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.
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.