Aluminum scuba cylinders in oxygen-enriched and oxygen service – why does Luxfer require cleaning for oxygen concentrations above 23.5%?

Few concepts have caused more confusion and controversy in the recreational diving industry than the so-called “40% rule.” While there seems to be general agreement that special cleaning is required when a pressurized oxygen concentration reaches a particular “threshold” percentage, there is disagreement about exactly what that threshold should be and at what pressure it becomes important. Some say 40%; others say 23.5%; still others say anything more than 21% when a gas mixture is pressurized more than 100 psig. It would be helpful to explore the background of this confusion briefly before discussing Luxfer’s position on this vital subject.

The 40% threshold is cited in a single Federal CFR published by the Occupational Safety and Health Administration (OSHA) of the U.S. Department of Labor: 29CFR910.430, which applies to “Commercial Diving Operations” and states in the section titled “Oxygen safety” on page 854: “(1) Equipment used with oxygen or mixtures containing over forty percent (40%) by volume oxygen shall be designed for oxygen service. (2) Components (except umbilicals) exposed to oxygen or mixtures containing over forty percent (40%) by volume oxygen shall be cleaned of flammable materials before use.”

Please note that OSHA also provides a very specific definition about who should—and should not—be considered a “commercial diver” to whom the 40% threshold applies: “Commercial diver means a diver engaged in underwater work for hire excluding sport and recreational diving and the instruction thereof” (46CFR197, page 409; italics added for emphasis).

Even though OSHA clearly excludes sport and recreational divers from the CFR that specifies a 40% threshold, some professionals in the recreational diving industry have nonetheless been citing the OSHA “rule” for many years and maintaining that special cleaning of recreational diving equipment is not necessary with oxygen concentrations of 40% or less. These advocates of the “40% rule” have often stated that the U.S. Navy supports their position, which at one time was true—but no more. In the current applicable military specification (Mil-Std-1330D), the Navy specifies a 25% threshold for oxygen cleaning. Compounding the confusion is the fact that two other OSHA documents, 29CFR1910.146 and 29CFR1910.134, specify an oxygen threshold of 23.5%.

For the sake of clarity, here’s a summary of the oxygen threshold percentages at which various key U.S. agencies and organizations require special cleaning of oxygen-handling equipment and systems:

U.S. Navy

>25%

Mil-Std-1330D

U.S. Compressed Gas Association (CGA)

>23.5%

CGA Pamphlet 4.4

National Fire Prevention Association (NFPA)

>21 – 25%

NFPA standards

American Society for Testing & Materials (ASTM)

>25%

G126, G128, G63, G94

National Aeronautical & Space Administration (NASA)

>21%/>100 psig

Various KSC & JSC

Occupational Safety & Health Administration (OSHA)

>23.5%

29CFR1910.146

OSHA

>23.5%

29CFR1910.134

OSHA

>40%

29CFR1910.430

The reasons for Luxfer’s position: Luxfer supports an oxygen-cleaning threshold of 23.5% and does not support the alleged “40% rule.” This means that when a pressurized oxygen concentration used in a Luxfer cylinder exceeds 23.5%, the cylinder must have been cleaned to the same cleanliness standard mandated for a cylinder containing 100% oxygen. Luxfer’s reasons for this position are:

• All key U.S. regulatory and gas industry references except one advocate an oxygen threshold of 21% to 25%.
• Luxfer is a member of the Compressed Gas Association and therefore supports the CGA-specified threshold of 23.5%. Furthermore, Luxfer defers to CGA on all safety matters related to oxygen handling and containment, as do OSHA and DOT.
• As an international manufacturer, Luxfer works with regulatory authorities and industry associations around the world—the overwhelming majority of which support a threshold value from 21% to 25% (for example, this is true in the United Kingdom, Australia, France, Germany and Japan).
• United Nations compressed air packaging guidelines (see UN 1002) indicate that when compressed air contains oxygen as the only oxidizing gas and the oxygen concentration exceeds 23.5%, then the entire gas mixture must be listed as an oxidizing gas.

Some within the recreational diving community contend that the supposed “40% rule” is justified by an excellent scuba safety record and should therefore be maintained—despite the fact that so many agencies and organizations have specified much lower threshold values for oxygen cleaning. Luxfer finds this “history-of-use” argument unconvincing for the following reasons:

• Compared to other industries and organizations that use pressurized oxygen, oxygen usage in the recreational diving industry has not been sufficiently widespread, nor are available oxygen-use statistics sufficiently comprehensive, to declare a successful history of use for the 40% threshold.
• Oxygen-related fires and explosions are inherently low-probability, high-consequence events—which means that they occur very infrequently, but are usually catastrophic when they do. Forensic evidence has shown that undetected, non-propagating fires happen within scuba oxygen systems more frequently than is generally known. It is possible to operate “on the edge” of a fire for years without knowing it—and to be lulled into complacency by seemingly “safe” performance.
• As use of higher oxygen concentrations at higher pressures increases in the recreational diving industry, the risk of serious accidents will also increase.

Under these circumstances, Luxfer believes that requiring thorough oxygen cleanliness at a threshold of 23.5% makes very good sense not only for the sake of individual safety, but also from the business standpoint of prudent risk management.