The debate: mandatory gear retirement at 10 years
As members of the NFPA technical committee on protective clothing for structural fire fighting, we were recently notified that an individual petitioned NFPA to reconsider requiring firefighter helmets be mandatorily retired 10 years following their date of manufacture.
The 2008 edition and the proposed 2013 edition of NFPA 1851 requires that fire departments remove any gear from service that has a manufacture date more than 10 years old. Gear subject to this requirement includes garments, hoods, gloves, boots and helmets.
This petition did not surprise us as the issue had been hotly debated during the standards development process. And while there was a general consensus for both its original implementation and its continued use, it has not been a popular requirement within the fire service for many reasons.
Background on the 10-year rule
Work on NFPA 1851 actually started back in the mid-1990s when fire service safety groups, including the Southern Area Fire Equipment Research, Northern Area Fire Equipment Research, Central Area Fire Equipment Research and Fire Industry Equipment Research Organization worked on creating a publication called "PPE Care & Use Guidelines."
The publication was intended to fill a void in information for the proper selection, care, use and maintenance of turnout clothing, which was somewhat haphazardly addressed by the industry many years ago. The fire service work also became the foundation for the development of NFPA 1851.
One chapter addressed retirement and listed a number of factors for the department to consider including obvious damage and deterioration and when the cost for repairing the gear exceeded 50 percent of the replacement cost.
Nevertheless, the bulk of information in that chapter was advisory. And it emphasized that the actual service life of PPE varies with the amount of use and care, and that decisions to retire gear should be made by trained, qualified individuals.
Mandate vs advice
When the development work for NFPA 1851 started, the standard was positioned to set mandatory requirements for fire departments the same way that NFPA 1971 and other product standards set mandatory requirements for gear manufacturers.
In the case of retirement, the committee struggled with what could be mandated and what should be advisory. One solution was to require that individual departments develop their own specific criteria for when to retire PPE; while this was put into the standard, it was considered to be a relatively weak requirement.
The committee then opted to set a maximum service life for turnout gear that would be unambiguous — remove any gear from service that had a manufacture date of more than 10-years, regardless of its use, care, or actual condition. This was applied for all types of gear except aluminized outer shells found in proximity firefighter clothing that were given an expiration date of 5 years.
Certainly, the 10-year retirement life was not a conspiracy on the part of manufacturers to sell more gear, but rather an attempt to create definitive requirement for ensuring that old gear was retired. The true basis for establishing 10 years as the benchmark for retirement comes from the consideration that the NFPA 1971 standard setting requirements for turnout gear is typically revised every 5 years so that a span of 10 years would represent two revisions of the standard.
The thinking was that after 10 years, new changes in materials and testing technology, plus the implementation of new requirements, would make the PPE obsolete. This reasoning was combined with the observation that most garments last on the average 4 to 6 years before they have to be replaced for wear and tear.
While several organizations have conducted research to determine the performance of gear that has been used in the field and of various ages and conditions, no definitive conclusions are possible. We, ourselves, performed work for the U.S. Fire Administration nearly 15 years ago showing various effects of use and care on clothing material performance properties.
In some cases, we observed degradation of certain characteristics such as tear strength and water absorption resistance for shell materials. In other cases, the effects were minor. In a few rare instances we found that some properties — such as thermal protective performance — actually improved with use.
Practically all of the study work that has conducted to date has focused on garments. Very little work has been done for the other elements of the ensemble including helmets, hoods, gloves, and footwear.
We had one instance where we examined used gloves for changes in their insulative performance after use, but the findings were mixed. We also are aware of one major metropolitan fire department that evaluated a large number of helmets that were more than 10 years old for their continued impact and penetration resistance. The test results still showed all of the helmets to be compliant with the pertinent criteria for NFPA 1971.
With a few exceptions, the majority of these tests are destructive so it becomes impractical to perform many different tests that can let the department know if the protective features of the gear have become compromised.
A matter of interpretation
Then there is the matter of being able to interpret results. If the tear strength for an outer shell sample taken from a used coat comes back just a little under the minimum requirement set for that material, does it mean that coat needs to be retired?
The committee responsible for these standards attempts to make the best decisions it can with the available information, but validation information is not available in all cases. For most performance properties, there is insufficient industry research to provide clear-cut findings for determining when the safety of products is diminished to the point that they are no longer protective.
Unfortunately, no one has any solid, fail-safe advice on how to make that interpretation and the whole aspect of retirement becomes this murky, judgment-based call for whoever is responsible within the department. Some argue that the 10-year mandatory retirement obviates these judgment calls or the fact that no judgments are made at all.
The growing demise
We are aware that many fire departments are facing hard times and funds for replacement gear are not always readily available, particularly when it may seem that the gear is still serviceable and apparently safe.
Every several years, the National Fire Protection Association conducts a needs assessment for the fire service and publishes the results in a comprehensive report. The most recent report from 2011 showed the following findings with respect to PPE age and back up equipment:
- 63 percent of departments have some personal protective clothing that is at least 10 years old, but this is down from 74 percent in 2001 and up from 59 percent in 2005.
- 53 percent of departments do not have enough reserve personal protective clothing to equip 10 percent of emergency responders, but this is down from 62 percent in 2001 and 57 percent in 2005.
These statistics show that there is a substantial number of departments that either cannot or choose not to comply with mandatorily retiring their gear after 10 years.
The NFPA standards development process affords several opportunities for individuals to make proposals and recommendations to challenge existing requirements. In this case, the individual put in a public proposal to remove the 10-year mandatory retirement rule as applied to helmets from NFPA 1851 during the early stages of the revision process, which was backed up with a thorough substantiation.
After the committee rejected this proposal, the same individual responded with a comment on why the committee should reverse its direction, again with further justification. Others also provided similar proposals and comments.
After the committee has completed its revision efforts, the final chance to pursue this matter is to bring the issue before NFPA at its 2013 association technical meeting.
At that meeting, the individual will be afforded a chance to make a motion and debate will ensue from those present before a vote is taken to find if the NFPA membership agrees or not with the submitter. If they do, then the committee will be asked to vote on the same issue and the results will be brought before NFPA's standard council for the final decision.
At this point in the process, the only way to formally weigh in on this issue is to attend the technical meeting, which will be held in Chicago from June 10 to 13. Please contact us or NFPA if you have questions about this topic.
Jeffrey O. and Grace G. Stull are president and vice president respectively of International Personnel Protection, Inc., which provides expertise on the design, evaluation, selection and use of personnel protective clothing, equipment and related products to end users and manufacturers. They are considered amongst the leading experts in the field of personal protective equipment. Send questions or feedback to Jeff or Grace at Jeffrey.O.Stull@FireRescue1.com. The views of the author do not necessarily reflect those of the sponsor.