29 CFR 1910.134 (b) has different definitions for “air-purifying respirator” and “atmosphere-supplying respirator.” In other paragraphs, such as (c) and (d), the term “respirator” is used. In (d)(2)(i), the terms “SCBA” and “SAR with auxiliary self-contained air supply” are used. Paragraph (h)(3)(iii), in specifying inspection procedures for SCBA, the pertinent sentence seems to me to be: “Employers shall determine that the regulator and warning devices function properly.” I argue that flow testing or other manufacturers’ requirements must be met to determine that the “regulator . . . function(s) properly.”
It’s 8:30 pm on a Friday night and there is either a visual confirmation that there is a release of a hazardous material (puddle or pile of stuff on the floor at or near a broken container, hose from a compressed gas cylinder is broken and venting, etc.) or an alarm is sounding. If you are the one going to clean up the mess or otherwise respond, how sure do you want to be that the appropriate respirator is working properly while you do initial monitoring and get containment or confinement of the spill/release? Thud (as in fall down and go thud) is not a reliable of “function properly.”
George C. Walton, CHMM
Reactives Management Corporation
1025 Executive Blvd., Suite 101
Chesapeake, VA 23320
I recently inherited our SCBA program and had a few questions. While not mentioned in OSHA's respiratory protection program, NFPA does require flow-testing for all SCBA units. Since NFPA and the manufacturer both require this, I am reasonably assuming that it then falls under the OSHA general duty clause.
I was just curious as to how many of my sister institutions are annually flow testing their SCBA units and if they purchased the equipment to do so in-house or use outside companies? I am already using outside companies to hydrostatically test my cylinders to get them up to date and I am using the cascade system at our fire house to fill them.
We currently have Survivair Puma/Cougar units.
Thanks for your input.
Brandon S. Chance, M.S., CCHO
Program Manager, Chemical Safety
Environmental Health and Safety
262 Alexander Street
Princeton, NJ 08540
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