As the leading manufacturer of SCBA in the North American fire services market, Scott Safety strives to keep our valued customers informed about current industry topics, as well as safety equipment issues and challenges.  One such industry topic that has recently gained attention involves the issuance of a special permit by the Department of Transportation (DOT) affecting breathing air cylinders.


On April 21, 2017, the Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) announced the issuance of Special Permit 16320 to Digital Wave Corporation to allow “the extension of the 15-year service of certain carbon fiber reinforced aluminum-lined cylinders (DOT-CFFC) that are used in self-contained breathing apparatuses by firefighters and first responders.”  The PHMSA website states that under this new Special Permit 16320, issued to Digital Wave Corporation, “cylinder life can be extended an additional 15 years through the use of Modal Acoustic Emissions (MAE) testing.”  In accordance with the special permit, PHMSA “may authorize extensions of service for DOT-CFFC cylinders in five-year increments when they are requalified by MAE testing” and “the incremental extensions may enable the cylinders to remain in service for up to 30 years.”

Modal Acoustic Emissions (MAE)

Modal Acoustic Emissions testing is a method of inspecting cylinders when pressurized in a test environment employing the use of sensors to “listen” for acoustic signatures.  These acoustic signatures are recorded and used to determine whether a cylinder has suffered a carbon fiber failure that would result in the condemning of the cylinder.  Provided a failure is not recorded during the MAE testing, the service life of the cylinder may be extended for another 5 years.

Luxfer Position Statement

Luxfer Gas Cylinders, a global supplier of breathing air cylinders to Scott Safety and other SCBA manufacturers, has issued a formal statement concerning the life extension of DOT-CFFC carbon composite cylinders by means of Modal Acoustic Emissions testing.

Read the statement.

To summarize:

  • Luxfer has not been involved with this new life-extension program.
  • Luxfer SCBA cylinders are designed and approved for a 15-year service life (Special Permit 10915) and Luxfer issues a 15-year warranty for the full service life of each cylinder it manufactures.
  • Luxfer has conducted a significant amount of testing over and above standard requirements to ensure that Luxfer cylinders can stand up to demanding firefighting environments for a 15-year period.
  • The special permit issued to Digital Wave specifically requires that the original special permit marking of each cylinder that is requalified using MAE testing be covered and replaced with “DOT-SP-16320.”
  • Luxfer cannot accept responsibility or liability for use of Luxfer-manufactured cylinders beyond the 15-year service life for which they were designed, nor does the Luxfer cylinder warranty extend beyond 15 years.

Scott Safety Position Statement

NIOSH approvals are applied for, and granted for, an entire respiratory system such as an SCBA to the respirator manufacturer and not for the individual components.  Part of this approval includes the breathing air cylinder and is specific to the special permit assigned to the cylinder manufacturer.  The NIOSH approval granted to Scott Safety for the Air-Pak SCBA does not include the new special permit (DOT-SP-16320) issued to Digital Wave.  Current NIOSH approvals held by Scott Safety include only cylinders with special permits held by Luxfer.

In the event that a customer should begin utilizing the MAE testing method for requalification of their SCBA cylinders, it is important to understand the regulatory impact that the use of that cylinder may have on the SCBA.  If using a MAE requalified cylinder on the Air-Pak SCBA, the NIOSH approval granted for that SCBA would not apply, and therefore the Air-Pak SCBA with cylinder would also not be NFPA certified.  Should Scott Safety decide to pursue the use of MAE testing, a new special permit would have to be added to the NIOSH approval of the Air-Pak SCBA, and subsequently a communication would be distilled through our authorized channel partner network.

Should you have any questions or concerns, please contact your Scott Regional Manager, Field Service Specialist, or Customer Service Representative at 1-800-247-7257.