The PPE world is still coming to terms with the recent, advocated changes to NFPA 1971: Standard on Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting. The primary change involves the consolidation of standards related to turnout clothing, station/work uniform, SCBA, and PASS certification requirements into a single standard (NFPA 1970) – a change that has generated significant discussion about future fire service PPE. Within the new framework, several new changes have been proposed; however, these changes have only been tentatively accepted at this stage.
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On the heels of the NFPA 1971 revision, the NFPA is attempting another consolidation of standards, this time with the selection, care and maintenance requirements for PPE that are primarily directed at fire departments. NFPA 1851 (turnout gear) and NFPA 1852 (SCBA) would be consolidated into the new NFPA 1850. This revision will be equally complicated and impactful to the fire service.
Here we’ll address what we believe to be the emerging issues of concern with respect to fire service PPE programs, gear selection, PPE cleaning and decontamination, verification for independent service providers (ISPs), and PPE retirement. We expect the consolidated NFPA 1850 to address rapidly evolving expectations and technology for properly selecting and caring for/maintaining clothing and SCBA.
While many departments struggle with the necessary resources to implement all parts of the PPE program prescribed by NFPA 1851, new questions have been raised about whether departments should be required to have a second set of gear to backfill gear taken out of service for purposes of cleaning or to require the exchange of PPE at an immediately dangerous to life and health (IDLH) event. At the very least, consideration may be given to requiring departments to have a plan for replacing gear that is taken out of service due to its contamination or need for repairs.
There are continuing issues with how individuals handling contaminated gear should be protected. These individuals include firefighters, workers at ISPs, and even manufacturers that have gear returned to them. The application of “universal procedures” – the assumption that clothing is contaminated with infectious material that is commonly applied in the medical field – may be extended to all forms of contamination and specifically for fire service gear following a response. The result of this approach would be to have individuals handling used/contaminated gear wear certain minimum PPE. This PPE is likely to include examination gloves, face shields, aprons, and in some cases, lesser forms of respiratory protection.
An established role in many departments is the SCBA technician – one trained by manufacturers – for the repair and servicing of SCBA. A related position is being proposed for all PPE where minimum qualifications would be set for one or more individuals within a department to be competent in the care and maintenance of department PPE.
Additionally, some believe that more education on contamination risks and exposure hazards is needed, and there is a strong push to provide more educational materials (housed in the annex of NFPA 1851) that allow departments to customize how they put together a program specific to their level of resources.
Over the past several years, various nuances for how gear may be selected have come into practice. As a result, there are several new considerations for how hazard and risk assessments should be conducted – considerations that are not currently part of the requirements or guidance offered by NFPA 1851. For example, while NFPA 1500: Standard on Fire Department Occupational Safety, Health, and Wellness Program generally covers requirements for the use of different PPE for different department responses, there is nothing in NFPA 1851 to specifically address the use of alternative types of PPE in contrast to structural firefighting protective ensembles. This is despite the fact that many statistics bear out that structural calls are only a small proportion of the overall number of responses for most departments. Thus, there may be increased consideration for departments to decide how they should limit the use of turnout gear and otherwise employ other types of gear for medical calls and other types of non-fire responses. All of this would need to account for available fire department resources.
Recent changes in industry offerings of various PPE also point to the inclusion of factors such as restricted substances present in gear, as well as overall durability and serviceability. New proposed metrics within the next edition of NFPA 1971 may provide end users with data for comparing products along these lines. Therefore, providing guidance in the NFPA 1851 standard is paramount in allowing departments to make selection decisions based on their risk and hazard assessments.
PPE cleaning and decontamination
In the 2020 revision of NFPA 1851, the entire cleaning and decontamination chapter was significantly revamped where greater emphasis was placed on gear worn during a structural fire being considered contaminated and subjected to advanced or specialized cleaning. The introduction of on-scene preliminary exposure reduction was another major milestone in transforming the approach to address contamination control at the fire scene. With the next edition of NFPA 1851, further advancements are expected.
One of the proposed areas of cleaning will be changes to the general procedures for helmets, gloves, footwear and SCBA to recognize emerging cleaning technologies that provide modern alternatives to conventional manual cleaning methods. It is also likely there will be criteria added that permit the qualification of entire turnkey processes, equipment and detergents to overcome what some in the industry to consider “loose” insufficiently validated claims of contamination removal effectiveness.
A separate area of investigation is the development of more explicit information for addressing the removal of common but unique contaminants such as diesel fuel and other hydrocarbon mixtures, asbestos and lithium battery fire decomposition products. Some of the proposals may entail promotion of methods where the effectiveness of a specific technique for removing these contaminants can be shown.
There is also an intention to provide more support for in-house department cleaning capabilities. One area of research being conducted by the Fire Protection Research Foundation is exploring how fire departments can perform relatively simple and inexpensive techniques to demonstrate that their internal cleaning procedures are working correctly and efficiently.
After a couple of years since the verification of ISP-based cleaning has been in place, some concerns have been raised as to whether “special” procedures are being utilized only during the verification process to meet the minimum contamination removal requirements (now set at 50% or greater for both organic and inorganic chemicals). Consequently, some ISPs may be getting better data than what is actually used for their standard cleaning of gear for fire departments. Steps are being considered for how the verification process can be better supervised to ensure that cleaning is consistently done and is effective as reported by the independent test results.
There is further interest in having ISPs report the results online to the certification organization. This will ensure that all fire departments can review results against the NFPA 1851 requirements as one factor in their choice of the specific ISP. Some contend that the verification procedures are not sufficiently reliable to allow an “apples to apples” comparison where the verification testing is repeatable for such comparisons. Therefore, another part of the investigation of changes for verifying of ISPs may include a robust examination and improvement of actual test procedures now in NFPA 1851.
No revision to NFPA 1851 goes by without a debate on the mandatory 10-year retirement of turnout clothing. This divisive requirement has been contentious since it was first introduced in the 2nd edition beginning 2008. The reason that gear must be taken out of service for principal protection has been based on three factors:
- 10 years represents two revision cycles of the NFPA 1971 product standard in which requirements and technology can significantly change for PPE;
- It is impossible to fully evaluate the efficacy of the gear for its continued protection since the necessary nondestructive tests are not available; and
- Evidence based on destructive testing for used gear has shown degradation in performance properties for gear that was 10 years old or more.
More recently, a new reason was added based on the knowledge that gear is not fully decontaminated using conventional cleaning processes.
There are entire states that have opposed the mandatory 10-year retirement requirement because they have unused gear obtained through grants sitting in reserve that would no longer be viable according to NFPA 1851. It is expected that this issue will come up again, and it is possible that special exceptions may be proposed. Yet, any such changes will be subject to rigorous debate.
SCBA has a unique situation whereby, per federal regulations, cylinders have a maximum service life of 15 years. Because many SCBA are updated by departments to the use of retrofit kits to bring the SCBA into compliance to a newer standard, the process of standardizing an overall service life becomes more difficult. Currently, fire departments are advised to follow manufacturer recommendations for taking specific SCBA and SCBA components out of service.
Mandatory retirement is seen as an onerous issue because it is often perceived as a means for creating premature replacement for items to the benefit manufacturers. This perception is unfounded because committees are balanced in their participation, where the fire service and other user concerns are duly taken into account for all aspects of product selection and use.
Since the revision process is just beginning, it is important for the NFPA Technical Committee to hear from the entire fire service. If you have ideas for changes or concerns about any changes discussed above, it is best to contact someone on the committee to get more information. Further, if you would like to propose any new ideas, you can visit the NFPA website to make specific public inputs for addressing topics in which you are interested.
We will have more updates on this topic as the revision process goes forward.
Note: The views of the author do not necessarily reflect those of the sponsor.
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