CGA Shares Medical Oxygen Safety Resources with California Agency Providing Oxygen for COVID-19 Patients

February 19, 2021

Recently, Compressed Gas Association (CGA) staff learned from a January 29, 2021 Los Angeles Times article that a state task force is building oxygen supply depots in an effort to alleviate oxygen supply and distribution issues in California. The article notes that depots, which are staffed by personnel from the California Emergency Medical Services Authority (EMSA), are using oxygen concentrators to fill cylinders for hospitals.

On February 11, 2021, Rich Craig, CGA’s Vice President, Technical & Regulatory Affairs, sent a message to Dr. Dave Duncan, Director of California’s Emergency Medical Services Authority, offering a set of medical oxygen safety resources and safe practices, to aid EMSA in the safe rollout of the oxygen supply depots. Dr. Duncan promptly replied to Rich Craig’s message, indicating that CGA’s information about the safe use of medical oxygen “will be incorporated into our operations and safety documentation.”

We provide a reprint of Rich Craig’s letter here:

CGA Letter to California Emergency Medical Services Authority

February 11, 2021

Dear Dr. Duncan;

We recently learned that a California state task force is building oxygen supply depots in an effort to alleviate oxygen supply and distribution issues in the state. It is our understanding that the depots, which are staffed by personnel from the Emergency Medical Services Authority, are using oxygen concentrators to fill cylinders for hospitals. While oxygen has hazardous properties, the hazards can be effectively managed by following safe practices. We are reaching out to you to share some essential safety information related to medical oxygen, to help keep your personnel and communities, safe.

The Compressed Gas Association (CGA), founded in 1913, is dedicated to the development and promotion of safety standards and safe practices in the industrial, medical, and food gases industry. CGA represents more than 130 member companies in all facets of the industry – manufacturers, distributors, suppliers, and transporters of gases, cryogenic liquids, and related products and services. Through a committee system, CGA develops technical specifications, safety standards, and training and educational materials, and works with government agencies to formulate responsible regulations and standards and to promote compliance with these regulations and standards.

Medical Oxygen Cylinder Inspection and Filling

When filling high pressure cylinders with medical oxygen it is essential to be familiar with the hazardous properties of oxygen, required safety precautions, and the applicable government regulations. Filling high pressure cylinders with medical oxygen requires personnel be trained in drug manufacturing, as prescribed by U.S. Food and Drug Administration (FDA) requirements.  Personnel must also be trained in inspecting the cylinders to ensure they are safe to fill, as prescribed by U.S. Department of Transportation (DOT) regulations. Failure to comply with either the FDA or DOT requirements can result in cylinders containing drug product that is inappropriate or hazardous to use, or cylinders that present hazards to anyone filling, transporting, or using them.

CGA has several standards and guidelines covering both these activities. We are providing the publications listed below to you at no charge to provide safety information for any EMSA personnel involved in the filling, transportation, and handling of these cylinders to help them know the requirements and complete these tasks in a safe manner, and to ensure that patients receive medical oxygen that is free from contamination and is safe to use.

CGA publications provided:

  • CGA C-6, Standard for Visual Inspection of Steel Compressed Gas Cylinders;
  • CGA C-6.1, Standard for Visual Inspection of High Pressure Aluminum Alloy Compressed Gas Cylinders;
  • CGA C-6.2, Standard for Visual Inspection and Requalification of Fiber Reinforced High Pressure Cylinders;
  • CGA G-4, Oxygen;
  • CGA P-15, Standard for the Filling of Industrial and Medical Nonflammable Compressed Gas Cylinders;
  • CGA P-83, Guidelines for Cleaning Externally Contaminated Medical Gas Containers; and
  • CGA SA-24, Safety Alert, Emergency Medical Services Filling Oxygen or Air for Human Respiration.

Hazards of Oxygen-Enriched Atmospheres

We also understand that patients are being released from the hospital with medical oxygen cylinders to enable their recovery at home. Improper use of high pressure oxygen in and around various ignition sources has led to incidents. To avoid incidents involving oxygen and oxygen-enriched atmospheres (mixtures or atmospheres containing greater than 23.5% oxygen), it is important to understand the associated risks.

Although oxygen itself does not burn, it does support and enhance combustion. Materials that burn in air, such as clothing and bed linens, will burn fiercely in an oxygen-enriched atmosphere. Materials that can be ignited in air require less energy to ignite in an oxygen-enriched atmosphere. Many of these materials can be ignited by different sources of ignition such as smoking or open flames, friction or expansion when oxygen at high pressure is rapidly introduced into a system that is initially at low pressure.

Following simple DO’s and DON’T’s can reduce the risk of incidents caused by oxygen enrichment.

In addition to the practices outlined in any manufacturer’s instructions provided, use the following safe practices where medical oxygen is in use:

DO NOT

  • DO NOT allow smoking or flames in the vicinity of oxygen use;
  • DO NOT allow lotions, oils, grease, household lubricants, or other combustible materials to come in contact with oxygen or its containers, valves, regulators, gauges, hoses, and fittings. Combustibles and oxygen can combine with explosive force;
  • DO NOT handle containers or apparatus immediately after using lotions or moisturizers;
  • DO NOT lubricate hoses, cannulas, valves, regulators, gauges, or fittings with lubricants or any other combustible substance;
  • DO NOT use an open flame to detect gas leaks;
  • DO NOT subject any part of a compressed gas container to a temperature greater than 125 °F (51.7 °C);
  • DO NOT place containers where they can become part of an electric circuit;
  • DO NOT let sparks or a flame come in contact with any part of an oxygen container, regulator, tubing, or other equipment;
  • DO NOT deface or remove any markings or labels used to identify the contents of a container;
  • DO NOT modify, replace, or add adaptors to existing connections;
  • DO NOT change, modify, tamper with, or obstruct the discharge ports of pressure relief devices; and
  • DO NOT use containers for any purpose other than to supply medical oxygen as received from the supplier.

DO

  • DO ensure that connections to tubing, regulators, and other equipment are tight to prevent leakage;
  • DO ensure only equipment suitable for medical oxygen use is connected;
  • DO keep hoses, cannulas, and masks in good condition;
  • DO open the cylinder valve slowly and completely after connecting to equipment;
  • DO remove any wrapping from cylinders or valves before use;
  • DO identify the gas content by the label before use. If the container does not have a label or the label is not readable, return the unused cylinder to the supplier. If the label does not correctly identify the gas contained in a cylinder, return the unused cylinder to the supplier;
  • DO read, understand, and follow all warning and precautionary handling information on the labels;
  • DO follow all signage provided by the oxygen supplier;
  • DO close the valve prior to disconnecting or replacing the cylinder;
  • DO close the valve and ensure that the valve protective cap and outlet caps or plugs, if used, are replaced before returning;
  • DO keep valves closed when the gas is not being used;
  • DO notify the oxygen supplier and isolate the cylinder if a foreign substance is present in or could have entered the valve outlet connection;
  • DO provide the oxygen supplier with complete details regarding any complaint or event involving the container or product including the container lot and serial number, and then isolate the container to prevent use;
  • DO ensure only experienced and properly instructed persons handle oxygen containers; and
  • DO isolate the container and move it to a well ventilated area if a leak is suspected, and it is safe to do so.

We are also providing a safety poster, Home Oxygen Safety, that addresses many of these items. Please feel free to provide this poster to patients discharged with medical oxygen cylinders. This poster and other safety information is also available on our Home Oxygen Safety Resource Center on the CGA website.

If you have any questions about this information, please contact me. CGA is committed to working with you to ensure that you and your employees have the information needed to facilitate a safe response to the COVID-19 pandemic.

Thank you,

Richard Craig
Vice President, Technical & Regulatory Affairs
Compressed Gas Association