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Luxfer hoop-wrapped carbon or aramid fibre gas cylindersGuide for the use, maintenance and periodic inspection in Europe of hoop-wrapped Luxfer cylinders (carbon or aramid fibre)
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This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps taken by Luxfer and its subsidiaries (“Luxfer”), for financial year ended December 31, 2018, to ensure that slavery and human trafficking is not ongoing within any of the Luxfer’s businesses or supply chains.
Introduction
Luxfer is aware that modern slavery takes various forms, including slavery, servitude, forced labour, child labour and human trafficking, and that it is a global and growing issue. Luxfer has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all of its business dealings and relationships. Luxfer encourages all stakeholders in its businesses to bring to its attention issues or grievances relating to any potential human rights concerns.
Organisational Structure
Luxfer is a global materials technology company, specialising in the design, manufacture and supply of high-performance materials, components and high-pressure gas-containment devices for healthcare, environmental, protection and speciality end-markets. Headquartered in Manchester, UK, Luxfer has a global presence employing over 1,600 staff and operating from twenty manufacturingplants plants based in seven countries. In 2018 our total revenue was approximately $487 million.
Luxfer is organised into five business units:
Supply Chain
Luxfer has a very broad-based and complex supply chain, which includes the sourcing of primary magnesium, aluminium log and alloys, zirconium sand, rare earth metals, carbon fibre and other speciality chemical compounds and intermediaries. Luxfer is aware that multiple risks accompany such a complex supply chain, including the possibility that modern slavery may be taking place.
Relevant Policies
Luxfer’s internal policies include:
Due Diligence and Audit of Suppliers
Businesses within Luxfer operate a supplier selection process and have considerable knowledge and understanding of many of the major suppliers, with whom they have a close, long standing business relationship. While Luxfer sources a significant portion of its material and services from European and North American based suppliers, it is understood that some of the goods and services that are purchased, and the countries from which they are sourced, may carry a greater risk.
As part of Luxfer’s ongoing commitment to identify and mitigate the risk of modern slavery in its supply chains, the following steps will continue to be undertaken:
In order to ensure the adequacy of the actions being undertaken by Luxfer, there has been an audit of the procurement strategy for each business unit and the implementation of a company-wide process specifically centred around taking steps to ensure Luxfer suppliers are compliant with expected ethical standards.
In undertaking these audits, examples of best practice have been highlighted and communicated throughout Luxfer to encourage the continual improvement of standards. This has included regular audits of supplier sites to ensure compliance with ethical standards reported and outlining any areas for improvement.
This is an ongoing process and Luxfer will continue to review supplier’s practices and their own policies to ensure the future commitment of Luxfer and its suppliers.
Training
Luxfer will continue to provide appropriate training to its employees to ensure a high level of awareness and understanding of the risks and implications of modern slavery in all areas of it business, including its supply chains.
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At Luxfer Gas Cylinders Limited, we recognise the value in diversity as a key differentiator. As such, we are committed to actively and aggressively reducing our gender pay gap. Below is a PDF containing the 2018 Gender Pay Gap report for Luxfer Gas Cylinders.
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Luxfer Gas Cylinders has received questions from cylinder inspectors and users about whether it is necessary to use eddy-current devices to test Luxfer scuba cylinders made from aluminum alloy 6061 (AA6061).
Eddy-current testing is used to detect sustained-load cracking (SLC) in aluminum alloy cylinders. The majority of Luxfer aluminum alloy cylinders in service today are made from Luxfer AA6061 alloy, which is not susceptible to SLC.
For all scuba cylinders made from Luxfer AA6061, the Luxfer manufacturer’s requirement is that cylinders conform to regulatory requirements for periodic inspection and testing in the countries in which cylinders are being used. Luxfer does not require or recommend eddy-current testing of these AA6061 cylinders.
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Guide to the use, maintenance and periodic inspection of Luxfer G-Stor™ carbon composite Alternative Fuel cylinders.
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Torques greater than the maximum specified are unnecessary and can damage the valve and in extreme over-torque cases might create unsafe conditions.
High over-torques can split the knob into 2 or 3 pieces. A cracked or split knob does not affect valve sealing; however, it indicates excessive torque applied to the knob. Replace a cracked or split knob immediately.
Please see the attached PDF file for further support.
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ALUMINIUM ALLOY CYLINDERS FOR UNDERWATER BREATHING APPARATUS
Statement for UK Diving Industry – March 2018
1. All Luxfer cylinders manufactured from aluminium alloys AA6351 and HE30/AA6082 and used primarily for gases for underwater breathing apparatus must undergo a thorough visual inspection by a trained, properly qualified inspector and be tested with an eddy-current device, in addition to testing required by the regulatory authority, at the time of periodic inspection and testing. Cylinders manufactured from these alloys are known to be susceptible to sustained-load cracking (SLC). Cylinders to be inspected and tested include those used for SCUBA diving, those that supply breathing air through an umbilical hose and those used to fill SCUBA cylinders. Failure to conduct such inspection and testing could result in serious harm.
2. Luxfer-required eddy-current testing is in addition to any other testing normally done during periodic inspection and testing. Luxfer approves two eddy-current devices, Visual Plus? and Visual Eddy™, for such testing. Periodic inspection and testing of these cylinders should occur at least every five years.
3. For Luxfer underwater breathing apparatus cylinders made from aluminium alloy 6061 (AA6061), Luxfer’s manufacturer’s requirement is that every five years a cylinder be visually inspected by a qualified inspector and also undergo testing required by the regulatory authority. Luxfer does not require eddy-current testing of Luxfer underwater breathing apparatus cylinders made from Luxfer’s proprietary version of AA6061, which is marketed under the trade name Luxfer L6X® or as ‘6061 (a proprietary blend)’. The vast majority of Luxfer aluminium cylinders in service today are made from this alloy, which is not susceptible to SLC.
4. Luxfer does not object to more frequent visual inspection of diving cylinders, typically annually or every 2.5 years, if the diving industry and/or regulatory authorities believe it useful to promote safety. Luxfer has supported such choices of the industry and regulatory authorities in the past and continues to do so.
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The following serial numbers of Luxfer medical oxygen cylinder model ME24 with an original hydrostatic test date of 08/15 are under recall by Luxfer Gas Cylinders. The reason for the recall is that the cylinders may fall outside of the design specification.
If you find that you are in possession of any cylinders on this list, please contact Luxfer Gas Cylinders customer service toll-free at 800-764-0366 for information regarding the return of cylinders to Luxfer.
This recall does not affect any other Luxfer products outside of the list or original manufacture date of 08/15.
BX302116
BX302118
BX302143
BX302200
BX302237
BX302250
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Luxfer Gas Cylinders sometimes receives inquiries about whether our aluminum and aluminum-lined composite medical cylinders are MRI compatible. The term "MR or MRI Compatible" has been superseded by the current ASTM International terminology: "MR Conditional," which is defined as "an item that has been demonstrated to pose no known hazards in a specified MRI environment with specified conditions of use." Field conditions that define a particular MRI environment include static magnetic field strength, spatial gradient, dB/dt (time varying magnetic fields), radio frequency (RF) fields and specific absorption rate (SAR).
Whichever term is used, the question remains: Can Luxfer medical cylinders be safely used in close proximity to magnetic resonance imaging (MRI) and other types of medical equipment that emit magnetic fields? The general answer to that question is: Yes.
In addition to our own testing, Luxfer commissioned in-depth third-party testing of our medical cylinders, covering all combinations of aluminum alloy and monolithic/composite construction. The third-party test report concluded: "For each cylinder tested, no apparent magnetic field interactions were detected under the conditional used for testing. Thus, each cylinder product may be considered 'MR Conditional at 3-Tesla or less.'"
Please note that Luxfer's statement and the cited test results apply only to Luxfer aluminum alloy and composite cylinders and do not apply to valves, regulators, handles, carts or any other equipment that may be either attached to or used in combination with Luxfer cylinders. Always ensure that any such ancillary equipment also meets ASTM or other applicable safety criteria for use in proximity to MRI equipment.
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For more than a decade, Luxfer has actively researched this matter and participated in detailed deliberations involving DOT, the Compressed Gas Association (CGA) and other cylinder manufacturers to obtain a service-life extension. However, DOT declined to approve life extension for these cylinders. Consequently, Luxfer decided not to pursue this effort further and to take a different approach to providing cylinders with longer service life.
BackgroundIn 1996, DOT issued its CCFC-1 standard that established basic requirements for design, manufacture and performance of cylinders consisting of seamless aluminum liners over-wrapped with structural layers of filament-wound carbon fiber and epoxy composite material. At that time, DOT offered the possibility of extending the 15-year service life of such cylinders "up to a total service life of 30 years." To obtain an extension, a cylinder manufacturer was required to submit for DOT approval a "Service Life Extension Plan" that would meet certain criteria. Soon after CCFC-1 was issued, Luxfer and other U.S. cylinder manufacturers individually submitted such life-extension plans to DOT. However, DOT accepted none of these plans and declined to extend cylinder service life.
In response, cylinder manufacturers attempted an industry-wide approach to obtain DOT approval under the auspices of a special CGA task group, but the service life was not extended.
Luxfer's longer-life composite cylinderIn 2006, Luxfer began developing a new, more robust cylinder designed for a service life longer than 15 years. This new cylinder was based on ISO 11119, an international design standard. In August 2008, DOT granted Luxfer special permit 14232 (SP14232), which authorizes the manufacture of these cylinders for use in the United States.
While cylinders made under SP14232 are designed for service lives as long as 30 years, the special permit explicitly sets forth certain testing and validation requirements that must be met before the service life of any cylinder may be extended beyond 15 years. As of the issue date of this bulletin, no cylinder manufactured under SP14232 has thus far been approved for a service life longer than 15 years since these cylinders have not yet reached the age at which their service life will be eligible for extension.
For more information, please use the DOT links below or contact Luxfer Gas Cylinders at 951-341-2348.
U.S. Department of Transportation special permits searchDOT-CFFC (Basic requirements for fully-wrapped carbon fiber reinforced aluminum-lined)
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SLC is a thoroughly researched and well-documented metallurgical phenomenon that occasionally develops in cylinders made from 6351 alloy, as well as in other types of pressure vessels and structural components under stress for sustained periods of time. SLC has occurred in cylinders manufactured by various companies, including Luxfer. Cylinders that have been mechanically damaged, over-filled or otherwise abused are more susceptible to SLC, which is not a manufacturing defect, but a phenomenon inherent in the metal itself.
Research has consistently shown that sustained-load cracks grow very slowly, typically taking eight or more years to grow large enough to cause a cylinder leak or, in extremely rare cases, a rupture. Because SLC growth is so slow, properly trained inspectors have adequate opportunity to detect cracks and remove cylinders from service during normal annual inspections or as part of the DOT-required requalification process every five years. Both Luxfer and DOT have long maintained that proper, diligent inspection by correctly trained personnel is the best way to avoid cylinder-related accidents.
It is important to note that SLC has occurred only in a small number of older cylinders made from 6351 aluminum alloy. Cylinders made from 6061 aluminum alloy, the metal currently used by all U.S. manufacturers, have not exhibited SLC.
Luxfer discontinued use of 6351 alloy in June 1988 and since that time has only manufactured scuba cylinders from Luxfer’s proprietary L6X® formula for 6061 aluminum alloy. Out of more than 40 million cylinders, no Luxfer cylinder made from L6X® (6061) alloy has ever exhibited a sustained-load crack.
For more detailed information about SLC, visit the Luxfer website at www.luxfercylinders.com, click “Support” on the top menu bar, click “Frequently Asked Questions” on the left-hand menu and then click the “Sustained-load Cracking (SLC)” heading. For specific dates when Luxfer switched different cylinder models from 6351 to 6061 alloy, click “Support,” then “Technical Bulletins” and scroll down to Dates when Luxfer changed its aluminum alloy from 6351 to 6061 (posted November 12, 2003).
If you have additional questions, call Luxfer’s toll-free customer service line: 800-764-0366.
1See Department of Transportation: HM-220F, Federal Register, Vol. 71, No. 167, pages 51122-51129.
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All-metal Luxfer 6061 aluminum alloy (L6X®) cylinders1—To remove paint from an all-metal cylinder and prepare the surface for repainting, blast with plastic, glass or other soft media just long enough to remove most of the old paint. Do not blast with sand, steel, grit or aluminum oxide media, which are too abrasive. Heavy or improper blasting with hard or overly abrasive media removes metal as well as paint from the cylinder, which can thin the cylinder wall and make the cylinder unsafe to fill or use. Improper blasting also obliterates stamped markings and damages the outer surface of the cylinder.
Never use corrosive, caustic or acidic paint strippers or solvents to remove paint. Never use burning or torching techniques. Do not use knives or other sharp instruments to remove labels.
Once paint has been removed, use a neutral, mild, water-based detergent to wash the cylinder. Rinse the cylinder well and thoroughly dry it at a metal temperature not exceeding 160 degrees F (70 degrees C). Carefully inspect the cylinder surface for damage and corrosion in accordance with all applicable regulations. If the cylinder passes the inspection, it is ready for repainting.
Composite cylinders—Do not attempt to remove intact old paint from composite cylinders by blasting or any other means that may damage the cylinder exterior. Lightly rub the surface with fine-grit emery paper to prepare it for repainting. If the surface is dirty, clean it with a neutral, mild, water-based detergent, then rinse it well and dry it thoroughly.
Never use corrosive, caustic or acidic paint strippers or solvents to remove paint or to clean composite cylinders. Never use burning or torching techniques. Do not use knives or other sharp instruments to remove labels.
Once the outer surface of the cylinder is clean, inspect it for damage in accordance with all applicable regulations. If the cylinder passes the inspection, it is ready for repainting.
All cylinder types—Do not use the above preparatory processes on the internal surface and thread area of any Luxfer cylinder. Different processes (not covered by this document) should be used to clean threads and internal surfaces.
While preparing a cylinder exterior for painting, take care not to damage the valve connection area or cylinder threads. Do not allow any process materials (e.g., cleaning agents, blast media, grit, etc.) to contaminate the threads and inside of the cylinder.
PaintingAll-metal Luxfer 6061 aluminum alloy (L6X®) cylinders—Do not use acidic or caustic paints that may damage the cylinder exterior. You may use any neutral, air-drying or aliphatic, water-based or solvent-based liquid paint that is compatible with aluminum. You may also use neutral, aluminum-compatible powder coatings as long as curing temperatures and exposure times do not exceed those recommended by Luxfer. Please note that different aluminum alloys have different maximum-temperature specifications; for example, for Luxfer 6061-alloy (L6X®) cylinders, the maximum metal temperature must not exceed 350ºF (175ºC). Exposure times at various temperatures vary according to alloy. Please contact Luxfer for time/temperature information about the particular cylinder and alloy that you intend to repaint using powder coatings. Cylinders subjected to temperatures and exposure times exceeding Luxfer recommendations or heated to unknown temperatures must pass hydrostatic tests before being filled or used.
Composite cylinders—Use flame-retardant, air-drying or aliphatic, water-based or solvent-based epoxy or polyurethane liquid paints on Luxfer composite cylinders. Do not heat cylinders to speed up curing or drying of paint. Do not use powder coatings or other coatings that must be heated or baked. Never expose composite cylinders to heat exceeding 180ºF (82ºC).
Do not paint over cylinder labels. Mask labels before painting and make sure that they remain legible. (Note: Color coding cylinders to identify gas contents or usage does not eliminate the regulatory requirement for legible, properly configured labels.)
All cylinder types—Do not allow paint to contaminate the threads, valve connection area or internal surface of any Luxfer cylinder.
1Luxfer markets its proprietary version of 6061 aluminum alloy under the registered trade name L6X