From: George C. Walton <g.c.walton**At_Symbol_Here**REACTIVES.COM>
Subject: Re: [DCHAS-L] SCBA Flow Testing
Date: Thu, 24 Oct 2013 19:23:12 -0400
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: 000a01ced110$020113b0$06033b10$**At_Symbol_Here**

Technical answer:

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.”


Non-technical  answer:

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

(757) 436-1033


From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Brandon S. Chance
Sent: Thursday, October 24, 2013 1:13 PM
Subject: [DCHAS-L] SCBA Flow Testing




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

Princeton University

262 Alexander Street

Princeton, NJ 08540

609-258-7882 (office)

609-955-1289 (mobile)

609-258-1804 (fax)


"The second I feel like I made it, the second I feel like I've arrived, that's the second someone will take my spot. And I like my spot." J.J. Watt – Houston Texans

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