection

1910.134(h)(4) Repairs.

The employer shall ensure that respirators that fail an inspection or are otherwise found to be defective are removed from service, and are discarded or repaired or adjusted in accordance with the following procedures:

  • 1910.134(h)(4)(i)
    Repairs or adjustments to respirators are to be made only by persons appropriately trained to perform such operations and shall use only the respirator manufacturer’s NIOSH-approved parts designed for the respirator;
  • 1910.134(h)(4)(ii)
    Repairs shall be made according to the manufacturer’s recommendations and specifications for the type and extent of repairs to be performed; and
  • 1910.134(h)(4)(iii)
    Reducing and admission valves, regulators, and alarms shall be adjusted or repaired only by the manufacturer or a technician trained by the manufacturer.

Appendix A, Basic Requirements for Fully Wrapped Carbon Fiber Reinforced Aluminum Lined Cylinders (DOT CFFC), March 2007 (Fifth Revision).

Flage, D. Hunter, D Robinson, S., Self-Contained Breathing Apparatus (SCBA) Cylinder Life Extension Study

Structural Integrity Evaluation of CNG Composite Cylinders by Acoustic Emission Monitoring, Olivier Skawinski, Patrice Hulot, Christophe Binétruy And Christian Rasche, J Acoustic Emission, 26 (2008) pp 120-131.