(from Lifesaving Resources)
We continue to receive numerous questions regarding the concerns and rumors
pertaining to the administration of oxygen by Lifeguards and other First
Responders. Lifesaving Resources has always advocated the need to administer
oxygen when responding to respiratory and/or cardiac emergencies, and
trauma incidents such as severe bleeding and suspected spinal injury.
As for drowning/near-drowning incidents, these are hypoxic incidents and
oxygen administration, suction, and defibrillation should be included
within the protocol when responding to such incidents.
The following should help clear up any misunderstandings regarding the
efficacy of implementing the use of oxygen within the emergency response
protocols of Lifeguards and First Responders:
Three federal agencies have oversight of oxygen. The Food and Drug Administration
(FDA) considers medical oxygen to be a drug, and under its authority regulates
the distribution, filling and labeling of oxygen devices. The Department
of Transportation (DOT) sets standards for the transportation of oxygen
and the Department of Labor's Occupational Safety and Health Administration
(OSHA) sets standards on workplace safety, which includes the use of oxygen
equipment for first aid care.
Food and Drug Administration
FDA's regulation of oxygen is defined by the dose and duration of the
oxygen administration. When the dose of oxygen is delivered for less than
6 liters per minute or for a duration of less than 15 minutes, a prescription
for oxygen is required. When oxygen is delivered at a dose of at least
6 liters per minute or for a duration of more than 15 minutes, it is considered
first aid use, commonly called "emergency oxygen" and does not require
a prescription.
Note: When oxygen is administered for emergency use, it is typically administered
at the rate of 10 - 25 liters per minute via Non-Rebreathing Mask or Bag-Valve-Mask
Resuscitator.
Applicability to Oxygen Administration Programs
Federal regulations do not require the agencies/organizations obtain a
prescription to purchase emergency oxygen for training purposes or use
at a first aid station. Oxygen for emergency use must be labeled with
the words "emergency oxygen." Emergency oxygen is available from medical
suppliers as an over-the-counter (OTC) product. A written prescription
is not required for these devices.
Department of Transportation
The Department of Transportation (DOT) regulations list oxygen as a category
2.1 material (flammable gas) which is subject to regulation. However,
a "materials of trade" exception exempts private motor vehicles not ordinarily
engaged in the business of transporting hazardous materials.
The placarding of vehicles carrying oxygen also falls under the regulatory
authority of the DOT. Those who transport less than 1001 pounds of this
hazardous material are exempt from the requirement of displaying placards
on vehicles.
Applicability
A standard "D" size oxygen cylinder contains just over one pound of oxygen.
The regulation's materials of trade exception allows for the transport
of up to 220 pounds of oxygen without having to comply with the packaging
and transportation requirements regarding oxygen cylinders. Vehicles do
not have to display placards when transporting oxygen for use in training
courses or first aid stations unless more than 1000 pounds of oxygen are
being moved.
Occupational Safety and Health Administration
OSHA standards relating to oxygen apply to the handling, storage and utilization
of compressed gases. The storage and handling requirements listed below
comply with OSHA regulations pertaining to workplace safety.
State Specific Regulations
Currently, only the State of Utah requires that an instructor who teaches
oxygen administration must be a certified respiratory therapist. A waiver
to this regulation is being sought. The Office of General Counsel has
reviewed the regulations in each of the 50 states and found no additional
state regulations on the use of emergency oxygen as it relates to child
labor, instruction or additional training requirements.
For more Information please contact;
Gerald M. Dworkin, Consultant
Aquatics Safety & Water Rescue
Lifesaving Resources Inc.
admin@lifesaving.com
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