Once a business becomes a government licensed hydro-test facility, they must follow the regulations or face fines and penalties for errors or mistakes.
by Don Kinney:
Let’s begin this article by stating that there is no United States federal law mandating annual visual inspections in the SCUBA industry. The federal law mandates a hydrostatic requalification for a cylinder, but nothing on an annual basis. The annual inspection program in the SCUBA industry was first reported in 1969 with a study conducted by the University of Rhode Island (URI). In the URI report they were researching safety concerns and documented the following in the study:
One of these organizations, the National Association of Skin Diving Shops. (NASDS) does have a valuable cylinder safety program, which it is trying to promote. This program is called the Visual Inspection Protection program (VIP). Under the program each diver has his SCUBA cylinder visually inspected once a year. The diver is charged a small fee of about $1.50; and in return, he receives the satisfaction of knowing the internal condition of his cylinder. In addition, if his cylinder is free from damaging internal corrosion, he is given a VIP sticker (Fig. 2) which is good for one year and enables him to save 25 cents on each air fill.
The NASDS program used a VIP sticker to show the cylinder was inspected and offered a discount air fill for having the cylinder inspected. The report does not state who issued the visual inspection stickers, or the training of the person inspecting the cylinder. That same problem continues to this day.
Visual inspection stickers commonly have a shop’s information and logo for promotional purpose. They place dates on the sticker and indicate when it was inspected, and as a reminder for when the next inspection is due. I would assume that most shops have inspection procedures in place and have trained their staff in proper inspection protocols. Why would they not? They are inspecting a cylinder that they will likely be filling, and they want to ensure its safety. If a problem occurs it affects their shop and their employees.
What happens when that cylinder is taken to another shop to be filled with a compressed gas? This shop is not aware of the training of the inspecting facility, they might not know the other facility, or they might feel that they are a competitor and look upon the visual inspection sticker with distrust. If this occurs, and one shop does not accept another shop’s sticker, there is only one concerned person; the cylinder owner. The cylinder owner was following the rules of the industry and getting their cylinder inspected annually. They went to the most convenient location to use their services. How was the customer to know that one shop may not trust another shop?
The SCUBA industry must continue encouraging the customer to obtain their annual inspections. SCUBA cylinders are exposed to many hazards that may cause concern during the filling process. To keep everyone safe the SCUBA cylinder should undergo a regular inspection, sometimes more frequently than every 12 months. If the cylinder has been exposed to a hazard it might need more frequent inspections. The customer must be educated and encouraged to have their cylinder inspected at any time an issue arises.
To keep the cylinder owner confident in an annual inspection program they must have some assurance that their cylinder was inspected by an individual with formal training. They must also be confident, that wherever they take their cylinder, that it will be filled because they did have a visual inspection completed. It is also up to the fill station to be confident that if another location inspected the cylinder that it is safe to fill.
The trust begins with proper training for the facility issuing the visual inspection. If they have sent their employees through a formal program a card and or certificate should be issued proving that they completed a training program. That certificate or card should be displayed prominently on the walls for everyone to see. A simple step like this will ensure the customer that their cylinder is being inspected by a trained individual and the facility issuing the visual sticker is qualified to do so. That way, when the customer goes to a fill station who questions the validity of the sticker, the customer can state that they saw the training credentials that stand behind the Visual sticker. If the fill station is still in doubt they can contact the other facility and request the training date and certificate of the inspector who conducted the formal inspection. If these steps are followed the fill station should honor the visual sticker to ensure that the consumer does not lose faith in the visual program.
The sticker needs to be able to handle the extreme environmental conditions, and these types of stickers do not come cheap. Some shops are unable to afford their own personal stickers with their facility name, address and logo. They may need to purchase generic stickers from outside sources at an affordable rate. In this circumstance the fill station would have no idea who to call to verify the training since there are no names or phone numbers on the sticker. Because of this, it is important that a sticker without facility information have the name of the inspector listed on that visual sticker. That will help assure a fill station technician that the cylinder was properly inspected.
A VIP Sticker ensures that whatever the composition of the cylinder, (steel, aluminum or composite) it was inspected to that specific standard. It also states that the person inspecting the cylinder was trained. How can this be verified? By the signature of the inspector at the bottom, stating their inspector number or qualification. The person signing the sticker is signing a declaration that they were properly trained. That helps the fill station technician understand that someone is placing their actual name on the item they inspected.
There is no way to guarantee that someone placing a visual inspector sticker on a cylinder was properly trained, or paid attention during their class. Some persons might even go so far as to make up a sticker and make false claims. However, we as an industry need to start trusting one another, to not trust someone because they are a competitor and we don’t like them is unprofessional. All that does is make the consumer uncomfortable with the entire visual inspection program.
The fill station or store should always check for proper cylinder markings and a current inspection sticker prior to filling a cylinder, trusting that the store, person or inspector who placed the sticker on the cylinder was properly trained. If the technician has a doubt about a cylinder’s safety, they can always insist on performing their own inspection. It is up to them if they are going to charge the consumer for this added service or simply perform it as a courtesy for the sake of safety. If they are refusing to fill a cylinder simply because the visual inspection sticker does not meet their personal needs, they should have the courtesy of explaining that to a customer. The customer deserves an honest answer of why the technician will not fill a cylinder. Simply stating “it’s not safe” with no justification is poor customer service and not an acceptable response.
Always be safe filling a cylinder, and question the customer if something appears wrong or unsafe about the cylinder. But check your unsolicited opinions at the door so you don’t start eroding the consumer’s faith in the very safe program of annually inspecting our SCUBA cylinders.
About the author: Don Kinney is the owner of Cylinder Training Services (www.cylindertrainingservices.com). He started formally working with and filling cylinders in 1991. With his background in public safety he continued to gain knowledge in the field of high pressure cylinders and began to develop training programs. He has developed programs for PSI/PCI including; Eddy Current testing (2003), SCBA, Fire Department (2004) and their Fire Safety Seminar program (2004). He went on to develop his own visual inspection program covering cylinders, valves, cleaning and compressors in 2011. At this time he realized that inspectors needed a source for affordable and high quality inspection tools. His tools are designed for the high pressure cylinder industry, and assist them in determining damage and ensuring cylinders remain safe. In 2014 he developed an inspection program for International Training where he published a manual and developed an on line training program. Don continues to dedicate himself to safety in the high pressure cylinder industries. He prides himself on understanding the clients and their needs and coming up with a safe and useful training program designed to keep them safe and save them thousands of dollars.
by Don Kinney:
There are many reasons to invest in formal visual inspection training. The best reason is safety; to keep everyone out of harm’s way from a cylinder failing while under pressure, or a compressor failing to work properly. There are also other reasons, even financial reasons, to invest in such training.
A properly trained individual will understand the allowable damage on a specific style of cylinder, the workings and proper operation of a compressor, and they can help develop safe filling procedures for a facility. There are a great number of people who have been around for a long time and have experience in these areas, but when was the last time they had a refresher course, listened to new ideas or developed new techniques? Taking a formal inspection training course can help a novice understand the nuances and dangers involved and can also give new ideas and techniques to the seasoned veteran.
Here are but a few reasons to take a formal training program:
Protect your investment in your equipment (cylinders, valves and compressors)
A company or person has invested hundreds, thousands or even millions of dollars in the cylinders they use recreationally or for business. These cylinders are quality pieces of equipment that can withstand specific uses and/or environments. There are times that the uses or environments exceed the design of the cylinder. The cylinder can then be exposed to factors that may weaken it due to corrosion and stress.
Many of these conditions can be reduced or eliminated as long as the cylinder is properly maintained.
An example of such a circumstance is a steel storage cylinder sitting on concrete with no barrier. The bottom of the cylinder is in direct contact with an environment where it is exposed to moisture. If this condition goes unchecked, it could lead to damage which may render the cylinder useless due to the level of corrosion. With proper training a person charged with the maintenance of the cylinder may prevent such an occurrence and keep that cylinder in service for its intended service life.
When a cylinder becomes damaged it must be determined if the damage exceeds an allowable limit. Simply having damage does not render a cylinder unsafe to use. Most cylinders are designed with a certain amount of damage expected and are designed to withstand that damage. The person maintaining the cylinder must know the allowable limits and understand how to gauge the amount of damage. When looking inside a cylinder and corrosion is detected, how can the inspector measure the damage and make an assessment? Proper training will give the inspector hands on knowledge with a trained professional.
The same principle holds true for the valve on the cylinder. The valve has moving parts and components designed to retain high pressure gases. Constant use, as well as infrequent use, can have an affect. Over-use or over-tightening the valve can affect the high pressure seating material. No use, with the addition of contaminates, may cause the valve to seize or not work as designed. With proper maintenance and care, a cylinder valve should have a long serviceable life. Proper training can cover common issues and proper maintenance tips to ensure a long service life.
If a person or organization has invested in a compressor, it is likely one of the most expensive pieces of equipment in their high pressure arsenal. The compressor is a complicated piece of machinery with numerous moving parts that must work in unison to achieve its rated service pressure. Small particles, not enough oil, too much oil or wearing seals can cause very expensive, unexpected repair bills. The compressor must be maintained, parts replaced and it should be on a scheduled, budgeted maintenance procedure. It is when the compressor is neglected or ignored that the maintenance costs become problematic. Proper training can help the staff develop a maintenance schedule and keep the compressor running as intended.
With a compressor working properly the compressed gas needs to be filled into a storage cylinder. How can this be accomplished safely? The compressor will likely handle pressure well above 207 BAR/3000 PSI. Even much lower levels of pressure, in the hundreds, is enough to go through skin and cause life threatening injuries. The person operating a high pressure fill station must understand these risks. The person filling a cylinder is also the most likely person to notice a safety issue with a storage cylinder and prevent a problem by not using a specific cylinder until it is properly inspected and found safe to use. The fill station can be one of the most dangerous assignments, and that person needs proper training to keep themselves and the facility safe.
Keep yourself safe – hazards from noise to explosions
Working around cylinders and compressors exposes a person to noise and other dangers such as air embolisms and possible failures of the valves or ruptures of cylinders. Care and maintenance of the cylinders and machinery is one step in preventing these issues. But a more critical step is training the person or employees to be safe around the hazards. Simple training tips, such as wearing hearing protection, how to properly move the cylinder, or how not to handle a valve, can go a long way in protecting a person and property. A formal training program will help an organization develop a proper and useful training program.
Compliance with some countries hazmat laws
Because the person or facility is dealing with compressors and cylinders and there is a risk of rupture and damage, most areas and countries have rules in place to keep persons and property safe. Even if an area does not have a governing body, it should be the operator or owner’s responsibility to develop rules that keep themselves and everyone safe. Governing bodies may dictate what training is required or how frequently that training must be administered. However, if no rules exist for proper training, it is important for the organization or person to develop common sense training to keep persons and equipment safe. Taking a formal training course will help to make a person or organization compliant with local rules and regulations, or give the organization proper training if no governing body exists.
There can be no guarantee that if a person takes formal training and follows all the rules, that an issue wont develop. However, if steps are taken to train persons in allowable damage, the repair of valves, the workings of a compressor and the dangers involved when dealing with high pressure gases, there is a greater chance to reduce the threat. A formal training program goes a long way in keeping personal safety as well as a facility safe and preventing damage to the expensive equipment it has purchased and wants to maintain for a long service life.
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About the author: Don Kinney is the owner of Cylinder Training Services (www.cylindertrainingservices.com). Don started formally working with and filling cylinders in 1991. With his background in public safety he continued to gain knowledge in the field of high pressure cylinders and began to develop training programs. He has developed programs for PSI/PCI including; Eddy Current testing (2003), SCBA, Fire Department (2004) and their Fire Safety Seminar program (2004). He went on to develop his own visual inspection program covering cylinders, valves, cleaning and compressors in 2011. At this time he realized that inspectors needed a source for affordable and high quality inspection tools. His tools are designed for the high pressure cylinder industry, and to assist them in determining damage and ensuring cylinders remain safe. In 2014 he developed an inspection program for International Training (SDI/TDI/ERDI) where he published a manual and developed an on-line training program. Don continues to dedicate himself to safety in the high pressure cylinder industries. He prides himself on understanding the client and their needs and coming up with a safe and useful training program designed to keep them safe and save them thousands of dollars.
by Don Kinney:
The primary rule affecting the inspection of high pressure cylinders in the United States is the U.S. Code of Federal Regulations (CFR) 180.205. This section refers to the hydrostatic requalification of cylinders, but also mentions that during this requalification, a visual inspection must be performed. The hydrostatic requalification may vary amongst high pressure cylinders, but a common time frame is every five years. This infers that a cylinder gets a visual inspection every five years, even though cylinders may be exposed to safety concerns countless times within a five year cycle.
Scuba diving organizations, being aware of these hazards, encourage annual visual inspections of cylinders. The National Fire Protection Association (NFPA) 1852 (18.104.22.168) requires an inspection of the cylinder at the beginning of each duty period. The Occupational and Safety Health Administration (OSHA) requires that each employer ensures that gas cylinders are safe, which can be determined by a visual inspection (1910.101(a)). None of these rules or regulations explain what to look for during these visual inspections. How can a person know what conditions are considered a safety risk?
A proper high pressure cylinder visual inspection course will show a user/inspector what conditions are acceptable and what conditions could be dangerous. The course also helps guide the user/inspector on what the next steps are to ensure safety. Each type of cylinder has unique characteristics which must be monitored to ensure its structural integrity.
Steel cylinders are common in most industries. They include storage, fire suppression, scuba diving and compressor systems. They are susceptible to moisture from their storage environment and need to be closely monitored for issues of corrosion. These cylinders are also commonly transported from location to location and have specific safety protocols; such as attaching caps during transportation and being properly secured during use.
Composite cylinders are light weight and handle greater pressures than their solid metal counterparts, but that does not mean that they can handle the same type of environment or abuses. Users/inspectors must pay close attention to cuts and gouges, as even a small cut can render the cylinder condemnable. They also respond differently to impact damage, which might not be easy to detect without proper training. These cylinders also are highly susceptible to chemical exposure and a minor incident involving a chemical might condemn a composite cylinder.
Aluminum cylinders are common in the beverage, scuba diving and medical industries. Aluminum is softer than steel, but the walls on the aluminum cylinder are manufactured with a thicker dimension than steel or composite. Even with these thicker walls, aluminum cylinders are prone to cuts and gouges which may render them unsafe . Some aluminum cylinders also require specific testing during a hydrostatic requalification and a closer inspection of the threads before continued use.
Cylinders are exposed to extreme conditions on a regular basis, thus it is recommended that they are inspected more frequently than every five years. Some of these exposures may make a cylinder unsafe long before it is due for it’s next hydrostatic requalification. A cylinder inspection course will train the user/inspector on the unique characteristics of each type of cylinder and how to recognize potential dangers before they become dangerous hazards.
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The search patterns, such as the Sweeping Arc, Jack Stay or Expanding Circle, all require refined buoyancy to make them effective. Consider a new public safety diver being deployed in any of those patterns and not taking a few seconds to establish proper buoyancy. During these patterns they are trying to use their hand to feel for an object in near zero visibility. Because of the lack of buoyancy their face is planting into the ground, their hand is being used to push off the bottom or they are floating away, out of reach of any potential object. Each time their body disturbs the sediment it makes it that much harder to locate the target.
Recreational divers are trained to stay off the bottom with visual references. They swim along looking for the fish and staying off the delicate plant life or structures. If they get too far off or start to float away, they check their computers and have ample time to adjust their equipment or techniques. Public Safety divers do not have those options. They know their target object is on the bottom, but they cannot see the target, let alone the bottom. They don’t know how far they are from the bottom unless they touch something. If they float above the bottom, they are lucky if they can clearly see their computer in time to realize their actual depth. The one thing they do not have is ample time to adjust for misjudgments. Their line is being pulled, the current is moving them or they are struggling their way through some aquatic obstruction.
The diver feels rushed to get into the water and complete their task. They have a lot of things on their mind and they may have some hesitation going into an unknown environment. If the diver is not trained to stop and obtain good buoyancy the mission could become more difficult or fail. Proper buoyancy requires controlled breathing, an understanding of their equipment and the ability to make adjustments using their senses since they may not have a visual reference.
The Public Safety diver never has a choice of where they want to dive. As much as the diver would like the mission to be in warm, clear, flat contour environments, we all know that is never the case. Buoyancy is a very important factor when the search pattern involves changing bottom topography. If the team decides on a circle search pattern and the pattern runs on a slope, the diver will continually change their depth and buoyancy characteristics. Just imagine a slight slope where the diver is at 10 feet during part of their pattern and 35 feet at the opposite end. If the diver does not have good buoyancy control there is an increased hazard for runaway ascents or dragging the bottom and possibly destroying evidence. Proper buoyancy will allow a diver to maintain neutrality no matter what depth during the pattern.
A buoyancy training technique you can try during your next drill involves a team of two divers. Have one primary diver place an obstruction in their mask which will limit their vision. Have the second diver act as the safety and lead diver. As the lead diver moves along in the training environment the primary diver follows by a slight touch to the lead diver as well as staying as close to the bottom as possible. The lead diver can intentionally rise above the bottom to the point the primary diver cannot touch. The primary diver will then need to adjust so they are touching the bottom again using only their fingertips. The lead diver can then re-establish contact and continue with the pattern. The lead diver intentionally moves up and down, away from the bottom, making the primary diver feel and adjust using their senses. The primary diver will need to know where the adjustment points are located on their equipment. They need to remain calm if they lose contact with the lead diver and maintain control of their breathing. The exercise will give the primary diver confidence in their buoyancy while being trained in a controlled environment.
A second training suggestion involves team members and extra weights, for an underwater game of hot potato. The divers all descend and establish neutral buoyancy with controlled breathing. The team brings down a bag of varied weights, from a few ounces to multiple pounds. When a diver gains good buoyancy, someone hands him a weight. The diver must re-establish their buoyancy with breathing techniques, BC adjustments or drysuit adjustments. Once they are neutral they hand the weight off to a nearby team member. As they hand over the weight, their buoyancy changes and they must re-adjust, only to be given a different weight. The exercise continues with the goal being the diver can quickly and properly adjust to changes in weight without overcompensating, or handing a weight off and not floating to the surface.
Dive teams need to become proficient with basic diver skills, such as buoyancy. All too often the team training focuses on the exciting parts of the mission and high end equipment and ignores refreshing on the basic skills. If the team works harder to become proficient at buoyancy, it will translate in to more efficient missions, safer divers and a greater likelihood of a successful mission.
About the author
Don Kinney – ERDI Instructor Trainer
Don Kinney has been a Public Safety Diver since 1991. He continues to lead his public safety team as well specialize in training other dive teams around the world. He has extensive experience in lakes, rivers, ponds, oceans and water holding tanks. He prides himself on developing training around the needs of each team and their unique environments. For further information please go to www.etds.org.
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