Topic: NFPA Codes & Standards Process Updates

Latest action on firefighting PPE standard underscores the need to better understand and to participate in the standards process

In June of this year I wrote a blog explaining how individuals could get involved in the conversation about NFPA standards and firefighter PPE. That blog provides a good overview for reference, and this piece provides a further update related to one particular standard - NFPA 1971, Standard on Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting, 2018 Edition. Since that time, a few additional pieces of the NFPA process have occurred and I believe this is a good time to review the overall timeline of this issue and how the various parts of the process play a role. The topic at hand centers around the concern of PFOA’s in firefighter turnout gear.  Proponents with the concern around PFOA’s have focused on a particular test – an ultraviolet light degradation test that is used to accelerate aging of the moisture barrier as part of overall performance testing.  During 1999 and the early 2000’s there were significant concerns raised by first responders about the degradation of moisture barriers in the field and, as a result, the UV degradation test was added to the standard in the 2007 edition.  The committee statement read in part “… that moisture barriers should be tested for resistance to degradation by light and has proposed a new test …”  For reference, the test was added with a technical committee vote of 30-1 and a correlating committee vote of 21-0 supporting the addition of the new requirement. Since the 2007 edition and over the past three editions, covering 15 years, there have been no recommended changes proposed to modify or delete the requirements for this UV test. Enter the TIA In May of 2021, a Tentative Interim Amendment (TIA) was filed to remove the UV test from the standard.  A TIA is a part of the NFPA process where the standard may be revised on an emergency basis between its normal revision cycles.  It is “tentative” because, if it passes the technical committee, it only remains in effect for that edition of the standard and is automatically submitted as a proposed language for the next edition of the standard.  It is “interim” because it is happening in between the normal revision cycles.  TIA’s also must receive a three-fourths affirmative vote of the technical committee and correlating committee (versus the normal two thirds affirmative during a regular revision cycle) because amending a standard in this way means it doesn’t go through the usual two rounds of public review.  Both the Technical Committee and the Correlating Committee reviewed the submitted material as well the public comments received on the TIA.  The TIA failed to gain the necessary support of the Technical Committee on technical merit and emergency nature and failed to gain the necessary support of the Correlating Committee on both correlation and emergency nature. It is clear from the voting comments that there are strong technical views on both sides of the issue.  Those views are also quite diverse among the various interests on the committee.  Take just one example – those on the committee that represent the fire service.  Ten fire service representatives on the technical committee voted on the TIA – two voted in favor of the TIA and six voted against the TIA, with two votes to abstain.  See the complete ballot results and ballot statements from the technical committee members and for the Correlating Committee members. For the NFPA process, what is important to understand is that the technical experts – the Technical Committee members charged with reviewing the submitted information – did not have agreement on accepting the deletion of the UV test. Appealing to the Standards Council As part of the NFPA process, participants can appeal Technical Committee actions on TIA’s to the NFPA Standards Council.  The Standards Council is made up of 13 volunteer members (none of whom are NFPA staff), who oversee the NFPA standards development process.  The Standards Council is NOT a technical body.  The Council does not have the expertise that is found on NFPA Technical Committees.  They exist to ensure the integrity of the NFPA process and to ensure the Regulations for the Development of NFPA Standards are followed.  For more information on the NFPA process and the overall roles and responsibilities of the various bodies see “A Primer on how NFPA Standards are Developed and Revised, and by Whom.”   An appeal was made to the NFPA Standards Council asking them to reverse the decision and vote of the Technical Committee and accept the TIA.  After hearing the appeal and reviewing all of the evidence, the Standards Council voted to deny the appeal.   You can review more information on that decision in my blog posted in September. Throughout the processing of the TIA, several serious safety concerns were raised by firefighters and others on both sides of the technical issue. Ultimately, the NFPA Standards Council determined that the balanced consensus Technical Committee and the Task Group (chaired by a representative from the fire service) that had recently been established by the committee to address this issue were in the best position to review all the technical and scientific information and to determine a proposed technical solution that provides the vital lifesaving performance requirements of firefighter PPE, including the moisture barrier, and addresses the health risks to first responders. Petitioning the NFPA Board of Directors An additional, and extraordinary step in the NFPA process allows a petition to be made to the Board of Directors to review a decision by the Standards Council. In accordance with NFPA regulations, petitions to the Board are intended to address extraordinary circumstances where the integrity of the standards development process was believed to have been violated or action by the Board is otherwise necessary to protect the organization.  A petition was filed with the Board of Directors asking for a review of the Standards Council’s decision on the NFPA 1971 TIA. The petition asked the NFPA Board to override the decision of the Standards Council, the vote of the Correlating Committee, and the vote of the Technical Committee and to issue the TIA to delete the UV light degradation test requirement and test method.  On November 2, 2021, the NFPA Board Petitions Subcommittee reviewed the record and on November 4, 2021, denied the petition, upholding the Council’s decision and the results yielded by the standards development process. This is a good spot to pause and discuss the importance of the steps in the process.  In this instance, had the NFPA Board Petitions Subcommittee or the Standards Council upheld the petition or appeal, respectively, they would have substituted their technical judgement for that of the Technical Committee.  Remember that neither the Board nor the Standards Council are technical bodies.  Nonetheless, arguments made in the Board Petition, as well as the appeal to the Council, focused on technical evidence and an assertion that the Technical Committee was simply wrong.   The appeal was denied by the Standards Council and the decision was upheld by the Petitions Subcommittee not because the UV test is technically appropriate or not, but because in this instance neither the Standards Council nor the Board Subcommittee found reason to overturn the technical committee’s decision.   The NFPA process is an open, balanced process, where the responsible technical committees of experts appointed by the NFPA Standards Council make the technical decisions and the Standards Council and Board are appellant bodies ensuring that the NFPA process is followed in accordance with the Regulations Governing the Development of NFPA Standards. Where does the issue go from here? This issue is important to many stakeholders. The best way to effect changes in NFPA standards is by participating in the NFPA process and proposing changes to the standard.  I previously outlined this process in my blog from June 3, 2021.  The Technical Committee gives consideration and review to all public submissions that come through the process.  It’s also important to note that ANYONE (other than NFPA staff) can submit a proposed change to the text of the standard through the process. IMPORTANT NOTE - As of the writing of this blog – there are no proposed changes relating to this UV test for the next edition, nor are there any proposed changes addressing the use or prohibition on the use of PFOAs for the next edition. Anyone who believes the standard should be changed to address these topics is strongly encouraged to submit proposed changes (public input) to the next edition of the standard (which will be a consolidated standard as NFPA 1970). You do not have to be an NFPA member or on an NFPA Technical Committee to provide input.  Anyone (except NFPA staff) can propose a change to the standard by suggesting specific wording and providing a technical rationale through our online submission system, which is accessible at nfpa.org/1970next.  Time is short as the deadline for Public Input is November 10, 2021. In the following months, the Technical and Correlating Committees will consider all of the proposed changes received by the deadline and will develop a First Draft of NFPA 1970.  NFPA anticipates that the First Draft Reports will be posted for public review in the Fall of 2022. Throughout the process, the latest information on this standard can be found at nfpa.org/1970next.
Sprinkler head

Are You Up to Speed on Changes within the 2022 Edition of NFPA 13?

The recently released 2022 edition of NFPA 13, Standard for the Installation of Sprinkler Systems contains a number of significant changes. While the 2019 edition of the standard underwent a dramatic reorganization, it was a relatively quiet cycle for technical revisions. The 2022 edition of the standard; however, makes up for that with many updates that will affect all the different users of the document. Here I will list a handful of the most notable changes featured in the new edition. With 275 First Revisions and 234 Second Revisions made during the revision cycle this is by no means an all-inclusive list. The most important change in a document tends to be the one we are dealing with at the exact moment on a particular project but with that said, here are some that might come up more than others. Single point density This is perhaps as big a fundamental shift in the application of NFPA 13 as we have seen in a long time. For decades users have been familiar with using density/area curve to calculate sprinkler density, but the 2022 edition does away with the curves (with an exception for existing systems) in favor of specifying a single-point method of density calculation. An entire article could be dedicated to this issue, but the short version is that not all points along the curves had truly been proven. Some supported it with the argument that at the time of their introduction they could be quite useful based on water supply, but today there is a wider selection of sprinklers with various K-factors that can allow for added flexibility. Rack storage updated again Chapter 25 on the protection of rack storage using in-rack sprinklers has been completely rewritten and reorganized. This chapter consolidates all the in-rack sprinkler design criteria into one chapter. Users can now determine all their protection options for in-rack sprinklers—and the accompanying ceiling sprinkler system—without having to leave the chapter. One notable technical change involves the fact that multiple row racks will need to be limited to a depth of 20 feet or they will need to be considered solid shelving; driving a need for in-rack sprinklers. Remote areas - considering walls This next topic addresses a new paragraph of text added to the standard specifying that where a sprinkler is located next to a full-height wall, the area on the opposite side of the wall cannot be counted toward the total design area even if the sprinkler’s assigned area of discharge would theoretically extend beyond the wall. This could result in additional sprinklers being required to be included in the determination of remote area demands. Some argue that this is a clarification of what has always been intended while others disagree. Either way, this makes it clear as to the approach that must be taken. Nitrogen System Updates Several additions have been made throughout the standard to better address the use of nitrogen for use with dry-pipe sprinkler systems. A key consideration here is the allowance for more favorable friction loss values for new dry pipe systems where nitrogen is used, provided the supply meets a certain set of criteria. Working plans checklist Modifications to the working plans checklist include several new or adjusted items. Those submitting plans, as well as plan reviewers, will need to give this area some additional attention. More hydraulic information signs The standard has been revised to require hydraulic design information signs to be placed in more locations on systems than was previously required. Rather than just at the alarm valve, dry pipe valve, preaction valve, or deluge valve, signs must now be provided at every system riser and every floor control assembly in addition to the locations previously required. This will have additional impact on system ITM as the signs will need inspection as part of NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems requirements.
NFPA's Technical Meeting

A primer on how NFPA standards are developed and revised, and by whom

NFPA standards are developed through an open-consensus process in which anyone (except NFPA staff) can participate. We receive lots of questions about how this time-tested process works from individuals who are not familiar with it as well as from those that are involved in some aspect of it. In answer to these questions, here is a broad overview of how NFPA standards are developed and the parties involved: What is the NFPA standards development process? NFPA facilitates the development of more than 300 standards that cover myriad aspects of building, life, fire, and electrical safety. Each of the standards is revised every three to five years, with each revision cycle opening with a call for Public Input (publicly suggested changes in text to the current edition of a standard) and concluding with the publication of the First Draft Report, which documents the responsible technical committee(s)’s actions and responses to all Public Inputs. Next, the Public Comment period seeks review and suggested changes to the First Draft text. After the committee(s) review and action on the Public Comments, their recommended text changes and responses to all Public Comments are published in the Second Draft Report for additional public review. Then, at the NFPA Technical Meeting each June, there is an opportunity to challenge a proposed change to a standard through a Notice of Intent to Make a Motion (NITMAM), which is submitted in advance of the meeting. Anyone may attend and debate motions, then the NFPA membership in attendance votes to either support the debated motion or the technical committee’s recommended second draft text as presented. The outcome from the public process and committee actions along with the Technical Meeting results are presented to the NFPA Standards Council who decides, based on all evidence, to issue the standard or return the standard to the technical committee for further work if necessary. Can a standard be changed before the next revision cycle? Yes, anyone may submit a Tentative Interim Amendment (TIA), which serves as an emergency recommended change to a standard in advance of the next revision cycle. Among other requirements, all TIAs must include the proposed text to be changed, added, or deleted and a statement of the problem and substantiation for the TIA must be provided, including identifying why the TIA is of an emergency nature requiring prompt attention. Because of the emergency nature of TIAs and the limited public review all TIA’s require three-fourths (75%) approval of the respective Technical and Correlating Committee members to be recommended for issuance by the NFPA Standards Council. Is there an appeals process for standards and TIAs? Yes, all appeals within the NFPA standards process are considered by the NFPA Standards Council. The Standards Council hears any process-related appeals, including those related to standards or TIAs. Appeals are an important part of the process, ensuring that all NFPA rules have been followed and that due process and fairness have continued throughout the standards development process. The Standards Council looks at the written record and conducts hearings when a hearing is granted, during which all interested parties can participate. Appeals are decided on the entire record of the process. It’s important to note that when appeals are made to the Standards Council, the focus of the appeal is based on whether the standards process was executed correctly, and to assess whether the technical committee followed the process correctly, adhering to the NFPARegulations Governing the Development of NFPA Standards at each step. Appeals to the Standards Council are not a further opportunity for technical debate on a topic, to introduce new information, or to review the technical merit of content within the document.  Technical debate and actions are addressed through the public process and by the appropriate Technical Committee of subject matter experts. After deliberating on all appeals related to a standard, the Standards Council either proceeds to issue the standard or to determine any further action as required, including sending the topic back to the respective technical committee for further attention.With respect to appeals on TIAs, the Standards Council determines whether to issue the TIA. Under limited and extraordinary circumstances, a final appeal of the Standards Council action, called a Petition, can be made to the NFPA Board of Directors. In these cases, the NFPA Board of Directors may take necessary action to fulfill its obligation to preserve the integrity of the standards development process. The new NFPA standard or TIA becomes effective 20 days following the Standards Council’s action of issuance. Who does what? NFPA Board of Directors The NFPA Board of Directors, which has general charge of all activities of the NFPA, issues rules and regulations that govern the development of NFPA standards and appoints the 13 members of the NFPA Standards Council. Members of the Standards Council are thoroughly familiar with the standards development process of the association and are selected from a broad range of interests. In extraordinary circumstances the NFPA Board of Directors may take necessary action in review of Standards Council action (through the Petitions process) to fulfill its obligation to preserve the integrity of the standards development process. NFPA Standards Council The NFPA Standards Council is responsible for overseeing NFPA standards development activities, ensuring compliance with the Regulations Governing the Development of NFPA Standards; appointing members to NFPA Technical and Correlating Committees; and serving as the appeals body over matters related to the standards development process. Additionally, members of the Council serve as presiding officers for the yearly NFPA Technical Meeting. The NFPA Standards Council is responsible for considering all appeals relating to the NFPA standards development process. NFPA Technical Committees Appointed by and reporting to the Standards Council, NFPA Technical Committees serve as the primary consensus bodies of subject matter experts responsible for developing and revising NFPA standards. Collectively comprised of more than 9,000 volunteers, the technical committees are responsible for the technical debate and requirements for the more than 300 NFPA standards. NFPA Technical Committees are the balanced consensus bodies of technical experts that are responsible for the development of technical requirements within NFPA standards, responding to all Public Input and Public Comments, and processing all proposed TIAs. NFPA staff An NFPA staff liaison is assigned to each NFPA technical committee and acts as the neutral facilitator for the NFPA standards development process. Each staff liaison is responsible for monitoring the activities of the technical committees to which they’ve been assigned, ensuring the process and procedures move forward in accordance with the Regulations Governing the Development of NFPA Standards. NFPA staff is not permitted to participate in the NFPA standards development process, including serving as members on technical committees and submitting public inputs or public comments. Additional resources Here is more detailed information and resources about how the NFPA codes and standards process works: How the NFPA standards development process works NFPA Standards Directory Regulations Governing the Development of NFPA Standards
PPE 1971

NFPA releases Standards Council TIA decision on NFPA 1971

A couple of months ago I wrote a blog explaining how individuals could get involved in the conversation about NFPA standards and firefighter PPE.  That blog provides a good overview for reference, and this piece provides new developments related to one particular standard - NFPA 1971, Standard on Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting, 2018 Edition. A recent NFPA Standards Council decision relating to NFPA 1971 has been partially referenced in many areas of social media and publications. Throughout the processing of the Tentative Interim Amendment (TIA), several serious safety concerns were raised by firefighters and others on both sides of the technical issue. Ultimately, the NFPA Standards Council determined that the balanced consensus Technical Committee (TC) and the current Task Group working on this issue were the best place to determine a proposed technical solution that provided the vital lifesaving performance requirements of PPE and the moisture barrier while at the same time addressing health risks to first responders.  NFPA Standards Council Decision The NFPA Standards Council voted on August 26, 2021, to deny an appeal requesting that the Council overturn the TC ballot results and issue TIA (No. 1594 on NFPA 1971 (2018 edition). The TIA was seeking to remove an ultra-violet (UV) light degradation test applicable to firefighter turnout gear. The appellant asserts that requiring this test causes the use of per-and polyfluoroalkyl substances (PFAS) in the moisture barriers of turnout gear.  TIA No. 1594 was balloted through the Technical Committee on Structural and Proximity Fire Fighting Protective Clothing and Equipment and the Correlating Committee (CC) on Fire and Emergency Services Protective Clothing and Equipment in accordance with the Regulations Governing the Development of NFPA Standards (Regs) to determine whether the necessary three-fourths majority support was achieved for recommendation of issuance. The TIA failed to achieve the necessary support of the TC on both technical merit and emergency nature, as well as failed to achieve the necessary support of the CC on both correlation and emergency nature. When a TIA fails to achieve the recommendation of the responsible committee, the resulting recommendation of the standards development process is to not issue the TIA. On appeal, the Council accords great respect and deference to the NFPA standards development process. In conducting its review, the Council will overturn the results of that process only where a clear and substantial basis for doing so is demonstrated.  The Council found no such basis demonstrated in this matter. Here are a few key points from the decision: As stated above, the TIA failed on all levels, including the Technical Committee and the Correlating Committee. From the decision, “The TIA failed to achieve the necessary support of the TC [technical committee] on both technical merit and emergency nature, as well as failed to achieve the necessary support of the CC [correlating committee] on both correlation and emergency nature.” This is not a simple issue. The moisture barrier provides significant protection to firefighters from various threats, and if this test is eliminated the Committee’s position was that it was not known technically what other impacts there may be on firefighter protection. From the decision, “This TIA seeks to remove an ultra-violet (UV) light degradation test applicable to firefighter turnout gear. The appellant asserts that requiring this test causes the use of per-and polyfluoroalkyl substances (PFAS) in the moisture barriers of turnout gear. Appellant expressed serious concern for health consequences to firefighters with continued use of PFAS in the moisture barrier.  Opponents to the TIA agree that PFAS should be removed or limited where possible, but express concern that removing this test without understanding of how removal will affect the moisture barrier could inherently be a serious risk to firefighter safety given the barrier is a primary protection from water and other common liquids, including chemicals and bloodborne pathogens encountered.”  The Technical Committee Chair formed a Task Group to address this topic in June 2021. The Council believes that the Task Group and the Technical Committee are in the best position (since they are the experts) to determine the best solution. From the decision, “The TC chair formed a Task Group in June 2021 to address this issue (and evaluate other issues related to hazardous substances). The Task Group membership includes topical experts, such as the appellant (IAFF), a representative from a nationally recognized testing lab, a turn-out gear manufacturer, and representatives from fire departments, among others. For these reasons, Council finds that the Task Group is in the best position to consider all technical and scientific information and to make an informed recommendation for the responsible TC’s consideration.”  The Council indicated that this is an important issue and urged the Task Group to continue its work. From the decision, “The Council notes that all parties in favor and against this appeal agreed that the TIA raises timely, important issues therefore the Council directs that the progressing Task Group work on this issue be expedited.  Additionally, the Council encourages the Task Group to submit a TIA for processing to the current edition and in parallel to the work being done within the next edition of the standard, if appropriate.” Background on NFPA Standards Process and NFPA 1971 NFPA does not write the standards. NFPA facilitates the development process for more than 300 different standards, including 114 that are fire-service-related. Technical Committees comprised of subject matter experts employ a transparent process that has relied upon diverse participation for 125 years. NFPA standards are typically updated every 3 to 5 years. NFPA standards do not specify or require the use of any particular materials, chemicals, or treatments for PPE. Those decisions are up to the manufacturer. NFPA 1971 specifies the minimum design, performance, testing and certification requirements for structural and proximity firefighting turnout gear including coats, trousers, coveralls, helmets, gloves, footwear, and interface components. The standard safeguards firefighting personnel by establishing minimum levels of protection from thermal, physical, environmental, and blood-borne pathogen hazards encountered during firefighting operations. NFPA 1971 does not, however, dictate what materials are used or how the manufacturer complies with the performance requirements of the standard.   Next Steps When the Task Group was established in June 2021, they were asked to submit their recommendations as public input on the next edition of the standard, which must be received by Nov 10, 2021. However, it is possible that the Task Group will continue to work beyond this date to complete or refine their recommendations. If a new consensus position is not reached in the First Draft stage, changes can still be considered in later stages (pending certain circumstances exist) or be adopted through a TIA, should one be filed. Public input to the next edition of the standard (which will be a consolidated standard as NFPA 1970) closes on November 10, 2021. Anyone (except NFPA staff) can propose a change to the standard by going online and suggesting specific wording and providing a rationale. NFPA anticipates that the First Draft Reports will be posted for public comment in the fall of 2022. The latest information on this standard can be found at nfpa.org/1970next.
Hatem Kheir, NFPA Board of Directors, Jim Pauley, NFPA President

Remembering NFPA Board member Hatem Kheir of Egypt and his contributions to life safety

“NFPA, the Middle East and North Africa (MENA), and the world have lost an incredible safety ambassador with the passing of NFPA Board member Hatem Kheir this week,” NFPA President and CEO Jim Pauley said. “Hatem was the consummate safety professional. His mechanical engineering background, passion for reducing risk, professional collaborations, commitment to educating the young and at risk, and his quest to offer in-language solutions to stakeholders were unmatched. We are eternally grateful for his contributions over the years.” Hatem passed away this week, at the age of 62, after a brief illness. Hatem joined the NFPA Board of Directors in 2016 and was serving his second term at the time of his death. During his tenure, he was a member of the Governance & Nominating Committee and the newly formed Corporate Development Committee.   NFPA Board Chair Amy Acton said, “Hatem was interested in being an NFPA Board member because he felt it would help him serve Egypt and other developing countries to better understand the importance of fire protection. He embraced the Fire & Life Safety Ecosystem™ and the opportunity to discuss safety with a long list of connections in the international marketplace.” Hatem was the owner and general manager of the Kheir Group based in Cairo, Egypt, a firm that specializes in supplying pumps, pumping services, and maintenance. He devoted 22 years to the standards development process, serving as a principal member on the Fire Pumps (FIM-AAA) technical committee that is responsible for the development of NFPA 20, Standard for the Installation of Stationary Pumps for Fire Protection.  Hatem was passionate about the proper use and application of NFPA codes and standards. With that in mind, he pioneered the first translation of NFPA documents into Arabic and worked to ensure that language was not a barrier to understanding and applying codes and standards. He believed wholeheartedly that we all play a role in safety and traveled all over the Middle East educating fire protection system users, firefighters, consultants, and engineers on how to select, install, test, and service fire pumps. He also devoted time to training and informing young engineers on the role that codes play in society and developed a study and education program for school-age children to help raise awareness of fire prevention and protection strategies.   Hatem helped launch the Egyptian Fire Protection Association so that government officials, companies, and workers were working holistically in the interest of safety; and until his death, served as Chairman of the Confederation of Fire Protection Association – International.  He worked with chamber of commerce leaders (American, British, Egyptian, and German), economic minds, fire protection industry groups, industrial engineering professionals, and those interested in culture development efforts throughout his career and was a founding member of the NFPA MENA Advisory Council.  Heartfelt condolences go out to Hatem’s wife Iman, his children, in-laws, grandchildren, and all who loved and admired him. His legacy will live on in the work that we do each day to reduce risk. 
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