converting air tanks to EAN

[nitroxfox]

This entire discussion is exausting, and has been since padi said nitrox would kill you. Scuba is an unregulated industry so far. That means that you get interpretation from many different agencies outside of the scuba parameter, trying to apply rules for transport, and filling, and storage. A hodge podge of selective implementation at best.

Like everything else, do your own research and determine what makes sense to you and the people in your hood. This entire debate and the poor quality of the fill stations in my hood is what prompted me to bite the bullet and by my own compressor. In the USA it is really hard to seperate marketing, revenue generation, urban scuba myth, and reality. It is why you have had so many responses from differing angles.
Eric

The Scuba Industry is definitely 100% regulated. The enforcement of the regulations is lax, however, until a complaint or accident occurs. Cylinders for Scuba are specifically mentioned in Title 49 of the CFR (DOT). Additionally, if you have employees in the USA you must deal with OSHA. Furthermore, if you sell goods to customers, you have the UCC (Uniform Commercial Code) which varies state by state. Basically, if you have to provide a protection to your employees because it is deemed hazardous to do so, you must extend that protection to your customers too.

Again, please read the OSHA statutes for RECREATIONAL SCUBA MANDATORY REQUIREMENTS, I included the preamble to alleviate some confusion for those who have never read the standard:

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FEDERAL_REGISTER&p_id=18073

Recreational Scuba gets and exemption from the MANDATORY decompression chamber requirements as long as 4 conditions are met and that is the only exemption from the Commercial Diving Standard that they get. According to 1910.5, whenever terms like MUST, SHALL, REQUIRED, etc are used , they are MANDATORY LANGUAGE.

"(f) Compliance with other OSHA standards. Under this proposed condition, employers must ensure that SCUBA equipment in which either nitrox breathing-gas mixtures or pure O₂ is under high pressure (i.e., exceeding 125 psi) complies with the requirements of paragraphs (i)(1) and (i)(2) of § 1910.430. OSHA is including this condition in the final standard as proposed because it ensures that this equipment is free of ignition sources that could cause an O₂-accelerated explosion. As noted above in the discussion of Condition 3(d)(iii), the Agency believes that paragraphs (i)(1) and (i)(2) of § 1910.430 reduce this risk by requiring employers to use diving equipment designed for O₂ service and to clean the equipment of flammable materials before such use.⁽⁷⁾"

"Footnote 7 In addition, employers already are required to comply with other OSHA standards that provide for accurate mixing and decontamination (especially hydrocarbon removal) of breathing gases, and they must assure that employees are properly protected during these activities. These standards include the appropriate provisions of §§ 1910.101 ("Compressed gases (general requirements)"), 1910.169 ("Air receivers"), and 1910.134 ("Respiratory protection").


While umbilicals, helmets, hoses, 2nd stages, and other low pressure systems subjected to less than 125psi do not need to be cleaned when they encounter less than 40% O2, High pressure components MUST be cleaned. You can't extend 40% to everything which it seems some folks have. It is important to read the WHOLE standard and not pick piecemeal from it. Additionally, directly from Condition 6 of the standard:


(d) Before producing nitrox breathing-gas mixtures using a compressor in which the gas pressure in any system component exceeds 125 pounds per square inch (psi), the:

(i) Compressor manufacturer must provide the employer with documentation that the compressor is suitable for mixing high- pressure air with the highest O₂ fraction used in the nitrox breathing-gas mixture when operated according to the manufacturer's operating and maintenance specifications;

(ii) Employer must comply with paragraph 6(e) of this appendix, unless the compressor is rated for O₂ service and is oil- less or oil-free; and

(iii) Employer must ensure that the compressor meets the requirements specified in paragraphs (i)(1) and (i)(2) of § 1910.430 whenever the highest O₂ fraction used in the mixing process exceeds 40%.

(e) Before producing nitrox breathing-gas mixtures using an oil- lubricated compressor to mix high-pressure air with O₂, and regardless of the gas pressure in any system component, the:

(i) Employer must use only uncontaminated air (i.e., air containing no hydrocarbon particulates) for the nitrox breathing-gas mixture;

(ii) Compressor manufacturer must provide the employer with documentation that the compressor is suitable for mixing the high- pressure air with the highest O₂ fraction used in the nitrox breathing-gas mixture when operated according to the manufacturer's operating and maintenance specifications;

(iii) Employer must filter the high-pressure air to produce O₂-compatible air;

(iv) The filter-system manufacturer must provide the employer with documentation that the filter system used for this purpose is suitable for producing O₂-compatible air when operated according to the manufacturer's operating and maintenance specifications; and

(v) Employer must continuously monitor the air downstream from the filter for hydrocarbon contamination.

(f) The employer must ensure that diving equipment using nitrox breathing-gas mixtures or pure O₂ under high pressure (i.e., exceeding 125 psi) conforms to the O₂-service requirements specified in paragraphs (i)(1) and (i)(2) of § 1910.430.


You will be able to find manufacturers who will give letters of compliance so you can use a membrane system. I have personally not been able to find a manufacturer to supply such a required letter for a continuous flow system though. The mixing process begins with about 100% O2 and then is diluted in the mixing stick before being pumped through the compressor. Equipment failure, design errors, operator errors, etc can and do happen which could lead to a catastrophic failure of a compressor and possibly cause injury or worse when using such systems in such a manner.
If you are using a continuous flow system without meeting all of the requirements, you are in violation of the standard. I wouldn't want to be in your shoes if an accident happens!!
"(iii) Employer must ensure that the compressor meets the requirements specified in paragraphs (i)(1) and (i)(2) of § 1910.430 whenever the highest O₂ fraction used in the mixing process exceeds 40%"

You can use one on an oil-less or oil-free compressor, but not an oil-filled.

Regardless of how you mix your gas, you still need to clean cylinders at 23.5%. 1910.1200 defines an OXIDIZER at 23.5%. DOT REQUIRES cleaning at 23.5%. From 1910.430:
1910.430(e)
Compressed gas cylinders. Compressed gas cylinders shall:
1910.430(e)(1)
Be designed, constructed and maintained in accordance with the applicable provisions of 29 CFR 1910.101 and 1910.169 through 1910.171.

From 1910.101:

1910.101(a) "Inspection of compressed gas cylinders." Each employer shall determine that compressed gas cylinders under his control are in a safe condition to the extent that this can be determined by visual inspection. Visual and other inspections shall be conducted as prescribed in the Hazardous Materials Regulations of the Department of Transportation (49 CFR parts 171-179 and 14 CFR part 103). Where those regulations are not applicable, visual and other inspections shall be conducted in accordance with Compressed Gas Association Pamphlets C-6-1968 and C-8-1962, which is incorporated by reference as specified in Sec. 1910.6. From the links I provided in my 1st post 173.302b requires cleaning at 23.5%. Directly from the Offilcal DOT Interpretation: Q1: If a cylinder is to be used to transport Nitrox, at what Oxygen percentage must a cylinder used for Oxygen service be cleaned and must the cylinder cleaning conform to the cleanliness standards specified in 173.302? A1: Gas mixtures with Oxygen concentrations greater than 23.5% by volume should be considered to cause or contribute to combustion of other material to a greater extent than air. These gas mixtures must be described as "Compressed gas, oxidizing, n.o.s." and must be classified and labeled with a Division 2.2 (nonflammable gas) primary hazard and a Division 5.1 (oxidizer) subsidiary hazard. If the Oxygen concentration is greater than 23.5%, the conditions specified in § 173.302(b) must be met. Good luck with all of this gentlemen. I know we all mean well and are trying to do the right thing. Ask the right questions of those in charge of the regulations and you will get to the bottom of it. I have been a dive professional for some time and it took quite a bit of time and training to find this knowledge. Please don't shoot the messenger for the message. So many people have so many opinions but at crunch time, it is the one with the fine book and regulations who will cost you. I encourage everyone to attend the DOT training when it is available and to ask questions of the regulatory authorities as they are the AUTHORITIES. Best Wishes

 

[waterpirate]

While I am not going to dispute the link you posted, I am going to take issue with the interpretation and implementation of the OSHA and dept. of labor involvement in what it calls " commercial diving operations " and refrences it's application to recreational avenues. I love my country, but fear my govt. and it's misguided involvement and subjective enforcement of a plethra of laws includeing " not walking my pig down main street on Sunday. "

YMMV and this is just not that important in the scheme of things.
Eric

 

[Abdullah]

While I am not going to dispute the link you posted, I am going to take issue with the interpretation and implementation of the OSHA and dept. of labor involvement in what it calls " commercial diving operations " and refrences it's application to recreational avenues. I love my country, but fear my govt. and it's misguided involvement and subjective enforcement of a plethra of laws includeing " not walking my pig down main street on Sunday. "

YMMV and this is just not that important in the scheme of things.
Eric

Commercial diving operations in the US are regulated in 29 CFR 1910 Subpart T, part of which is listed above. Recreational scuba and scientific diving have limited exemptions from subpart T. Scientific diving operations have a framework of self regulation that they must maintain to avoid this regulation. Recreational diving operations must be conducting NDL dives and EAN less than 40%. Keep in mind that OSHA applies to employers and their diving employees at work, not to fun divers enjoying their hobby.

The regulation was promulgated before tec diving became a significant part of the recreational dive industry. If a dive op employs instructors who are conducting deco dives as part of their work, or are using EAN >40% as part of their work, then the dive op loses the recreational exemption and are regulated as a commercial dive op (which requires the chamber, specific equipment maintenance, etc.).

There are specific regulations in the US for maintaining scuba cylinders and for the types of inspections required (no need to see them here).

 

[nitroxfox]

Commercial diving operations in the US are regulated in 29 CFR 1910 Subpart T, part of which is listed above. Recreational scuba and scientific diving have limited exemptions from subpart T. Scientific diving operations have a framework of self regulation that they must maintain to avoid this regulation. Recreational diving operations must be conducting NDL dives and EAN less than 40%. Keep in mind that OSHA applies to employers and their diving employees at work, not to fun divers enjoying their hobby.

The regulation was promulgated before tec diving became a significant part of the recreational dive industry. If a dive op employs instructors who are conducting deco dives as part of their work, or are using EAN >40% as part of their work, then the dive op loses the recreational exemption and are regulated as a commercial dive op (which requires the chamber, specific equipment maintenance, etc.).

There are specific regulations in the US for maintaining scuba cylinders and for the types of inspections required (no need to see them here).

Abdullah,

You are correct. These are regulations for the USA. Each country varies. There is a push in the Commercial arena for harmonizing of standards and it will probably be coming. Emergency diving for Police and EMS etc are under Appendix A of 1910 SubPart T
Scientific Diving is Appendix B
Recreational Diving is Appendix C

From the USA Regulations per Appendix C:

"Recreational diving instruction" means the training of diving students in the use of recreational diving procedures and the safe operation of diving equipment, including open-circuit, semi-closed-circuit, or closed-circuit SCUBA during dives.

"Dive-guiding operations" means the leading of groups of trained sports divers, who use open-circuit, semi-closed-circuit, or closed-circuit SCUBA, to local undersea diving locations for recreational purposes.

• 3. Add new definitions for "dive-guiding operations" and "recreational diving instruction" to the alphabetical list of definitions in § 1910.402, to read as follows:

§ 1910.402 Definitions.

Dive-guiding operations means leading groups of sports divers, who use an open-circuit, semi-closed-circuit, or closed-circuit self-contained underwater breathing apparatus, to local undersea diving locations for recreational purposes.

* * * * *

Recreational diving instruction means training diving students in the use of recreational diving procedures and the safe operation of diving equipment, including an open-circuit, semi-closed-circuit, or closed-circuit self-contained underwater breathing apparatus, during dives.

Again, these are Mandatory regulations in the USA. As I live and operate here, I MUST abide or I risk punishment in the event of an inspection or accident. Please do not confuse my knowledge of these standards with agreement. There is , to my knowledge nothing pertaining to folks diving for fun except regulations we must all follow. For instance, I can go to my local hardware store and buy propane within certain limits. If I load truck with a limit that exceeds that to put on a party or other function, I am at risk of penalty. Just because it is for private use does not mean a free for all. Everything is regulated in the USA. The DOT applies to anyone transporting on USA highways. You can't take 30 propane cylinders through a tunnel just because they are for your personal use!!

Thanks again and safe diving!!

 

[Abdullah]

Snip

Again, these are Mandatory regulations in the USA. As I live and operate here, I MUST abide or I risk punishment in the event of an inspection or accident. Please do not confuse my knowledge of these standards with agreement. There is , to my knowledge nothing pertaining to folks diving for fun except regulations we must all follow. For instance, I can go to my local hardware store and buy propane within certain limits. If I load truck with a limit that exceeds that to put on a party or other function, I am at risk of penalty. Just because it is for private use does not mean a free for all. Everything is regulated in the USA. The DOT applies to anyone transporting on USA highways. You can't take 30 propane cylinders through a tunnel just because they are for your personal use!!

Thanks again and safe diving!!

I'd be curious if the US dive ops are complying with this regulation. An op whose courses and dive trips never exceed the NDL wouldn't need to pay much attention. But do the tec shops that do deco training and deco diving comply with all the requirements? Do they know they have to?

 

[nitroxfox]

I'm sure most of them are unaware or if aware they ignore the standard. This is rarely mentioned in a technical instructor course!! If you are a tech instructor, at the beginning of your S&Ps(Standards and Procedures) for each organization there is usually a disclaimer such as " some of these training standards violate OSHA workplace safety regulations and WE,(OrganizationXXXXXX) take your pick, do not condone activities that violate workplace safety standards" I know mine does!!

Again, These are USA regulations. They may not apply outside of the USA and its territories. That is why a lot of the tech teaching seminars held by different training organzations are held outside the USA. Workshops and discussions may be held in the USA but you will find that the diving portion is held offshore in places that do not have OSHA oversight. Check for yourself the next time you see a tech workshop listed.

I do not agree with the standard, but it is the law and living in the USA, I'm stuck. Complying with these regulations is VERY costly and that can be prohibitive. I'm also sure you would be in a bind with your insurance here in the USA if you were found to be operating outside of OSHA workplace safety standards and an accident occurred. OSHA applies to the employer/employee relationship. However, the Uniform Commercial Code (UCC) applies to anyone engaged in business. Once you have the training, as long as you are doing it for fun and recreation and not making any $ off of it, you are on your own. It is a problem for the tech instructor though and the boat operator and the dive master.......

 

[Abdullah]

I'm sure most of them are unaware or if aware they ignore the standard. This is rarely mentioned in a technical instructor course!! If you are a tech instructor, at the beginning of your S&Ps(Standards and Procedures) for each organization there is usually a disclaimer such as " some of these training standards violate OSHA workplace safety regulations and WE,(OrganizationXXXXXX) take your pick, do not condone activities that violate workplace safety standards" I know mine does!!

Again, These are USA regulations. They may not apply outside of the USA and its territories. That is why a lot of the tech teaching seminars held by different training organzations are held outside the USA. Workshops and discussions may be held in the USA but you will find that the diving portion is held offshore in places that do not have OSHA oversight. Check for yourself the next time you see a tech workshop listed.

I do not agree with the standard, but it is the law and living in the USA, I'm stuck. Complying with these regulations is VERY costly and that can be prohibitive. I'm also sure you would be in a bind with your insurance here in the USA if you were found to be operating outside of OSHA workplace safety standards and an accident occurred. OSHA applies to the employer/employee relationship. However, the Uniform Commercial Code (UCC) applies to anyone engaged in business. Once you have the training, as long as you are doing it for fun and recreation and not making any $ off of it, you are on your own. It is a problem for the tech instructor though and the boat operator and the dive master.......

How does that work for the US cave guides? Is this why I see so much talk about getting GUE/DIR/etc. certified in Mexico?

 

[ozzydamo]

That's a lot of interesting detail. It's probably important to understand if you are a tech working for the LDS.

Where I dive, very few shops bank Nitrox. That means that if I need a nitrox fill, it will be partial pressure blended.

And that means my tanks need a sticker issued by a tech affiliated with a shop, with the ANDI reg number on it.

And the ONLY way I have found is to get that sticker by having the bottle and valve cleaned at the LDS.

So I conclude, perhaps wrongly, that if you have a bottle that you want to use with Nitrox, it's practical to get the bottle and valve O2 cleaned at the LDS, get the sticker and you are done.

Did I get that wrong?

Yes you did!

You can buy the stickers on ebay and put them on yourself, if you wanted to.

 

[NAM001]

Yes you can just buy the stickers on ebay. Yes you can go to KINKO"S and print them on bumper sticker material. You can do a lot of things to skip out of the 15 bucks for a vis. It will only work for a while because shops are now refusing to deal with tanks unless they have recognized agency stickers, done by their shop, or a verifiable inspector number is on the vis sticker. VIS by abc dive shop stickers are no longer being accepted. Vis stickers like PSI and ANDI and the like are valid. The day is nearing that stickers will have bar codes on them to id the inspector. I can tell you that PSI folks do get calls asking to verify the INSPECTOR # on the sticker as being a valid number. Eventually you wont be able to inspect your own tanks. IE customer and VIS ID can not be the same.

 

[Abdullah]

Yes you can just buy the stickers on ebay. Yes you can go to KINKO"S and print them on bumper sticker material. You can do a lot of things to skip out of the 15 bucks for a vis. It will only work for a while because shops are now refusing to deal with tanks unless they have recognized agency stickers, done by their shop, or a verifiable inspector number is on the vis sticker. VIS by abc dive shop stickers are no longer being accepted. Vis stickers like PSI and ANDI and the like are valid. The day is nearing that stickers will have bar codes on them to id the inspector. I can tell you that PSI folks do get calls asking to verify the INSPECTOR # on the sticker as being a valid number. Eventually you wont be able to inspect your own tanks. IE customer and VIS ID can not be the same.

Wait until they start requiring eddy current testing.