3-28-2006
Manufacturer Notice
Clarification on interpretation of NIOSH approval
RIT Rescue and Escape Systems, Inc. is a world leader in manufactured Emergency
Egress Systems and is proud to have a reputation for delivering safe, third
party certified, life safety systems for the Fire-Rescue community. RIT,
with over 7 years of documented commitment to safety in providing these
necessary systems, will continue to maintain all certifications possible
to ensure its quality.
Over the
past 4 years RIT has worked with major
manufacturers of SCBA units in an attempt
to provide the firefighter with an SCBA
with an integrated Emergency Egress System
which is NIOSH certified. Although we
have yet to obtain universal agreement
there are manufacturers that do have
NIOSH approved Emergency Egress Systems
in conjunction with their specific SCBA.
Please note: Draeger Safety utilize the
RIT system in their Integrated Safety
Rescue System. Draeger are currently
in the process of obtaining NIOSH and
NFPA approvals with certification expected
to be available by the end of April.
The emergency egress system sold by MSA
is approved by NIOSH and NFPA but is
not manufactured by RIT.
Questions
and concerns have come up from the end
user about the possibility of the NIOSH
certification being voided if our egress
system is integrated into an SCBA. As
a result RIT requested a meeting with
the respirator branch of NIOSH to clarify
concerns that have been asked. RIT’s
goal is to publish factual information
to allow for an informed decision when
considering the purchase of integrated
egress systems to the SCBA. RIT has and
will continue to maintain a neutral position
with this discussion.
A meeting
on March 28, 2006 at the NIOSH Pittsburg
office of the respiratory branch of NIOSH
was attended by the following personal:
Heinz W.
Ahlers, JD Acting Respirator Branch Chief,
NIOSH
Thomas D. Pouchot, PE General Engineer, NIOSH
Jeffrey Peterson General Engineer, NIOSH
Omar Jordan, President RIT Rescue and Escape Systems, Inc.
During the
meeting several issues were discussed.
This outline will elaborate on statements
generated recently from the State of
New Jersey PEOSH program and a letter
published from NIOSH directed to SCBA
manufacturers. This entire notice has
been reviewed by NIOSH as to its accuracy.
Following the Question and Answer section
is a statement to RIT from Mr. Heinz
Ahlers of NIOSH further clarifying their
position on modifications to the SCBA.
The letter,
titled Respirator User’s Notice sent
out by NIOSH on March 17, 2006 with the
subject: Meaning of NIOSH Approvals,
has prompted RIT to attempt to clarify
the following questions.
Q. Was this
letter generated in response to concerns
that adding the RIT Egress System would
void the NIOSH certification on the SCBA?
A. No. The
letter was sent out and directed to all
respirator manufacturers that have approvals
on some but not all of their products
or are adding modifications to their
products and is a clarification of rulings
for manufacturers when marketing such
products.
Q. Because
the Draeger system will have NIOSH certification
soon, can RIT state the RIT egress system
is NIOSH certified on other manufacturers
SCBAs?
A. No. RIT
can only state that there are SCBA manufacturers
that have SCBA units equipped with an
emergency egress system that are NIOSH
approved. NIOSH only certifies complete
respirator systems.
Q. Is there
any way that RIT can get NIOSH approval
for the rescue system?
A. No. Only
the manufacturer of the SCBA can certify
the breathing apparatus. Since the SCBA
harness is a component part of the complete
system the escape system is then a part
of that specific manufacturers SCBA unit
and is a component of the certified SCBA.
Q. Will
adding the RIT Emergency Egress System
to the waist belt of a SCBA void the
NIOSH certification?
A. No. Only
NIOSH can void the NIOSH certification
and this is done at the manufacturers
level.
Q. Because
adding the RIT Emergency Egress System
does not void the NIOSH certification
what is the best way to describe the
resultant SCBA after the RIT system is
added?
A. The end
user would be adding a non NIOSH approved
component to an approved SCBA. The system
would be considered by NIOSH to be in
a “non-approved configuration.” This
would be the same designation used by
NIOSH should other various field changes
be, i.e., changes to the settings or
operating characteristics, or the addition
of an accessory not originally included
by the manufacturer.
Q. If there
is an injury to, or death of, a firefighter
and NIOSH reviews the SCBA and finds
non approved items on the SCBA, how does
that effect the findings and ruling for
the accident.
A. There
has been several firefighter injuries
and/or deaths in which SCBA units have
been involved that had non approved changes
made to them. In these cases the findings
would state that non approved changes
have been made to the SCBA. Further,
NIOSH would report if these changes may
or, may not have contributed with the
injury or death.
Q. How does
NIOSH determine if the SCBA is compliant
to the NIOSH standards?
A. The manufacturer
has a matrix that lists every component
part comprising the SCBA unit. If changes
have been made to the SCBA whose part
numbers do not appear on the matrix then
those items are deemed non compliant
to the certified SCBA. Also if changes
have been made to the settings or operating
characteristics of an approved SCBA,
such as resetting the low air pressure
warning signal levels the respirator
would be operating in a non-approved
condition.
Q. Can the
manufacturer of the SCBA submit for approval
to have the RIT Egress System added as
an approved item to the SCBA?
A. Yes.
The easiest way is to file a request
for extension of approval to add the
new belt components to their approved
configurations. This is relatively inexpensive
and requires less paperwork than the
full certification. NIOSH would evaluate
the testing required when the request
for extension of approval was received.
It could be as simple as one or two simple
pull tests required which would take
approximately 1 month to complete. A
second option is to include the egress
system as a component on a SCBA that
is being submitted for other reasons.
The entire SCBA unit as sent into NIOSH
would be certified.
Received
via E-Mail from Heinz Ahlers
Dear Mr.
Jordan,
Thank you for visiting the NIOSH NPPTL facilities in Pittsburgh. We also thank
you for the opportunity to review your proposed letter. We have suggested some
editorial clarification but you must understand that we cannot "approve" your
statements or endorse your product. We have drafted the following statement
to clarify our position on modifications to SCBA configurations:
The National Institute of Occupational Safety Health and Health National Personal
Protective Technology Laboratory (NPPTL) approves only complete respirator
assemblies. This constraint is contained in 42 CFR 84.30(d) “The institute
will not issue certificates of approval for any respirator component or for
any respirator sub-assembly. Additionally 42 CFR 84.71(a)(10) specifically
includes the harness as a component of a self-contained breathing apparatus.
The NPPTL
certificate of approval is issued to
a manufacture to indicate that the submitted
respirator on its component parts have
been inspected, examined and tested in
accordance with 42 CFR part 84.
Modification
of an approved respirator means that
the respirator is being used in a non-approved
condition. It does not result in a “voiding
of the approval.’ If the respirator is
returned to its approved condition, it
will be once again in an approved respirator
configuration.
Because
of the constraints of 42 CFR 84.30(d)
only the manufacturer who holds an approval
may apply for a modification of the certificate
of approval. The application for such
a modification make take a number of
forms, from something as complex as entire
new approval to something as simple as
an extension of approval for a modification
of the harness hardware.
Although
the issuance of a certificate of approval
is a matter between NIOSH and the respirator
manufacturer, the Occupational safety
and Health Administration requires the
use of NIOSH certified respirators under
29 CFR 1910.134:
1910.134
(d)(1)(i)
The employer shall select a NIOSH-certified respirator. The respirator shall
be used in compliance with the conditions of its certification.
The OSHA
view on compliance or non-compliance
with NIOSH approvals is not necessarily
as strict as that imposed on NIOSH by
regulations. The following section of
the OSHA Fire Protection regulations
serves as an example:
1910.156(f)(1)(iii)
Approved self-contained breathing apparatus may be equipped with either a "buddy-breathing" device
or a quick disconnect valve, even if these devices are not certified by NIOSH.
If these accessories are used, they shall not cause damage to the apparatus,
or restrict the air flow of the apparatus, or obstruct the normal operation
of the apparatus. |
