By HUGH STOTT
Several years ago, the fire service made efforts to get “back to basics.” For years, we were exhorted to think outside the box and to be innovative. Structural fires were dropping off in terms of numbers, and the command of solid firefighting skills and experience was diminishing. Unfortunately, numerous firefighters weren’t even learning where “the box” was. Then, the pendulum started swinging back, and the basic skills of structural firefighting once again became a focus. Hose handling, ventilation techniques, rapid intervention team (RIT) skills, leadership qualities, and breathing apparatus capabilities were reinforced.
Developing a respiratory protection program is one of those acts that straddles the lines between administration, training, and equipment maintenance. Air supply competence is absolutely critical to the safety of firefighters on the fireground and is an imperative skill for those moments when rapid intervention is put into motion. And, if a department experiences the tragedy of a fireground death or injury, the program’s thoroughness will likely come under close scrutiny. One of the critical considerations in creating a respiratory protection program is that its presence is a requirement of federal law! It is not a suggestion. It is not a standard. It is mandated by law.
Respiratory protection is impacted by several different federal and state agencies; some of them have direct enforcement powers. This article outlines several steps by which you can assess and build a program that will meet your department’s needs and resources.
With the increasingly complex nature of firefighting, technology has become a more significant portion of our way of doing business. We use thermal imaging cameras, computers, and complex radio systems. Our breathing apparatus is no different. The implementation of integrated personal alert safety system (PASS) devices, firefighter locating systems, and heads-up displays has transitioned our air supply training into a highly interactive program of administrative support, operational protocols, training activities, and record keeping. And, as daunting as that may sound, it is not out of the reach of every fire department. You can develop a successful respiratory protection program that meets the needs of your department while also conforming to state and federal regulations and national performance standards.
Administrators may indicate that the cost of developing a respiratory protection program will be too expensive during this down economy. They may tell you that there is no extra money to pay for the requirements of a program. When one considers that the failure to conform to expected national standards and state laws could be even MORE expensive, the program’s development becomes more realistic.
Your respiratory protection program should have several identifiable goals, which could include improving member safety, developing a greater sense of responsibility within the organization, promoting greater safety awareness, conforming to expected national standards, and helping limit departmental liability.
HISTORICAL FAILURES OF PROGRAMS
To put things in perspective and to determine the need to keep your program realistic, you need to assess specifically several prior failures in respiratory protection programs that have been observed. One way to do this is to examine the National Institute for Occupational Safety and Health (NIOSH) Firefighter Fatality Investigation Reports. Although the number of deaths that are immediately attributable to self-contained breathing apparatus (SCBA) may be minimal, the investigations have exposed some administrative failures regarding SCBA. Some of them include failure to provide “fit for duty” medical evaluations, a lack of respirator fit tests, poor SCBA maintenance, insufficient SCBA record-keeping methods, lack of periodic air quality testing, and others. Additionally, some investigations have determined that lack of air management procedures and air management training is also involved. Failing to conform to standards and legal regulations may expose a fire department to greater liability of a fireground injury or death.
An investigation into a fireground or training death will examine training records, personal protective equipment, and the procedural documents of the department involved. This investigation will shine a bright light on the actions of agencies that have the best of intentions but no documented guidelines. NIOSH fatality reports identify numerous factors that may have contributed to the death, even if not directly and immediately.
You can do several things with a respiratory protection program that can help improve competencies and capabilities of your members while wearing SCBA. First, access the NIOSH Web site (www.cdc.gov/niosh/fire) and read firefighter fatality reports. Specifically, review the recommendations provided and determine how your program can work to avoid the problems cited. Never use these reports to lay blame but rather to honor the loss of our members and to make certain that they did not die in vain. If we do not learn from their loss, then that is our fault. Some recommendations may serve your department well, even without being germane to the subject of SCBA. Read these investigative reports and examine just how these events might happen in your own department.
NATIONAL CONSENSUS STANDARDS
Next, read and develop a general understanding of the seven National Fire Protection Association (NFPA) standards that impact breathing apparatus: NFPA 1404, Standard for Fire Service Respiratory Protection Training; NFPA 1500, Standard on Fire Department Occupational Safety and Health Program; NFPA 1852, Standard on Selection, Care and Maintenance of Open-Circuit Self-Contained Breathing Apparatus (SCBA); NFPA 1981, Standard on Open-Circuit SCBA for Emergency Services; NFPA 1982, Standard on Personal Alert Safety Systems; NFPA 1984, Standard on Respirators for Wildland Firefighting Operations; and NFPA 1989, Standard on Breathing Air Quality for Emergency Services Respiratory Protection. Take your time when reading these standards. Some of the sections may seem quite complex. However, when you comprehend the structure and intent of a standard and compare it to the focus of another standard, each will begin to make sense. Many fire departments can obtain the NFPA standards if they subscribe to the NFPA subscription service. Nonmembers can contact the NFPA through its Web site (www.nfpa.org). NFPA standards cost approximately $35 to $40 each.
Some say that national standards are not regulations and do not carry the weight of law. Those people would be right! However, be aware that a national standard is considered, by consensus, to be a desired and acceptable level of care and performance. If a member is injured or killed on the fireground, you will be measured by and held accountable to a standard as the level of performance to which you are expected to perform.
NFPA 1404 references the components of training for your program. Its last edition was released in 2006; the next edition is expected in 2013. Some of its sections deal with the need for fit testing and medical “fit for respirator use” evaluations prior to implementing training. It distinguishes between the areas of training for recruit members and the annual training for all other members. A valuable part of NFPA 1404 is to train on air management techniques and to implement ongoing respiratory protection training.
NFPA 1500 contains numerous component portions; one of the most substantial is within Chapter 7.9, which identifies that a fire department shall create a respiratory protection program. One of the items in this standard that causes contention is the requirement that no facial hair shall extend under the face piece seal. The standard also identifies that members shall be fit tested annually only by quantitative fit testing methods. NFPA 1500 also references NFPA 1989 as the desired air quality standard. Chapter 5 gives direction to the training. Chapter 7 deals with protective equipment, with specific detail provided in sections 7.15 through 7.9. The reference to rapid intervention activity in Chapter 8, along with the various appendices, provides valuable items to consider in developing a respiratory program.
NFPA 1852, particularly Chapters 4 through 7, outlines SCBA compliance and record keeping, the program, selection of respirators, the care of the chosen respirators, and maintenance of your equipment, respectively. Chapter 4 outlines the general concepts in an overall respiratory program. Here, there is sound information about the detail of necessary record keeping. Chapter 5 suggests a process for selecting breathing apparatus based on a risk assessment plan developed by your department. If your department is considering purchasing new breathing apparatus, review and understand Chapter 5 before making any decision on purchases. When you are considering these purchases, this guidance can make your work much easier, and a reputable sales representative will respect and appreciate your thoroughness. This chapter makes several references to the U.S. Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.134 and NFPA 1981, NFPA 1982, and NFPA 1500. Chapter 6 features suggestions made for inclusion in your program regarding regular care, cleaning, disinfection, and storage. These items, along with the direct input of the manufacturer of your particular SCBA, will fortify your program’s procedures. Chapter 7 emphasizes SCBA maintenance and inspection. A significant factor identified is that flow tests of all SCBA should be completed annually. Chapter 7 outlines SCBA cylinder testing and inspection. NFPA 1852’s appendices should be used as valuable reference items. This standard, along with 29 CFR 1910.134, offers a great backbone in creating a program.
NFPA 1981 was created in 1971 to prevent the further use of canister-type respirators for firefighting. It is principally a technical performance-based standard whose primary focus is toward SCBA manufacturers. You must have a general understanding of 1981. The last edition of 1981 was issued in 2007; the next is expected in 2013 and may have some substantial changes that will affect new versions of breathing apparatus. One of those changes is an adjustment in the requirement for the amount of heat energy that must be reflected by the surface of the SCBA face piece lens. Another component change may be in the requirements of the end of service time indicator, also called the “alarm” or “bell.” Additionally, the concept of “buddy breathing” is under consideration, as is establishing an emergency tone for PASS devices that would be common among various manufacturers.
NFPA 1982 is another technical performance-based standard that focuses on the construction and performance of PASS devices. Once again, its primary focus is toward PASS device manufacturers. You should have a general understanding of the standard because your SCBA are now being manufactured with integrated PASS devices. The use of PASS devices is outlined in NFPA 1500.
Another standard that, at first, seems to have limited impact for many of us is NFPA 1984, which was created in 2011. Although these respirators’ use is for nonimmediately dangerous to life or health (IDLH) environments and precludes their use for structural firefighting, many members do wildland firefighting in addition to structural firefighting. If you work in a department that does both, be aware of this standard. It may impact your firefighting operations and how you equip your firefighters. Even during wildland fires, the potential for exposure to chemicals exist. During the September 2009 Station wildland fire in California, seven firefighters were treated for exposure to cyanide vapors, possibly resulting from the heating of galvanized metal, wire, and cans in the area.1
NFPA 1989 was created to avoid some of the conflicts and discrepancies that were in place among existing standards. With some of the recommendations that were made in NIOSH reports regarding air quality testing, you must have a command of this standard. Compliance with it will have a direct financial impact; you must ensure that your compressor is properly maintained to provide good, clean breathing air. You must also have filters and cartridges placed in the purification system, and you should have the air quality tested on a quarterly basis by a qualified testing laboratory.
If you purchase air from a commercial provider or if you obtain breathing air in your SCBA cylinders or storage cylinders from a neighboring fire department, you must still ascertain whether the air is of the proper high quality for breathing purposes. If your department has a water rescue unit that refills self-contained underwater breathing apparatus (SCUBA) tanks from your own compressor, it is necessary that you understand this standard. The purity of air used for diving purposes must be of a higher quality than the minimum standard for surface use because of the characteristics of gases under pressure. In the latest edition, a requirement has been added that mandates a carbon monoxide (CO) sensor for compressors lubricated with oil. This sensor will shut down the compressor if levels of CO exceeding five parts per million are measured in the air flow. Sensors for low oil pressure and for high temperatures that will shut off the compressor are also required.
LEGAL REQUIREMENTS
The next step is to determine the legal requirements within your state that mandate respiratory protection. These are generally enforced by a state’s department of labor. It may have an approved OSHA program, or it may enforce its own regulations. These are generally specified as the degree of “fitness for duty” medical evaluations and respirator qualification exams conducted prior to training and use of a respirator. Contact your state’s department of labor to determine if it will conduct a nonpunitive evaluation of your department and program. It may guide you in achieving compliance without the risk of legal enforcement if you invite it in for assistance. However, this will vary from state to state. Go to the U.S. Department of Labor Web site (www.osha.gov/dcsp/osp/index.html) for direction for your state’s program.
One legal obligation we all have nationwide is OSHA’s 29 CFR 1910.134 regulation. In recent years, most of us have become aware of the “two-in/two-out” requirement that obligates us to have personnel available to rescue firefighters even while preparing to mount an interior structural fire attack. However, this is just one small component of the law. This federal law mandates that each employer have a respiratory protection program. It is a comprehensive regulation that spells out precisely what is required of the employer. Your understanding of this law will be quite beneficial in creating an effective respiratory protection program that works to meet the intent of the law. The regulation’s very structure can be helpful in creating the written program document.
Much like NFPA 1852, the component portions of 1910.134 actually list the requirements of what needs to be within the respiratory program. Using these two documents together, you can begin to formulate your program with the details of the requirements right at your fingertips. You can obtain the text of the law at www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=12716&p_table=standards. The protocol for conducting a quantitative fit test is identified in the appendix of 1910.134.
The U.S. Department of Transportation (DOT) plays a part as well. The cylinders that store compressed air are subject to some of the same rules with which cylinders that contain hazardous materials must comply. Because the cylinders contain a gas under pressure and because they have been offered for commerce and transport, they must comply.
In the past, cylinders that held compressed gases were all made of steel; many still are. The cylinders in our firehouse fill station mobile air cascades as well as cylinders for SCUBA diving and are typically steel; this makes them strong yet heavy. They should meet DOT specifications. In the process of decreasing weight and increasing duration of SCBA cylinders for firefighting, cylinders were engineered with aluminum shells and fiberglass, Kevlar™, and carbon fiber windings around the shell. This design did not meet the various specifications of DOT cylinders but, as a result of DOT’s testing and evaluations, these cylinders were granted “exemptions” from the specs.
One of the criteria for an exempted cylinder is that it is allowed only a 15-year total use expectancy, regardless of the number of fill and emptying cycles. New cylinders are no longer called “exempt” but rather are given a “special permit” under DOT rules. Some cylinders were given an extended hydrostatic testing cycle after 2001. To know when you must hydrostatically test these cylinders, know where the exemption or special permit number is located on the cylinder label. You can then refer to the DOT Web site and access the permit letter to identify that hydrotest cycle requirement. This is found at the Web site for the Pipeline and Hazardous Materials Safety Administration (www.phmsa.dot.gov/hazmat/regs/sp-a/special-permits/list). When your chief asks you WHY you have to test the cylinder and WHY the cylinders have to be replaced, you will have the information source available at hand.
So far, we have discussed a few of the influences toward developing a respiratory protection program that meets your department’s needs. If you have respiratory protection equipment besides your SCBA, you have to consider that equipment as well. This could include supplied airline respirators for use in confined space rescues, air purifying respirators for your fire investigators, and canister respirators for chem-bio or law enforcement purposes.
Those departments that conduct dive team operations must also analyze the particular impact that those operations have on respiratory protection, particularly if they do any operations at any substantial depth. Air quality issues and the medical aspects of diving need special considerations and are outside of the specific realm of this article. However, some of the skills that create a firefighter who has skill, competence, and confidence while wearing an SCBA for firefighting purposes will also carry over to diving and may be a sound reason for firefighters often participating in dive rescue teams as well.
PREPARING THE DOCUMENT
We have identified several major tasks that help prepare you to write your program document. Now we will discuss how to take that information and formulate it into a manageable program based on a written document.
Inventory
First, thoroughly take inventory of each component of your respiratory protection equipment. For instance, take each SCBA backframe and its attached pressure regulator and gather the following information:
- Manufacturer,
- manufactured date,
- model, and
- regulator serial number.
If it has an integrated PASS device, collect its PASS module and console serial numbers. If it has an attached mask-mounted style regulator or an asset tracing tag, collect its serial number. If you have records to indicate when that regulator last had a flow test, record that date.
To make recognition more simplified during training, inspections, and maintenance, consider marking the backframe with a distinct department identification number unique to your breathing apparatus assets. This could be a sticker or an engraved number placed onto a part of the backframe that is not exposed to wear and tear. Once you have identified each frame and regulator, note to which apparatus that frame is assigned. For maintenance and regular inspection purposes, it is recommended that backframes and regulators be assigned to an apparatus for consistency.
Next, identify and inventory all of your SCBA cylinder information such as its manufacturer, manufactured date, DOT exemption or “SP” number, date of its last hydrostatic test, the due date for its next hydrostatic test, and the date it is required to go out of service (if an exempted cylinder). Place a unique identifying inventory number on each cylinder as well. SCBA cylinders can be placed on different backframes of the same manufacturer provided it is the same type of cylinder for which the SCBA was NIOSH approved. You cannot intermingle cylinders with different manufacturers; that is a violation of the NIOSH approval.
Finally, inventory all face pieces. They generally do not have a distinct serial number and are usually only distinguishable by the size of the face piece. Again, consider marking each face piece with a distinct number, which can match the backframe to which it may be assigned. Or, if you issue personal face pieces to each firefighter, use a different series of numbers to distinguish them. Check with the SCBA manufacturer to determine what method it recommends for marking the face piece.
Format
After collecting the information on each item, place it into an easily accessible and manageable format, such as a spreadsheet, which provides all of the information on an immediately visible table. With this format, you can put your backframes, face pieces, and cylinders on separate worksheets that are all part of one document. Choose the frame worksheet, and you will see the data on all of them at once; the same thing holds true for the cylinders. You can print all of the worksheets and have the pertinent data on all of your equipment right at hand. If you or someone in the department is computer savvy, you could enter data into a database format and then select each item by searching. Unless you are adding additional information, a database may be more extensive than you need. Start with entering the information onto a spreadsheet and go from there.
It may be handy to create a notebook for frames, regulators, cylinders, and face pieces. Within each of these notebooks, create a tab with the identifying number for each item. Under that tabbed page, insert work orders, hydrostatic test records, or annual flow test reports for each appropriate piece of equipment organized by the unique identification number you have assigned. Print the special permit letters from the DOT for each of the various cylinder styles you have, and retain those copies in the binder with the cylinder information.
Once you gather the equipment information, you can proceed with creating the format for your complete program. Remember, 1910.134 offers great information to start organizing various parts of the document. Also, use NFPA 1852 to include additional items.
Training
For the program’s training portion, make certain that members are fit tested before they begin training. A reasonable and effective set of guidelines to your training portion of the respiratory protection program could be taken, in concept, from the objectives of the breathing apparatus specialist program at the University of Illinois Fire Service Institute. Those objectives indicate that the program is intended to “make efficient use of the SCBA for normal operations, to be capable to respond to unusual events, and to prepare for extreme events.”
Following are benchmarks in the training that you should identify:
- 1. The importance of fit tests.
- 2. The need for obtaining a respirator used in “fit for duty” evaluations.
- 3. Familiarity with the name and function of each portion of the SCBA.
- 4. Demonstration and practice of the proper way to don and doff the equipment.
- 5. Recognizing and correcting perceived malfunctions during use.
- 6. How to use the SCBA within restricted spaces.
- 7. How to use the SCBA during emergency situations.
- 8. How to use SCBA features during a Mayday.
- 9. The situations when you should transmit a Mayday and how to do it.
- 10. Procedures to return an SCBA to service and how to refill the storage cylinder.
- 11. Procedures to clean and disinfect the SCBA after use.
Refer to NFPA 1404, Standard for Fire Service Respiratory Protection Training, for additional information on benchmark items that should be included. Here, you will begin to appreciate the value of understanding the various NFPA standards as they refer to each other and make their own recommendations, some of them for training.
Once members develop the skill for wearing and operating the SCBA, they should be trained in understanding the capacities and limitations of wearing SCBA in IDLH environments. This should include the concept of air management techniques, which should prevent the wearing of an SCBA once the “end-of-service” time indicator begins to activate.
A valuable part of an air management program must include assessing the quantity of air available prior to entering the environment so you are certain that you have enough air to exit once you arrive at the place where work needs to be done. Keep in mind that some of the NIOSH investigations refer to this very action. Members of the Seattle (WA) Fire Department have identified the concept of not remaining inside an IDLH environment until the end-of-service indicator activates. They emphasize that this air remains at one-quarter service for emergency purposes only. Training to avoid using any part of that reserve air is highly recommended. We must train our members to monitor their air level more readily. And, we MUST exit so we have sufficient air to exit safely before that alarm activates.
The program’s training portion should also include the types of recurring training that is important and relevant to each member annually. Ideally, there should be some overlap between recruit training items and recurrent training. “Consumption”-type circuit training so members can assess their own work levels and air capacity use works well. Members may climb under or over an obstacle, hoist and carry hose packs, swing a maul, traverse through cones, and so on. Members will have full visibility and work alone while being observed by a partner for encouragement and assistance, if needed. Calculate the amount of air used, and count the number of laps completed in a noted period of time to determine the member’s general time frame for a rated air cylinder’s capacity. Because every firefighter is different, there is no value in comparing the results of one member with the next. The consumption course exists for each individual firefighter to test his capabilities.
A restricted visibility obstacle course can also be used and should be a reasonable challenge to the member; keep it “winnable” so that members develop confidence and competence in their skills. Never make it so difficult that members cannot complete the course or become stuck. Its implementation and difficulty should also be progressive so that members are trained on how to manage an obstruction in bright light and plenty of room before moving to a limited visibility course. Obstacle course tests should be done with a partner and be closely observed by an instructor.
Maintenance
To establish the maintenance section of your program, establish a strong relationship with the corporate representative and the local maintenance technician for your brand of SCBA. They are your allies and will be willing to assist you. Provide a copy of the spreadsheet of frames and regulators to the technician when annual flow tests are being conducted. In that manner, the technician knows which frames are yet to be tested, from where they need to be located, and where they can be returned on completion of any said work. The technician is important for helping determine which spare parts you should keep on hand for minor repairs. This will also avoid your having too large of an inventory of rarely used parts and unnecessary costs.
Contact your factory technician if you wish to conduct an occasional “field repair” training class. You could host the repair class at your department’s training room, and your factory technician could invite representatives from several different agencies with the same brand of equipment to provide timely repair information and avoid duplication of training. This regional manufacturer representative might also agree to attend to help facilitate and assist in program delivery.
Compressor and Air-Storage System
If your department has its own breathing air compressor, consider the importance of maintaining this system. The compressor’s operation should be evaluated by a qualified technician. Generally, compressors should be serviced once per year. Those larger departments that frequently operate the compressor should base their maintenance on the number of operating hours on the compressor. The compressor should have the lubricating oil changed, and its air purification system must have its cartridges and filters changed at intervals recommended by the compressor manufacturer. This might be based on the number of compressor operating hours per year or on a calendar basis.
Air quality samples should be taken when the purification system is serviced as well as every 90 days. In many cases, this is also when the compressor’s CO sensor is recalibrated. When cartridges and filters are changed, the technician should take one sample before the cartridges are removed and another after the replacements are installed.
Figure 1 is a sample checklist that can be used to help you develop a new respiratory protection program or to evaluate your current program. It is flexible and can be used as needed; it is by no means all-inclusive.
To secure administrative support in developing a strong respiratory protection program, keep your chief updated regularly on the program’s status. His understanding of the program’s goals may pave the way for him to provide the needed financial resources to maintain the program.
The development/assessment of a respiratory protection program is well within the reach of every fire department. It is a broad and deep process, but it is certainly achievable. It takes some research and some hard work, along with organizational skill. If you have the support of your chief, then you can fully gather the support of the membership.
ENDNOTE
1. Gabbert, Bill. “Firefighters Overcome By Noxious Fumes on Station Fire,” Wildfire Today, 5 September, 2009. http://wildfiretoday.com/2009/09/05/firefighters-overcome-by-noxious-fumes-on-station-fire.
HUGH STOTT is a career firefighter and deputy chief with the West Chicago (IL) Fire District. Stott has been a field instructor for the University of Illinois Fire Service Institute since 1983, where he has also been a lead instructor for the Breathing Apparatus Specialist Program. He is a certified fire officer and instructor and has bachelor degrees from Purdue University and Southern Illinois University. Stott is also plans team manager for the Illinois Urban Search and Rescue Task Force 1.
