Well the part about breathing is something passive, just like Ito Ito makes Doflamingo a stringman and Gomu Gomu makes Luffy a rubberman. As it turns the user into a lung, it would allow him to breathe naturally underwater due to being a powerful lung, without that meaning that he'd be able to survive underwater for ages. He'd still be unable to move and do anything else at all. In fact, it's like a disadvantage from the way I see it as the user could be down underwater, too weak to do anything and survive, while also being unable to die.
The original idea was that the user could be capable of infinitely using a gas he has stored inside his body (which is a lung) so that he could simply recycle the gas over and over again inside his body until he exhaled it, but that would be too OPed. Thus, I decided to stick with the submitted version that allowed him to be capable of simply breathing anywhere. Then again, I can see what your concern is, so it's your call.