NFPA Technical Committee on

Technical Committee on

Standard on Selection, Care, and Maintenance of Protective Ensembles for Structural

Fire Fighting and Proximity Fire Fighting

NFPA 1851 FIRST DRAFT MEETING

Orlando, FL

February 28 & March 1-2, 2017

AGENDA

1. Call to order at 8:00am

2. Introductions

3. Opening remarks – Chairman King

4. Review and approval of minutes from previous meeting

5. NFPA Staff Liaison report - Chris Farrell

6. Presentations

a. Digital tagging

b. NIOSH work

7. NFPA 1851 First Draft

a. Task Group Reports

b. Act on remaining Public Inputs

8. New business

9. Old business

10. Other items

11. Next meeting

12. Adjourn

NFPA Technical Committee on

Structural and Proximity Fire Fighting Protective Clothing and Equipment

NFPA 1971 SECOND DRAFT MEETING

Colorado Springs, CO

June 21-24, 2016

MINUTES

Tuesday, June 21st, 2016

1. Called to order at 8:07am

2. Introductions – Committee Members and Guests

Principal Members Present:

Stephen King Chair, FDNY (retired)

George Berger US Marine Corps Installations Command

Steven Corrado Underwriters Laboratories, Inc

Paul Curtis L.N. Curtis & Sons

Anthoney Shawn Deaton NC State University

Tim Durby Prescott Fire Department

Jonathan Fesik Fire Industry Repair Maintenance Inc.

Patricia Freeman Globe Manufacturing Company, LLC

Richard Granger Charlotte Fire Department

A. Ira Harkness U.S. Department of the Navy

William Haskell NIOSH-NPPTL

Earl Hayden International Association of Fire Fighters

John Karban FireDex, LLC

Kim Klaren Fairfax County Fire & Rescue Department

Steve Lakey Verified Independent Service Providers Association

Karen Lehtonen Lion Group, Inc.

Michael McKenna Michael McKenna & Associates, LLC

Daniel Melia Fire Department City of New York

Louis Ott Gentex Corporation

Tom Ragan Shelby Specialty Gloves

Jim Reidy Texas State Association of Fire Fighters

John Rhoades International Association of Fire Chiefs

John Rihn Mine Safety Appliances Company

R. Wendell Robison National Volunteer Fire Council

Jeffrey Stull International Personnel Protection, Inc

Tim Tomlinson Addison Fire Department

Robert Tutterow Fire Industry Education Resource Organization

Richard Weise Southern Area Fire Equipment Research

Harry Winer HIP Consulting, LLC

Voting Alternate Members Present: Douglas Sloan Honeywell First Responder Products

Alternate Members Present:

Roger Barker (via phone) North Carolina State University

Thomas Clark International Association of Fire Fighters

Tom Hamma Heartland Fire & Rescue

Tricia Hock Safety Equipment Institute (SEI)

Pamela Kavalesky Intertek Testing Services

Amanda Newsom Underwriters Laboratories, Inc

Marni Schmid (Secretary) Fortunes Collide Marketing/Alt. for F.I.E.R.O.

Guests Present: Yvonne Smith NFPA

Nancy Wirtes NFPA

Jessica Ambrose Globe Manufacturing Company

Tim Porch 3M Personal Safety Division

Mark Williams W.L. Gore

Matt Colatruglio TenCate

Charles Dunn TenCate

Eric Baker TenCate

Bart McCool TenCate

David Esken Milliken & Co

John E Ashley Milliken & Co

Brian Sullivan W.L. Gore

Jacques Cantin Safety Components

Allen Rom Fire-Dex

Tory King Fire-Dex

Brian Marenco Honeywell

Jim Walter Honeywell

Angel Sanchez, Jr Phenix Technology, Inc.

Shaun Russell Phenix Technology, Inc.

Bill Burke Fire-Dex

Jenny McPherson Fire-Dex

Jack Kay Stedfast

Scott Mackenzie Stedfast

Mike Salvato Stedfast

Robin Tutor UL

Jennifer Wise W.L. Gore

Bill Brooks UniMac

Dan Tharan Veridian

Gretchen Grandt-Brown PGI, Inc

Jian Xiang DuPont

Jordan Carlen DuPont

David Litchfield DuPont

Mark Collins Stanfield’s/Lifeliners

Ed MacDonald Stanfield’s/Lifeliners

Matthew Decker W.L. Gore

Allen Maples W.L. Gore

Rob Tieman Bullard

Matt Ernst Bullard

Tom Lochner Fire Craft

Michelle Gervais Fire Service Women Ontario, Canada

Janeane Matvin Majestic Fire Apparel

Bob Keys Fire-Research and Development of NY Consulting, LLC

Kevin Roche FACETS Consulting

Jen Brust Honeywell First Responder Products

Brian Shiels PBI Performance Products

Diane B Hess PBI Performance Products

Jeff Sedivec L.N. Curtis & Sons

Jay Tarley National Institute for Occupational Safety & Health

Daniel Theriault US Department of the Navy

Don Welch Globe Manufacturing Company

Patrick Woods Fire Department City of New York

Staff Liaison Chris Farrell National Fire Protection Association

Dave Trebisacci National Fire Protection Association

Chris Gaudette ORAFOL Americas

Tom Flaherty ORAFOL Americas

Joey Underwood Safety Components

3. Opening remarks

4. The minutes from the previous meeting were reviewed and approved

5. NFPA Staff Liaison report

6. Presentations

1. David Litchfield, Ph.D. Research Investigator, DuPont Protection Technologies,

presented Rationales to the Particulate Barrier Hood Standard Proposal

2. Steven Corrado, UL, LLC, opened the presentation by explaining what is being

proposed for ASTM F2299; Holly Blake, W.L. Gore & Associates, presented

information on particulate and moisture barrier hoods

3. Matthew Decker, W.L. Gore & Associates, presented Physiological Trial Summary

4. Michael Salvato, Stedfast USA, presented Why Ret is a Misleading

7. Task Group Reports

a. The Technical Committee acted on 134 Public Comments and created 63 Second Revisions

i. There was a Call for Division on Public Comment 105. Motion to accept: 25 voted in favor, 2

opposed, 6 abstained

ii. There was a Call for Division on Public Comment 128. Motion to reject: 17 voted in favor, 8

opposed, 5 abstained

8. New business

a. Robert Tutterow announced the F.I.E.R.O. Fire PPE Symposium to be held March 20-22, 2017 in

Raleigh.

b. Chairman King disbanded all existing NFPA 1971 task groups, the NFPA 1851 Risk Assessment and

Common Chemicals task groups.

c. Chairman King assigned new task groups based on additional work requirements identified during the

Second Draft meeting.

i. Helmets - Ear flap removal / Helmet band removal/cleaning – Dick Weise, task group chair

ii. Hoods - Flexing Procedure for particulate barrier hoods / Stored thermal energy / Advance

Cleaning and Inspection of Barrier Hoods – Rich Granger, task group chair

iii. Ret – Earl Hayden, task group chair (see attached for testing results shared from test methods

task group)

iv. Helmet eye and face protection, Robert Tutterow, task group chair

v. Editorial – this task group was not disbanded because the current focus is on NFPA 1851 –

Marni Schmid, task group chair

9. Old business - none

10. Other items - none

11. Next meeting: NFPA 1851 - February and December, 2017

d. The First Draft meeting will likely be held in late February. The Public Input period closes January 5,

2017.

12. Adjourned at 4:51pm, Thursday, June 23, 2016

Total Heat Loss and Water Vapor Resistance Testing Organized by Test Methods Task Group

Designation Composite Moisture Barrier Thermal Liner Outer Shell Ret THL ARefA 8 Steadair 3000 Aralite NP Ultra 31.85 206.9 0.0208

B 3 Crosstech 3 Layer 4A Defender M SL2 Kombat Flex 26.48 218.1 0.0213C 1 RT7100 3D Glide Gold Pure Armor 7.0 45.17 219.8 0.0187

D 11 Steadair Gold Caldura Npi Gemini 53.07 222.2 0.0196

E 7 Parallon System Parallon System Advance 24.01 234 0.0206

F 5 Crosstech Black 2F Q8 Gemini 27.3 249.8 0.0162

G 4 Crosstech Black 2F Glide Gold Pure Gemini 28.62 252.03 0.016703H 10 Steadair 4000 Q8 Ultra 62 255.8 0.0157

I 6 Crosstech Black 2F Caldura SL2i Pioneer 25.01 281.5 0.0149

J 9 Steadair 3000 Caldura SL2i Mellenia XTL 53.46 285.2 0.0146

K 12 Steadair Gold Aralite SL2 Defender 750 49.51 296.5 0.0129

L 2 RT7100 3D Omni Synergy 2Layer Defender 750 38.21 303.38 0.012616

20

30

40

50

60

70

100

125

150

175

200

225

250

275

300

325

350

A B C D E F G H I J K L

Ret (

Pa m

2 /W

)

THL

(W/m

2 )

THL Ret

Proposed Ret Req't

THL Compliant

NFPA 1971 THL Req't

Comparisons

Desig THL RetA 206.9 31.85B 218.1 26.48C 219.8 45.17D 222.2 53.07E 234 24.01F 249.8 27.3G 252.03 28.62H 255.8 62I 281.5 25.01J 285.2 53.46K 296.5 49.51L 303.38 38.21

Desig THL ArefA 206.9 0.0208

B 218.1 0.0213C 219.8 0.0187

D 222.2 0.0196

E 234 0.0206

F 249.8 0.0162

G 252.03 0.016703H 255.8 0.0157

I 281.5 0.0149

J 285.2 0.0146

K 296.5 0.0129

L 303.38 0.012616

Desig Aref RetA 0.0208 31.85B 0.0213 26.48C 0.0187 45.17D 0.0196 53.07E 0.0206 24.01F 0.0162 27.3G 0.016703 28.62H 0.0157 62I 0.0149 25.01J 0.0146 53.46K 0.0129 49.51L 0.012616 38.21

y = 0.0836x + 17.659R² = 0.043

20

25

30

35

40

45

50

55

60

65

200 220 240 260 280 300 320

Ret (

Pa m

2 /W

)

THL (W/m2)

Ret vs. THL

y = -9E-05x + 0.0394R² = 0.9074

0.01

0.012

0.014

0.016

0.018

0.02

0.022

200 220 240 260 280 300 320

ARef

(kPa

m2 /

W)

THL (W/m2)

ARef vs. THL

y = -1441.9x + 63.311R² = 0.1106

20

25

30

35

40

45

50

55

60

65

0.01 0.012 0.014 0.016 0.018 0.02 0.022

Ret (

Pa m

2 /W

)

ARef (kPa m2/W)

Ret vs. ARef

Public Input No. 118-NFPA 1851-2017 [ Global Input ]

Type your content here ...

Search for all references that equal "manufacturer trained organization" and replace with "manufacturer-trained organization"

Statement of Problem and Substantiation for Public Input

The Editorial Task Group suggests searching the entire document for missing hyphens related to “manufacturer-trained organizations” so that they are consistent with the spelling in the definition in Chapter 3.

Submitter Information Verification

Submitter Full Name: Marni Schmid

Organization: Fortunes Collide Marketing LLC

Street Address:

City:

State:

Zip:

Submittal Date: Wed Jan 04 20:42:45 EST 2017

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

1 of 259 2/14/2017 9:09 AM


(See Attached Public Comment Log # 39 to; Add definitions and supporting appendixinformation.....) (Sections 3.3.X and 7.1.6)

Additional Proposed Changes

File Name Description Approved

F2012_ROC_Report.pdf NFPA 1851_ROCLog#39


Note: This Public Input appeared as "Reject but Hold" in ROC Log # 39 of the F2013 Report on Comments for NFPA 1851 and per the Regs. at 4.4.8.3.1.

Provide additional appendix information to A.7.1.6 to read as follows:The U. S. Environmental Protection Agency (EPA) applies the following requirements to antimicrobial products whichbear label claims or recommendations for use in the treatment of laundry to provide disinfecting or sanitizing activity for fabrics and/or laundry water. Label claims must distinguish between products recommended as soaking treatments prior to laundering and products represented as additives in actual laundry operations.Products recommended for pre-soaking soiled fabrics prior to routine laundering must be shown to be effective by appropriate tests (e.g. AOAC Use Dilution Method for disinfectants; Sanitizer Test for inanimate non-food contact surfaces for sanitizers) in the presence of organic soil (e.g. 5% blood serum). The directions for use must specify rinsing of the items to remove gross filth prior to soaking, followed by complete immersion in an adequate volume of soaking solution (at least 5:1 w/w solution to fabric ratio, e.g. half a washload in a 3 - gallon pail) at the recommended usedilution for a specified contact time prior to the laundering operation.A clear distinction should be made on the label between products recommended for household laundering andproducts represented as commercial-industrial-institutional laundry additives. The water to fabric ratio in home machines is about 10:1 (w/w), whereas in industrial laundering operations the ratio is about 5:1. The effectiveness of products may be significantly altered by these differences; thus, demonstrated efficacy in one system may not be able to be for front-loading automatics (e.g. 8-10 gallon water capacity) and top-loading automatics and wringer-type washers (e.g.12-15 gallon water capacity). Product dosages, in this instance, should be specified in household measurements. Dosage instructions for industrial laundering may be based on pounds of dry fabric.The directions for use of laundry additives should specify the machine cycle in which the product is to be added, water level, temperature range, and treatment time. Compatibility of the treatment with other common laundry additives (e.g. soaps, detergents, bleach, starch, bluing, sours, fabric softeners) should be determined in testing and addressed in labeling, when applicable.Efficacy data requirements for disinfectants and sanitizers intended for use as additives in laundry operations are as follows:DisinfectionTest standard – A proposed simulated use procedure employed by Petrocci and Clarke (Petrocci, A. M. and Clarke, P.1969. Proposed Test Method for Antimicrobial Laundry Additives. Journal Association of Analytical Communities, 52:836-842) is acceptable. Alternately, a simulated-use study utilizing washing machines may be employed. The following basic elements must be incorporated in either study:(1) The test bacteria are Staphylococcus aureus (ATCC 6538) and Klebsiella pneumonia (ATCC 4352). If the product is intended for use on hospital linens, it must also be tested against Pseudomonas aeruginosa (ATCC 15442).(2) The basic bacteriological procedures must be the same as those specified in the Petrocci and Clarke protocol.


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(3) Tests must be conducted with 3 product samples, representing 3 different batches, one of which is at least 60 days old. Each sample must be tested with 9 fabric swatches against each of the specified test bacteria.(4) The method employed must be designed to include testing both the fabric and the laundry water (5 ml from the automatic washer, or 0.5 ml from the simulated washing device in individual widemouth jars containing subculture media and neutralizers. The laundry water-to-media volume ratio must not exceed 1:40.(5) Growth or no-growth must be recorded and reported after a 48-hour incubation period.Performance standard – There must be no growth in the fabric subcultures and no growth in the subcultures from the laundry water with all test bacteria.SanitizationTest standard – The same type of studies referred to under "Disinfection" above must be employed for evaluating the efficacy of laundry additives intended to sanitize laundry, with the following exceptions:(1) Tests must be conducted with 3 samples representing 3 product batches, one of which is at least 60 days old. Each sample must be tested with 3 cloth swatches against each test microorganism required.(2) Quantitative bacteriological assays must be conducted and the results reported.Performance standard – The data requirements outlined herein do not apply to sodium-calcium hypochlorites, sodium-potassium dichloro-s-triazinetriones or trlchloro-s-triazinetrione.These procedures may also be conducted in accordance with ASTM E2406 - 09 Standard Test Method for Evaluation of Laundry Sanitizers and Disinfectants for Use in High Efficiency Washing OperationsResidual Self-SanitizationLaundry operations – A clear distinction should be made on the label between products recommended for household laundering and products represented as commercial-industrial-institutional laundry additives. The water to fabric ratio in home machines is about 10:1 (w/w), whereas in industrial laundering operations the ratio is about 5:1. The effectiveness of products may be significantly altered by these differences; thus, demonstrated efficacy in one system may not be extrapolated to the other. In addition, directions for use of household laundering products may require different dosages for front-loading automatics (e.g., 8-10 gallon water capacity) and top-loading automatics and wringer-type washers(e.g., 12-15 gallon water capacity). Product dosages, in this instance, should be specified in household measurements. Dosage instructions for industrial laundering may be based on pounds of dry fabric. The directions for use of laundry additives should specify the machine cycle in which the product is to be added, water level, temperature range, and treatment time. Compatibility of the treatment with other common additives (e.g., soaps, detergents, bleach, starch, bluing, sours, fabric softeners) should be determined in testing an addressed in labeling, when applicable.Test standard – A suggested protocol published by Petrocci and Clarke (J. AOAC 52:836-842) is acceptable for treating the fabric. The basic elements outlined in the protocol of the "Quantitative Procedure" of the American Association of Textile Chemists and Colorists (AATCC) Test Method 100 employing Staphylococcus aureus (ATCC6538) and Klebsiella pneumoniae (ATCC 4352) are acceptable for evaluating the residual antimicrobial activity. However, 3 samples, representing 3 different product batches must be tested, and the following modifications to the method must be incorporated:(1) Use a sufficient number of swatches placed exactly on top of each other so that they completely absorb 1 ml of inoculum which is prepared to contain at least 107 microorganisms/ml.(2) The number of swatches used per jar must be reported. (4) Quantitative bacteriological assays should be performed at the following time intervals: 0, 30 min., 1-hr, 3-hr, 6-hr, and 24-hr. Consideration could be given to fewer or different time intervals, depending on the label claims, on acase-by-case basis.Performance standard – For residual self-sanitizing claims against pathogenic microorganisms, the reduction of each test microorganism must be at least 99.9% over the "0-time" control and the parallel untreated inoculated control.All disinfectants and sanitizers should be shown to not degrade the performance properties of protective ensemble elements by using similar procedures described in A.7.1.9.


Submitter Full Name: Tc On Fae-Spf

Organization: NFPA

Street Address:

City:


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State:

Zip:

Submittal Date: Thu Aug 18 15:22:24 EDT 2016


4 of 259 2/14/2017 9:09 AM

Report on Comments – November 2012 NFPA 1851_______________________________________________________________________________________________1851-19 Log #39 FAE-SPF

_______________________________________________________________________________________________Jeffrey O. Stull, International Personnel Protection, Inc.

1851-33Add definitions and supporting appendix information to read as follows:

A type of antimicrobial agent that kills or irreversibly inactivates at least 99.9 percent of allmicroorganisms present on a surface.

Sanitizers reduce levels of microorganism to safe levels. The EPA requires as a minimum that asanitizer reduce the level of and or by 99.9% onnon-food contact surfaces within 5 minutes.

A type of antimicrobial agent that destroys or irreversibly inactivates microorganisms onhard,inanimate surfaces and objects.

Disinfectants are only intended for hard, non-porous surfaces. Hard, non-porous surfaces do notinclude the textile products used in fire fighter protective clothing. All disinfectants must be registered with the EPA andmeet specific labeling requirements. A listing of currently registered disinfectants can be found athttp://www.epa.gov/oppad001/chemregindex.htm.Disinfectants are classified as:Limited – Must be supported by efficacy testing against either Salmonella cholerasuis (gram-negative bacteria) or

Staphylococcus aureus (gram-positive bacteria). Limited disinfectants are found mostly in household use.General – Must be supported by efficacy testing against both Salmonella cholerasuis and Staphylococcus aureus.

General disinfectants are used in commercial areas.Hospital – Must be supported by Association of Analytical Communities (AOAC) Use Dilution or AOAC Germicidal

Spray efficacy testing against Staphylococcus aureus, Salmonella cholerasuis and Pseudomonas aeruginosa. Thebacteria Pseudomonas aeruginosa hides behind biofilm and is difficult to eliminate. Killing of this bacteria is required forHospital Disinfectants.The EPA’s definition of a general or “broad spectrum” disinfectant is one that has public health claims for all three of

the major classes of organisms:Bacteria – effective against gram-negative and gram-positive bacteriaFungi – effective against at least one pathogenic fungi (usually Trichophyton mentagrophytes)Viruses – effective against pathogenic viruses (at least one enveloped virus such as Influenza A and one

non-enveloped virus such as Adenovirus).Sanitizers are not considered broad spectrum by EPA’s definition since they are only meant to reduce bacteria levels.Modify current requirement to read as follows:

Organizations shall have written procedures detailing the decontamination and cleaning processes forensembles and ensemble elements contaminated with body fluids. Where used, these processes shall only employdisinfectants or sanitizers that have are registered and have been properly validated as to the specification claims ofdisinfection and sanitization. Selected disinfectants and sanitizers shall not degrade the performance properties ofprotective ensemble elements. Universal precautions shall be observed at all times by members handling elementsknown or suspected to be contaminated with body fluids.

Provide additional appendix information to A.7.1.6 to read as follows:The U. S. Environmental Protection Agency (EPA) applies the following requirements to antimicrobial products which

bear label claims or recommendations for use in the treatment of laundry to provide disinfecting or sanitizing activity forfabrics and/or laundry water. Label claims must distinguish between products recommended as soaking treatments priorto laundering and products represented as additives in actual laundry operations.Products recommended for pre-soaking soiled fabrics prior to routine laundering must be shown to be effective by

appropriate tests (e.g. AOAC Use Dilution Method for disinfectants; Sanitizer Test for inanimate non-food contactsurfaces for sanitizers) in the presence of organic soil (e.g. 5% blood serum). The directions for use must specify rinsingof the items to remove gross filth prior to soaking, followed by complete immersion in an adequate volume of soakingsolution (at least 5:1 w/w solution to fabric ratio, e.g. half a washload in a 3 - gallon pail) at the recommended usedilution for a specified contact time prior to the laundering operation.A clear distinction should be made on the label between products recommended for household laundering and

products represented as commercial-industrial-institutional laundry additives. The water to fabric ratio in home machinesis about 10:1 (w/w), whereas in industrial laundering operations the ratio is about 5:1. The effectiveness of products maybe significantly altered by these differences; thus, demonstrated efficacy in one system may not be able to be

1Printed on 8/18/2016

Report on Comments – November 2012 NFPA 1851extrapolated to the other. In addition, directions for use of household laundering products may require different dosagesfor front-loading automatics (e.g. 8-10 gallon water capacity) and top-loading automatics and wringer-type washers (e.g.12-15 gallon water capacity). Product dosages, in this instance, should be specified in household measurements.Dosage instructions for industrial laundering may be based on pounds of dry fabric.The directions for use of laundry additives should specify the machine cycle in which the product is to be added, water

level, temperature range, and treatment time. Compatibility of the treatment with other common laundry additives (e.g.soaps, detergents, bleach, starch, bluing, sours, fabric softeners) should be determined in testing and addressed inlabeling, when applicable.Efficacy data requirements for disinfectants and sanitizers intended for use as additives in laundry operations are as

follows:DisinfectionTest standard – A proposed simulated use procedure employed by Petrocci and Clarke (Petrocci, A. M. and Clarke, P.

1969. Proposed Test Method for Antimicrobial Laundry Additives. Journal Association of Analytical Communities, 52:836-842) is acceptable. Alternately, a simulated-use study utilizing washing machines may be employed. The followingbasic elements must be incorporated in either study:(1) The test bacteria are Staphylococcus aureus (ATCC 6538) and Klebsiella pneumonia (ATCC 4352). If the product

is intended for use on hospital linens, it must also be tested against Pseudomonas aeruginosa (ATCC 15442).(2) The basic bacteriological procedures must be the same as those specified in the Petrocci and Clarke protocol.(3) Tests must be conducted with 3 product samples, representing 3 different batches, one of which is at least 60 days

old. Each sample must be tested with 9 fabric swatches against each of the specified test bacteria.(4) The method employed must be designed to include testing both the fabric and the laundry water (5 ml from the

automatic washer, or 0.5 ml from the simulated washing device in individual widemouth jars containing subculture mediaand neutralizers. The laundry water-to-media volume ratio must not exceed 1:40.(5) Growth or no-growth must be recorded and reported after a 48-hour incubation period.Performance standard – There must be no growth in the fabric subcultures and no growth in the subcultures from the

laundry water with all test bacteria.SanitizationTest standard – The same type of studies referred to under "Disinfection" above must be employed for evaluating the

efficacy of laundry additives intended to sanitize laundry, with the following exceptions:(1) Tests must be conducted with 3 samples representing 3 product batches, one of which is at least 60 days old. Each

sample must be tested with 3 cloth swatches against each test microorganism required.(2) Quantitative bacteriological assays must be conducted and the results reported.Performance standard – The data requirements outlined herein do not apply to sodium-calcium hypochlorites,

sodium-potassium dichloro-s-triazinetriones or trlchloro-s-triazinetrione.These procedures may also be conducted in accordance with ASTM E2406 - 09 Standard Test Method for Evaluation

of Laundry Sanitizers and Disinfectants for Use in High Efficiency Washing OperationsResidual Self-SanitizationLaundry operations – A clear distinction should be made on the label between products recommended for household

laundering and products represented as commercial-industrial-institutional laundry additives. The water to fabric ratio inhome machines is about 10:1 (w/w), whereas in industrial laundering operations the ratio is about 5:1. The effectivenessof products may be significantly altered by these differences; thus, demonstrated efficacy in one system may not beextrapolated to the other. In addition, directions for use of household laundering products may require different dosagesfor front-loading automatics (e.g., 8-10 gallon water capacity) and top-loading automatics and wringer-type washers(e.g., 12-15 gallon water capacity). Product dosages, in this instance, should be specified in household measurements.Dosage instructions for industrial laundering may be based on pounds of dry fabric. The directions for use of laundryadditives should specify the machine cycle in which the product is to be added, water level, temperature range, andtreatment time. Compatibility of the treatment with other common additives (e.g., soaps, detergents, bleach, starch,bluing, sours, fabric softeners) should be determined in testing an addressed in labeling, when applicable.Test standard – A suggested protocol published by Petrocci and Clarke (J. AOAC 52:836-842) is acceptable for

treating the fabric. The basic elements outlined in the protocol of the "Quantitative Procedure" of the AmericanAssociation of Textile Chemists and Colorists (AATCC) Test Method 100 employing Staphylococcus aureus (ATCC6538) and Klebsiella pneumoniae (ATCC 4352) are acceptable for evaluating the residual antimicrobial activity.However, 3 samples, representing 3 different product batches must be tested, and the following modifications to themethod must be incorporated:(1) Use a sufficient number of swatches placed exactly on top of each other so that they completely absorb 1 ml of

inoculum which is prepared to contain at least 107 microorganisms/ml.(2) The number of swatches used per jar must be reported.


Report on Comments – November 2012 NFPA 1851(3) Incubation must be at 20-21°C (68-70°F).(4) Quantitative bacteriological assays should be performed at the following time intervals: 0, 30 min., 1-hr, 3-hr, 6-hr,

and 24-hr. Consideration could be given to fewer or different time intervals, depending on the label claims, on acase-by-case basis.Performance standard – For residual self-sanitizing claims against pathogenic microorganisms, the reduction of each

test microorganism must be at least 99.9% over the "0-time" control and the parallel untreated inoculated control.All disinfectants and sanitizers should be shown to not degrade the performance properties of protective ensemble

elements by using similar procedures described in A.7.1.9.

The submitter of the comment and the TC believes that further research should be undertakenfor providing detailed guidance to the fire service and service providers in their selections of agents for biologicaldecontamination.

Affirmative: 304 Barker, R., Davis, R., Doan, S., Durby, T.



Where "Routine Cleaning" appears, it should be replaced by "On Scene (Preliminary) Cleaning"


This proposed change reflect a terminology change separately recommended.

Related Public Inputs for This Document

Related Input Relationship

Public Input No. 204-NFPA 1851-2017 [Section No. 3.3.13]


Submitter Full Name: Jeffrey Stull

Organization: International Personnel Protection, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Thu Jan 05 13:46:00 EST 2017


5 of 259 2/14/2017 9:09 AM


The entirety of the annex A sections specific to Section 7.1 should be revised and update based onproposed changes to Section 7.1 including the establishment of a hierarchy of approaches tohandling, cleaning, and disposing of protective elements with soiling and contamination.


Extensive changes to Section 7.1 warrant updating and reorganizing the information provided in the respective related Annex A sections.



Public Input No. 207-NFPA 1851-2017 [Section No. 7.1]




Street Address:

City:

State:

Zip:



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Specific requirements should be identified or developed that pertain to the new category of barrierhoods recently added to the new edition of NFPA 1971. At a minimum, procedures are needed toaddress their inspection, cleaning, and repair.


NFPA 1851 should be updated to provide specific inspection, cleaning, and repair procedures for the new element type of barrier hoods, which have features that are likely to be substantially different than standard structural or proximity protective hoods.




Street Address:

City:

State:

Zip:



7 of 259 2/14/2017 9:09 AM


Section 7.4 should be incorporated into Section 7.3. A new section on Specialized Cleaning shouldbe developed to reflect specific practices for addressing certain types of contamination includingbulk chemicals, asbestos and other designated substances, body fluids and other biologicalcontaminants, and significant contamination by products of combustion and soot.


Additional detail is needed to address procedures for specialized cleaning. Work of the Fire Protection Research Foundation is expected to provide some bases for creating recommended procedures prior to the completion of the First Draft.







Street Address:

City:

State:

Zip:



8 of 259 2/14/2017 9:09 AM


Specific procedures for validating the effectiveness of cleaning ensemble elements, primarily protectivegarments and hoods, for removal of combustion products and associated contamination in addition toseparate procedures for the sanitization of protective elements for biological contamination are proposed.Specific research is being carried out to develop simplified procedures by which specially contaminatedsamples can be sent to any facility and subjected to a respective organization’s cleaning process andprocedures. The facility would then return the “cleaned” samples back to a qualified laboratory for analysis.Based on the analysis of the samples, a determination can be made as to how much contamination hasbeen removed by the respective cleaning process are procedures.

Is recommended that these validation procedures be specified for qualifying specific cleaning anddecontamination processes as applied to the removal of products of combustion contamination andseparately to biological contamination. Thus, only those equipment, cleaning agents/sanitizers, proceduresand processes that pertain a specific level of contamination removal efficiency would be used.

Work is already underway by the Fire Protection Research Foundation and is sufficiently advanced fordeveloping procedures that examines both chemical and biological contamination. In the case of chemicalcontamination, two separate approaches are being investigated. The first approach entails exposing smallmaterial swatches in a repeatable fashion to products of combustion created and a small controlledchamber that creates both soot particles and various types of organic and inorganic chemicals. A secondapproach involves impregnating fabric samples with a certain like carbon material and inoculating thematerial with specific amounts of known organic and inorganic chemicals. In while either case, thecontaminated samples would be characterized for the levels contamination an identical set would be sent tothe facility for incorporation into a clothing set that is then subjected to the respective cleaning processbeing evaluated. With the return of the wash samples, and analysis would be performed to determine theremaining level of contaminants retained by the sample. By comparing the levels both in the uncleaned andcleaned samples, a quantitative measure can be obtained for individual substances or contaminants.Similarly, specimen fabric samples can be inoculated with specific microorganisms and likewise subjectedto cleaning or sanitization processes to determine the remaining number of microorganisms following theapplication the process. Specific efficiencies can be set for qualifying the effectiveness of thedecontamination processes for either chemical or biological contaminants.

The inclusion of cleaning validation will be proposed in the following ways:

1. All advanced cleaning processes would be required to be validated for effectiveness for chemicaldecontamination.

2. Any cleaning process recommended for the removal biological contaminants would be required to bevalidated for effectiveness for biological decontamination.

3. It would be permitted for vendors to qualify their equipment, cleaning/sanitization, and specializedprocesses for either chemical or biological decontamination effectiveness.

4. These procedures would be applied to Independent Service Providers to verify their cleaning as no suchcurrent procedures exist and would be undertaken during the verification process applied to ISPs.

Specific details for how these requirements would be implemented as well as current proposed proceduresfor the conduct of both chemical and biological contamination will be specified prior to the first draft meetingto allow committee review of the recommended changes to the standard.


And overwhelming amount of attention is being placed within the fire service for determining how effective cleaning is a removing contaminants from firefighter exposure during various emergency incidents, particularly as related to exposure to persistent chemical and carcinogenic contaminants. Research being conducted by the Fire Protection Research Foundation as partner organizations including the National Institute for Occupational Safety and Health (NIOSH), Intertek Testing Services (ITS), and International Personnel Protection, Inc. is being positioned to provide substantiation for any recommended procedures for cleaning validation as well as answer the question of “how clean is clean?”


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Street Address:

City:

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Particulate Penetration Inspection Methods

Separate inspection methods should be refined and incorporated into NFPA 1851 to address the particulateprotection offered by both ensembles and barrier hoods. Simple procedures can be implemented that arebased on the use of a surrogate aerosol containing a fluorescent agent such as the commercial productGlogerm, which can be sprayed onto the ensemble while a test subject carries out simulated firegroundactivity. An inexpensive black light can be then used to show any penetration of the fluorescent aerosolthrough the respective ensemble elements or interface areas onto the test subject’s skin or under clothing.These procedures have been employed in contaminated doffing exercises as well as by the Boston FireDepartment. The relative simplicity and low expense of the technique provides a means for firedepartments to easily evaluate selected ensembles and ensemble elements for their protection ofindividuals against particulate hazards.


Fire departments need simple tests to show how well their ensembles performed to prevent the inward leakage of particulates to either barrier hoods or complete ensembles. The proposed inspection technique can be easily performed and can be further used as a means for training firefighters on their relative exposures during fire ground operations. In addition, this technique has utility for showing cross contamination that occurs during the doffing process.




Street Address:

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Please address the carrying and moving around (storage) of dirty or contaminated gear in personalvehicles. If my gear is off gasing and must be cleaned or deconed, how is it safe for my car orpatient care areas such as inside an ambulance?


Safety of the ff and his family by not dragging around filthy gear


Submitter Full Name: melissa doak

Organization: [ Not Specified ]

Affilliation: None

Street Address:

City:

State:

Zip:

Submittal Date: Thu Dec 22 06:43:29 EST 2016


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Table A.4.2.3 requires updating to ensure that the same sections of NFPA 1971 in the secondcolumn still apply to the respective ensemble and ensemble element properties. At the very least,"CBRN" in the last row should be replaced with "Liquid and particulate contamination protective"and "Man-in-simulant (MIST)" should be replace with "Whole ensemble liquid integrity" and "Inwardparticulate leakage" with the correct paragraph numbers.


This section should be modified as the CBRN option has been removed from NFPA 1971 and there are no certified ensembles that meet these optional requirements. The proposed changes address the new optional category of liquid and particulate contamination protective ensembles.







Street Address:

City:

State:

Zip:



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Selection and assessment of structural or proximity gear using Chapter 5 of NFPA 1851.

Aircraft Rescue and Firefighting/USMC have units that deploy in an expeditonary environment.

The type of duties will rang from tent camp fire protection, fire prevention, ARFF, Rescue, EMR, andTactical Vehicle Response. The environment can range from desert to jungle and from hot to cold.

My question is:

Do we do the assessment based on the most severe mission, location, and environment?

Or do we as AHJ make an educated guess on what criteria to use?



Choosing Structural gear instead of Proximity gear for ARFF USMC units.


Submitter Full Name: Christopher Toten

Organization: Us Marine Corps

Street Address:

City:

State:

Zip:



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Public Input No. 45-NFPA 1851-2016 [ Section No. 1.1.4 ]

1.1.4

This standard shall also specify the minimum selection, care, and maintenance requirements for structuralfire fighting protective ensembles with optional CBRN liquid and particulate contamination protection andfor proximity fire fighting protective ensembles with optional CBRN liquid and particulate contaminationprotection.


This section is no longer needed as the CBRN option has been removed from NFPA 1971 and there are no certified ensembles that meet these optional requirements. The proposed changes address the new optional category of liquid and particulate contamination protective ensembles.



Public Input No. 46-NFPA 1851-2016 [Section No. 1.3.2.1]












Public Input No. 58-NFPA 1851-2016 [Section No. A.3.3.8]

Public Input No. 59-NFPA 1851-2016 [Global Input]

Public Input No. 60-NFPA 1851-2016 [Section No. A.5.1.8(2)]

Public Input No. 61-NFPA 1851-2016 [Section No. A.6.3.7.1]





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Public Input No. 46-NFPA 1851-2016 [ Section No. 1.3.2.1 ]

1.3.2.1

This standard shall also apply to structural fire fighting protective ensembles with optional CBRN liquid andparticulate contamination protection and to proximity fire fighting protective ensembles with optional CBRNliquid and particulate contamination protection.









Street Address:

City:

State:

Zip:



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1.3.4

This standard shall not apply to respiratory protective equipment other than where such equipmentinterfaces with structural fire fighting protective ensembles or proximity structural fire fighting protectiveensembles with the optional CBRN liquid and particulate contamination protection.









Street Address:

City:

State:

Zip:



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Public Input No. 7-NFPA 1851-2015 [ Chapter 2 ]

Chapter 2 Referenced Publications

2.1 General.

The documents or portions thereof listed in this chapter are referenced within this standard and shall beconsidered part of the requirements of this document.

2.2 NFPA Publications.

National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169-7471.

NFPA 600, Standard on Industrial Fire Brigades, 2010 edition.

NFPA 1500, Standard on Fire Department Occupational Safety and Health Program, 2013 edition.

NFPA 1951, Standard on Protective Ensembles for Technical Rescue Incidents, 2013 edition.

NFPA 1971, Standard on Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting,2013 edition.

NFPA 1972, Standard on Helmets for Structural Fire Fighting, 1992 edition.

NFPA 1973, Standard on Gloves for Structural Fire Fighting, 1993 edition.

NFPA 1974, Standard on Protective Ensembles for Proximity Fire Fighting, 1992 edition.


NFPA 1977, Standard on Protective Clothing and Equipment for Wildland Fire Fighting, 2011 edition.

NFPA 1991, Standard on Vapor-Protective Ensembles for Hazardous Materials Emergencies, 2005edition.

NFPA 1992, Standard on Liquid Splash–Protective Ensembles and Clothing for Hazardous MaterialsEmergencies, 2012 edition.

NFPA 1994, Standard on Protective Ensembles for First Responders to CBRN Terrorism Incidents, 2012edition.

NFPA 1999, Standard on Protective Clothing for Emergency Medical Operations, 2013 edition.

2.3 Other Publications.

2.3.1 ACGIH Publications.

American Conference of Governmental Industrial Hygienists, 1330 Kemper Meadow Drive, Cincinnati, OH45240.

ACGIH Publication No. 0107 0115 ,2007 2015 TLVs and BEIs.

2.3.2 ISO Publications.

International Organization for Standardization, ISO Central Secretariat 1 , ch. de la Voie-Creuse, Casepostale 56, CH-1211 Genève 20, Chemin de Blandonnet, 8, CP 401, 1214 Vernier, GenevaSwitzerland .

ISO/IEC 17011, Conformity assessment — General requirements for accreditation bodies accreditingconformity assessment bodies, 2004.

ISO/IEC Guide 65, General requirements for bodies operating product certification systems, 1996.(Superseded by ISO/IEC 17065)

ISO/IEC 17025, General requirements for the competence of testing and calibration laboratories, 2005,corrigendum 1, 2006 .

ISO/IEC 17065, Conformity Assessment - Requirements for Bodies Certifiying Products,Processes, and Services, 2012.


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2.3.3 U.S. Government Publications.

U.S. Government Printing Government Publishing Office, Washington, DC 20402-9325 732 NorthCapitol Street, NW, Washington, DC 20401-0001 .

NIOSH Publication No. 2005-149, NIOSH Pocket Guide to Chemical Hazards, September 2005.

2.3.4 Other Publications.

Lewis, R., Hazardous Chemicals Desk Reference, John Wiley & Sons, New York, 2002.

Merriam-Webster’s Collegiate Dictionary, 11th edition, Merriam-Webster, Inc., Springfield, MA, 2003.

2.4 References for Extracts in Mandatory Sections. (Reserved)


Referenced current SDO names, addresses, standard names, numbers, and editions.


Submitter Full Name: Aaron Adamczyk


Street Address:

City:

State:

Zip:

Submittal Date: Sun Dec 06 23:54:41 EST 2015


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Public Input No. 99-NFPA 1851-2017 [ Chapter 2 ]

Chapter 2 Referenced Publications

2.1 General.

The documents or portions thereof listed in this chapter are referenced within this standard and shall beconsidered part of the requirements of this document.

2.2 NFPA Publications.


NFPA 600, Standard on Industrial Fire Brigades,2010 2015 edition.


NFPA 1951, Standard on Protective Ensembles for Technical Rescue Incidents, 2013 edition.


NFPA 1972, Standard on Helmets for Structural Fire Fighting, 1992 edition.

NFPA 1973, Standard on Gloves for Structural Fire Fighting, 1993 edition.



NFPA 1977, Standard on Protective Clothing and Equipment for Wildland Fire Fighting,2011 2016edition.

NFPA 1991, Standard on Vapor-Protective Ensembles for Hazardous Materials Emergencies,2005 2016edition.

NFPA 1992, Standard on Liquid Splash–Protective Ensembles and Clothing for Hazardous MaterialsEmergencies, 2012 edition.






ACGIH Publication No. 0107, 2007 TLVs and BEIs.


International Organization for Standardization, ISO Central Secretariat 1, ch. de la Voie-Creuse, Casepostale 56, CH-1211 Genève 20, , BIBC II, Chemin de Blandonnet 8, CP 401, 1214 Vernier, Geneva,Switzerland.

ISO 17011, Conformity assessment — General requirements for accreditation bodies accrediting conformityassessment bodies, 2004.

ISO/IEC Guide 65, General requirements for bodies operating product certification systems ,1996.ISO/IEC 17025, General requirements for the competence of testing and calibration laboratories,2005.

ISO/IEC 17065, Conformity assessment - Requirements for bodies certifying products, processes andservices, 2012.


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U.S. Government Printing Office, Washington, DC 20402-9325.

NIOSH Publication No. 2005-149, NIOSH Pocket Guide to Chemical Hazards, September 2005.

2.3.4 Other Publications.



2.4 References for Extracts in Mandatory Sections. (Reserved)


Changes reflect updates to addresses, standards and revision dates since last publication of NFPA 1851.Several NFPA standards will require updating in second revision.


Submitter Full Name: Karen Lehtonen

Organization: Lion Group, Inc.

Street Address:

City:

State:

Zip:



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Public Input No. 197-NFPA 1851-2017 [ Section No. 2.3 ]




ACGIH Publication No. 0107, 2007 TLVs and BEIs .


International Organization for Standardization, ISO Central Secretariat 1, ch. de la Voie-Creuse, Casepostale 56, CH-1211 Genève 20, Switzerland.

ISO 17011, Conformity assessment — General requirements for accreditation bodies accrediting conformityassessment bodies, 2004.

ISO/IEC Guide 65, General requirements for bodies operating product certification systems, 1996.

ISO/IEC 17025, General requirements for the competence of testing and calibration laboratories, 2005.


U.S. Government Printing Office, Washington, DC 20402-9325.

NIOSH Publication No. 2005-149, NIOSH Pocket Guide to Chemical Hazards , September 2005.

2.3.4 2 Other Publications.




The ACGIH and NIOSH publications are being moved to the annex because they have been eliminated from the definition of carcinogen and placed in the annex information. They are also updated.



Public Input No. 195-NFPA 1851-2017 [New Section after A.3.2.4]


Public Input No. 199-NFPA 1851-2017 [Section No. B.1.2.9]

Public Input No. 201-NFPA 1851-2017 [New Section after B.1.2.9]


Submitter Full Name: Marcelo Hirschler

Organization: GBH International

Street Address:

City:

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3.2.3 Labeled.

The manufacture shall attach a label to each piece of equipment. Identifying each piece with a uniqueserial number so that the equimpent can be track throughout its life. Equimpent that shall have serialnumbers are helmet, hood, gloves, coat, boots and pants.

Equipment or materials to which has been attached a label, symbol, or other identifying mark of anorganization that is acceptable to the authority having jurisdiction and concerned with product evaluation,that maintains periodic inspection of production of labeled equipment or materials, and by whose labelingthe manufacturer indicates compliance with appropriate standards or performance in a specified manner.


At this time gloves and hoods only have LOT numbers on them when purchased from manufacture. When these items are re-issued to other personnel it is impossible to track the exact hood or gloves when all gloves and hoods that are purchased have the same LOT number.


Submitter Full Name: Daniel Willott

Organization: Portland Fire Department

Affilliation: Portland Fire Department

Street Address:

City:

State:

Zip:

Submittal Date: Fri Dec 04 20:11:57 EST 2015


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Public Input No. 18-NFPA 1851-2016 [ New Section after 3.3 ]

Recommendation: Add definitions and supporting appendix information as shown in the attached.



Holds_for_F2018_1851.docx 1851_PC Log 39


NOTE: This Public Input appeared as "Reject but Hold" in Comment Log No. 39 of the F2013 ROC Report for NFPA 1851 and per the Regs. at 4.4.8.3.1. Provide additional appendix information to A.7.1.6 to read as follows:The U. S. Environmental Protection Agency (EPA) applies the following requirements to antimicrobial products whichbear label claims or recommendations for use in the treatment of laundry to provide disinfecting or sanitizing activity for fabrics and/or laundry water. Label claims must distinguish between products recommended as soaking treatments prior to laundering and products represented as additives in actual laundry operations.Products recommended for pre-soaking soiled fabrics prior to routine laundering must be shown to be effective by appropriate tests (e.g. AOAC Use Dilution Method for disinfectants; Sanitizer Test for inanimate non-food contact surfaces for sanitizers) in the presence of organic soil (e.g. 5% blood serum). The directions for use must specify rinsing of the items to remove gross filth prior to soaking, followed by complete immersion in an adequate volume of soaking solution (at least 5:1 w/w solution to fabric ratio, e.g. half a washload in a 3 - gallon pail) at the recommended usedilution for a specified contact time prior to the laundering operation.A clear distinction should be made on the label between products recommended for household laundering andproducts represented as commercial-industrial-institutional laundry additives. The water to fabric ratio in home machines is about 10:1 (w/w), whereas in industrial laundering operations the ratio is about 5:1. The effectiveness of products may be significantly altered by these differences; thus, demonstrated efficacy in one system may not be able to be for front-loading automatics (e.g. 8-10 gallon water capacity) and top-loading automatics and wringer-type washers (e.g. 12-15 gallon water capacity). Product dosages, in this instance, should be specified in household measurements. Dosage instructions for industrial laundering may be based on pounds of dry fabric.The directions for use of laundry additives should specify the machine cycle in which the product is to be added, water level, temperature range, and treatment time. Compatibility of the treatment with other common laundry additives (e.g. soaps, detergents, bleach, starch, bluing, sours, fabric softeners) should be determined in testing and addressed in labeling, when applicable.Efficacy data requirements for disinfectants and sanitizers intended for use as additives in laundry operations are as follows:DisinfectionTest standard – A proposed simulated use procedure employed by Petrocci and Clarke (Petrocci, A. M. and Clarke, P.1969. Proposed Test Method for Antimicrobial Laundry Additives. Journal Association of Analytical Communities, 52:836-842) is acceptable. Alternately, a simulated-use study utilizing washing machines may be employed. The following basic elements must be incorporated in either study:(1) The test bacteria are Staphylococcus aureus (ATCC 6538) and Klebsiella pneumonia (ATCC 4352). If the product is intended for use on hospital linens, it must also be tested against Pseudomonas aeruginosa (ATCC 15442).(2) The basic bacteriological procedures must be the same as those specified in the Petrocci and Clarke protocol.(3) Tests must be conducted with 3 product samples, representing 3 different batches, one of which is at least 60 days old. Each sample must be tested with 9 fabric swatches against each of the specified test bacteria.(4) The method employed must be designed to include testing both the fabric and the laundry water (5 ml from the automatic washer, or 0.5 ml from the simulated washing device in individual widemouth jars containing subculture media and neutralizers. The laundry water-to-media volume ratio must not exceed 1:40.(5) Growth or no-growth must be recorded and reported after a 48-hour incubation period.


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Performance standard – There must be no growth in the fabric subcultures and no growth in the subcultures from the laundry water with all test bacteria.SanitizationTest standard – The same type of studies referred to under "Disinfection" above must be employed for evaluating the efficacy of laundry additives intended to sanitize laundry, with the following exceptions:(1) Tests must be conducted with 3 samples representing 3 product batches, one of which is at least 60 days old. Each sample must be tested with 3 cloth swatches against each test microorganism required.(2) Quantitative bacteriological assays must be conducted and the results reported.Performance standard – The data requirements outlined herein do not apply to sodium-calcium hypochlorites, sodium-potassium dichloro-s-triazinetriones or trlchloro-s-triazinetrione.These procedures may also be conducted in accordance with ASTM E2406 - 09 Standard Test Method for Evaluation of Laundry Sanitizers and Disinfectants for Use in High Efficiency Washing OperationsResidual Self-SanitizationLaundry operations – A clear distinction should be made on the label between products recommended for household laundering and products represented as commercial-industrial-institutional laundry additives. The water to fabric ratio in home machines is about 10:1 (w/w), whereas in industrial laundering operations the ratio is about 5:1. The effectiveness of products may be significantly altered by these differences; thus, demonstrated efficacy in one system may not be extrapolated to the other. In addition, directions for use of household laundering products may require different dosages for front-loading automatics (e.g., 8-10 gallon water capacity) and top-loading automatics and wringer-type washers(e.g., 12-15 gallon water capacity). Product dosages, in this instance, should be specified in household measurements. Dosage instructions for industrial laundering may be based on pounds of dry fabric. The directions for use of laundry additives should specify the machine cycle in which the product is to be added, water level, temperature range, and treatment time. Compatibility of the treatment with other common additives (e.g., soaps, detergents, bleach, starch, bluing, sours, fabric softeners) should be determined in testing an addressed in labeling, when applicable.Test standard – A suggested protocol published by Petrocci and Clarke (J. AOAC 52:836-842) is acceptable for treating the fabric. The basic elements outlined in the protocol of the "Quantitative Procedure" of the American Association of Textile Chemists and Colorists (AATCC) Test Method 100 employing Staphylococcus aureus (ATCC6538) and Klebsiella pneumoniae (ATCC 4352) are acceptable for evaluating the residual antimicrobial activity. However, 3 samples, representing 3 different product batches must be tested, and the following modifications to the method must be incorporated:(1) Use a sufficient number of swatches placed exactly on top of each other so that they completely absorb 1 ml of inoculum which is prepared to contain at least 107 microorganisms/ml.(2) The number of swatches used per jar must be reported. (4) Quantitative bacteriological assays should be performed at the following time intervals: 0, 30 min., 1-hr, 3-hr, 6-hr, and 24-hr. Consideration could be given to fewer or different time intervals, depending on the label claims, on acase-by-case basis.Performance standard – For residual self-sanitizing claims against pathogenic microorganisms, the reduction of each test microorganism must be at least 99.9% over the "0-time" control and the parallel untreated inoculated control.All disinfectants and sanitizers should be shown to not degrade the performance properties of protective ensemble elements by using similar procedures described in A.7.1.9.

The submitter of the comment and the TC believes that further research should be undertaken for providing detailed guidance to the fire service and service providers in their selections of agents for biological decontamination.


Submitter Full Name: Tc On Fae-Spf

Organization: NFPA

Street Address:

City:

State:


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Submittal Date: Tue Nov 22 14:44:06 EST 2016


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Report on Comments – November 2012 NFPA 1851

Printed on 11/22/2016 1

1851-19 Log #39 FAE-SPF

Jeffrey O. Stull, International Personnel Protection, Inc.

1851-33

Add definitions and supporting appendix information to read as follows:

A type of antimicrobial agent that kills or irreversibly inactivates at least 99.9 percent of all

microorganisms present on a surface.

Sanitizers reduce levels of microorganism to safe levels. The EPA requires as a minimum that a

sanitizer reduce the level of and or by 99.9% on

non-food contact surfaces within 5 minutes.

A type of antimicrobial agent that destroys or irreversibly inactivates microorganisms on

hard,inanimate surfaces and objects.

Disinfectants are only intended for hard, non-porous surfaces. Hard, non-porous surfaces do not

include the textile products used in fire fighter protective clothing. All disinfectants must be registered with the EPA and

meet specific labeling requirements. A listing of currently registered disinfectants can be found at

http://www.epa.gov/oppad001/chemregindex.htm.

Disinfectants are classified as:

Limited – Must be supported by efficacy testing against either Salmonella cholerasuis (gram-negative bacteria) or

Staphylococcus aureus (gram-positive bacteria). Limited disinfectants are found mostly in household use.

General – Must be supported by efficacy testing against both Salmonella cholerasuis and Staphylococcus aureus.

General disinfectants are used in commercial areas.

Hospital – Must be supported by Association of Analytical Communities (AOAC) Use Dilution or AOAC Germicidal

Spray efficacy testing against Staphylococcus aureus, Salmonella cholerasuis and Pseudomonas aeruginosa. The

bacteria Pseudomonas aeruginosa hides behind biofilm and is difficult to eliminate. Killing of this bacteria is required for

Hospital Disinfectants.

The EPA’s definition of a general or “broad spectrum” disinfectant is one that has public health claims for all three of

the major classes of organisms:

Bacteria – effective against gram-negative and gram-positive bacteria

Fungi – effective against at least one pathogenic fungi (usually Trichophyton mentagrophytes)

Viruses – effective against pathogenic viruses (at least one enveloped virus such as Influenza A and one

non-enveloped virus such as Adenovirus).

Sanitizers are not considered broad spectrum by EPA’s definition since they are only meant to reduce bacteria levels.

Modify current requirement to read as follows:

Organizations shall have written procedures detailing the decontamination and cleaning processes for

ensembles and ensemble elements contaminated with body fluids. Where used, these processes shall only employ

disinfectants or sanitizers that have are registered and have been properly validated as to the specification claims of

disinfection and sanitization. Selected disinfectants and sanitizers shall not degrade the performance properties of

protective ensemble elements. Universal precautions shall be observed at all times by members handling elements

known or suspected to be contaminated with body fluids.

Provide additional appendix information to A.7.1.6 to read as follows: The U. S. Environmental Protection Agency (EPA) applies the following requirements to antimicrobial products which

bear label claims or recommendations for use in the treatment of laundry to provide disinfecting or sanitizing activity for

fabrics and/or laundry water. Label claims must distinguish between products recommended as soaking treatments prior

to laundering and products represented as additives in actual laundry operations.

Products recommended for pre-soaking soiled fabrics prior to routine laundering must be shown to be effective by

appropriate tests (e.g. AOAC Use Dilution Method for disinfectants; Sanitizer Test for inanimate non-food contact

surfaces for sanitizers) in the presence of organic soil (e.g. 5% blood serum). The directions for use must specify rinsing

of the items to remove gross filth prior to soaking, followed by complete immersion in an adequate volume of soaking

solution (at least 5:1 w/w solution to fabric ratio, e.g. half a washload in a 3 - gallon pail) at the recommended use

dilution for a specified contact time prior to the laundering operation.

A clear distinction should be made on the label between products recommended for household laundering and

products represented as commercial-industrial-institutional laundry additives. The water to fabric ratio in home machines

is about 10:1 (w/w), whereas in industrial laundering operations the ratio is about 5:1. The effectiveness of products may

be significantly altered by these differences; thus, demonstrated efficacy in one system may not be able to be

http://www.epa.gov/oppad001/chemregindex.htm

http://www.epa.gov/oppad001/chemregindex.htm

Printed on 11/22/2016 2

Report on Comments – November 2012 NFPA 1851 extrapolated to the other. In addition, directions for use of household laundering products may require different dosages

for front-loading automatics (e.g. 8-10 gallon water capacity) and top-loading automatics and wringer-type washers (e.g.

12-15 gallon water capacity). Product dosages, in this instance, should be specified in household measurements.

Dosage instructions for industrial laundering may be based on pounds of dry fabric.

The directions for use of laundry additives should specify the machine cycle in which the product is to be added, water

level, temperature range, and treatment time. Compatibility of the treatment with other common laundry additives (e.g.

soaps, detergents, bleach, starch, bluing, sours, fabric softeners) should be determined in testing and addressed in

labeling, when applicable.

Efficacy data requirements for disinfectants and sanitizers intended for use as additives in laundry operations are as

follows:

Disinfection

Test standard – A proposed simulated use procedure employed by Petrocci and Clarke (Petrocci, A. M. and Clarke, P.

1969. Proposed Test Method for Antimicrobial Laundry Additives. Journal Association of Analytical Communities, 52:

836-842) is acceptable. Alternately, a simulated-use study utilizing washing machines may be employed. The following

basic elements must be incorporated in either study:

(1) The test bacteria are Staphylococcus aureus (ATCC 6538) and Klebsiella pneumonia (ATCC 4352). If the product

is intended for use on hospital linens, it must also be tested against Pseudomonas aeruginosa (ATCC 15442).

(2) The basic bacteriological procedures must be the same as those specified in the Petrocci and Clarke protocol.

(3) Tests must be conducted with 3 product samples, representing 3 different batches, one of which is at least 60 days

old. Each sample must be tested with 9 fabric swatches against each of the specified test bacteria.

(4) The method employed must be designed to include testing both the fabric and the laundry water (5 ml from the

automatic washer, or 0.5 ml from the simulated washing device in individual widemouth jars containing subculture media

and neutralizers. The laundry water-to-media volume ratio must not exceed 1:40.

(5) Growth or no-growth must be recorded and reported after a 48-hour incubation period.

Performance standard – There must be no growth in the fabric subcultures and no growth in the subcultures from the

laundry water with all test bacteria.

Sanitization

Test standard – The same type of studies referred to under "Disinfection" above must be employed for evaluating the

efficacy of laundry additives intended to sanitize laundry, with the following exceptions:

(1) Tests must be conducted with 3 samples representing 3 product batches, one of which is at least 60 days old. Each

sample must be tested with 3 cloth swatches against each test microorganism required.

(2) Quantitative bacteriological assays must be conducted and the results reported.

Performance standard – The data requirements outlined herein do not apply to sodium-calcium hypochlorites,

sodium-potassium dichloro-s-triazinetriones or trlchloro-s-triazinetrione.

These procedures may also be conducted in accordance with ASTM E2406 - 09 Standard Test Method for Evaluation

of Laundry Sanitizers and Disinfectants for Use in High Efficiency Washing Operations

Residual Self-Sanitization

Laundry operations – A clear distinction should be made on the label between products recommended for household

laundering and products represented as commercial-industrial-institutional laundry additives. The water to fabric ratio in

home machines is about 10:1 (w/w), whereas in industrial laundering operations the ratio is about 5:1. The effectiveness

of products may be significantly altered by these differences; thus, demonstrated efficacy in one system may not be

extrapolated to the other. In addition, directions for use of household laundering products may require different dosages

for front-loading automatics (e.g., 8-10 gallon water capacity) and top-loading automatics and wringer-type washers

(e.g., 12-15 gallon water capacity). Product dosages, in this instance, should be specified in household measurements.

Dosage instructions for industrial laundering may be based on pounds of dry fabric. The directions for use of laundry

additives should specify the machine cycle in which the product is to be added, water level, temperature range, and

treatment time. Compatibility of the treatment with other common additives (e.g., soaps, detergents, bleach, starch,

bluing, sours, fabric softeners) should be determined in testing an addressed in labeling, when applicable.

Test standard – A suggested protocol published by Petrocci and Clarke (J. AOAC 52:836-842) is acceptable for

treating the fabric. The basic elements outlined in the protocol of the "Quantitative Procedure" of the American

Association of Textile Chemists and Colorists (AATCC) Test Method 100 employing Staphylococcus aureus (ATCC

6538) and Klebsiella pneumoniae (ATCC 4352) are acceptable for evaluating the residual antimicrobial activity.

However, 3 samples, representing 3 different product batches must be tested, and the following modifications to the

method must be incorporated:

(1) Use a sufficient number of swatches placed exactly on top of each other so that they completely absorb 1 ml of

inoculum which is prepared to contain at least 107 microorganisms/ml.

(2) The number of swatches used per jar must be reported.

Printed on 11/22/2016 3

Report on Comments – November 2012 NFPA 1851

(3) Incubation must be at 20-21°C (68-70°F).

(4) Quantitative bacteriological assays should be performed at the following time intervals: 0, 30 min., 1-hr, 3-hr, 6-hr,

and 24-hr. Consideration could be given to fewer or different time intervals, depending on the label claims, on a

case-by-case basis.

Performance standard – For residual self-sanitizing claims against pathogenic microorganisms, the reduction of each

test microorganism must be at least 99.9% over the "0-time" control and the parallel untreated inoculated control.

All disinfectants and sanitizers should be shown to not degrade the performance properties of protective ensemble

elements by using similar procedures described in A.7.1.9.

The submitter of the comment and the TC believes that further research should be undertaken

for providing detailed guidance to the fire service and service providers in their selections of agents for biological

decontamination.

Affirmative: 30

4 Barker, R., Davis, R., Doan, S., Durby, T.


3.3.2 Advanced Cleaning.

See 3.3.13.1. Advanced Cleaning.


The Editorial Task Group would like the definition to be consistent with other definitions that point the reader to another section by naming the test in the referenced section.




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3.3.5* Carcinogen/Carcinogenic.

A cancer-causing substance that is identified in one of several published lists, including, but not limited to,NIOSH Pocket Guide to Chemical Hazards, Hazardous Chemicals Desk Reference , and the ACGIH 2007TLVs and BEIs those prepared by the U.S. National Toxicology Program, the International Agency forResearch on Cancer (IARC), the National Institute for Occupational Safety and Health (NIOSH), and theAmerican Conference of Governmental Industrial Hygienists (ACGIH) .


The proposed changes update the definition and expand the sources for identifying carcinogens. A related annex item is separately provided to given a actual source lists.







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3.3.5 * Carcinogen/Carcinogenic.

A cancer-causing substance that is identified in one of several published lists, including, but not limited to,NIOSH Pocket Guide to Chemical Hazards, Hazardous Chemicals Desk Reference , and the ACGIH 2007TLVs and BEIs .


Carcinogens are cancer causing substances, irrespective of whether they are identified or not in any list. Moreover, references to other documents or standards should not be included in definitions. This information is being moved to the annex.










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3.3.8 * CBRN Barrier Layer.

The part of the composite that is intended to provide protection against CBRN terrorism agents.


This term is no longer needed as the CBRN option has been removed from NFPA 1971 and there are no certified ensembles that meet these optional requirements.







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3.3.13 Cleaning.

The act of removing soils soiling and contaminants contamination from ensembles and ensembleelements by mechanical, chemical, thermal, or combined processes.

3.3.13.1* Advanced Cleaning.

The thorough cleaning of ensembles or elements by washing with cleaning agents.

3.3.13.2* Routine Cleaning On Scene (Preliminary) Cleaning .

The light cleaning of ensembles or ensemble elements performed at or near the emergency scene or assoon as practically possible by the end user without taking the elements out of service .

3.3.13.3* Specialized Cleaning.

Cleaning to remove hazardous materials or , body fluids, or other forms of contamination .


The current hierarchy of cleaning definitions is not consistent with actual practice or the approach that is needed to reduce the spread of persistent contamination following emergency operations. The proposal of the term “on scene” cleaning is intended to connote that cleaning must start as soon as possible following the exit from the fire ground or other emergency area.



Public Input No. 205-NFPA 1851-2017 [Sections A.3.3.13.1, A.3.3.13.2, A.3.3.13.3]






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3.3.15* Contamination/Contaminated .

The process by which ensembles and ensemble elements are exposed to hazardous materials, bodyfluids, accumulation of hazardous materials on or in an ensemble or ensemble elment that includescarcinogenic, toxic, corrosive, or sensitizing chemicals, potentially infectious body fluids, other infectiousmicroorganisms, or CBRN terrorism agents.


A clearer, more robust definition is needed for contamination that identifies other forms of potential contaminants. The definition has also been made consistent with soiling. An annex section is separately recommended to provide further explanation of the definition.



Public Input No. 144-NFPA 1851-2017 [New Section after A.3.3.13.3]




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3.3.22* Disinfectant.

An A type of antimicrobial agent that destroys , neutralizes, or inhibits the growth of harmful biologicalagents or irreversibly inactivates microorganisms on hard, inanimate surfaces and objects .


The proposed definition is consistent with the definition provided by the EPA regarding the classification of antimicrobial agents. An annex item is separately provided to provide further clarification of the definition.



Public Input No. 150-NFPA 1851-2017 [New Section after A.3.3.13.3]




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3.3.49 Independent Service Provider (ISP).

An independent third party utilized by an organization to perform services. In order to comply with thestandard, an ISP must be verified. See 3.3.110, Verified Independent Service Provider (ISP).


The Editorial Task Group would like to add a definition for an ISP. The task group acknowledges that the definition was removed in the 2014 edition because the committee did not want to imply that an ISP could comply with the standard without being verified. This definition addresses that issue while providing a basic, generic definition of an ISP.




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3.3.56 Major A Seam.

See 3.3.81.1. Major A Seam.






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3.3.57 Major B Seam.

See 3.3.81.2. Major B Seam






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3.3.59 Manufacturer-Trained Organization.

See 3.3.63.1 Manufacturer-Trained Organization .






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3.3.61 Minor Seam.

See 3.3.81.3 Minor Seam .






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3.3.71 Proximity Fire Fighting Protective Ensemble with Optional CBRN Terrorism Agent Liquid andParticulate Contamination Protection.

A compliant proximity fire fighting protective ensemble that is also certified as an entire ensemble to meetthe optional requirements for protection from specific CBRN terrorism agents liquid and particulatecontaminants .


This term has been revised to be consistent with the new edition of NFPA 1971 and addresses the new optional category of liquid and particulate contamination protective ensembles.







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Public Input No. 151-NFPA 1851-2017 [ New Section after 3.3.80 ]

3.3.X* Sanitizer. A type of antimicrobial agent that kills or irreversibly inactivates at least 99.9percent of all microorganisms present on a surface.


The definition of sanitizer is needed to differentiate its antimicrobial activity against a disinfectant. The proposed term is consistent with the EPA definition of a sanitizer.







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3.3.80 Routine Cleaning.

See 3.3.13.2 Routine Cleaning .






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3.3.87* Soiled/ Soiling.

The accumulation of materials that are not considered hazardous materials, body fluids, or CBRN terrorismagents but that could degrade the performance of the ensemble or ensemble element sweat, dust, dirt,debris, and other non-hazardous materials on or in an ensemble or ensemble element that could degradeits performance .


The current definition does not define what soiling is but instead what it is not. The proposed definition provides a clearer description of soiling. A separate annex section is being recommended to clarify the definition of soiling. "Soiled" does not need to be defined as it is the action of soiling.







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3.3.88 Specialized Cleaning.

See 3.3.13.3 Specialized Cleaning .






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3.3.94 Structural Fire Fighting Protective Ensemble with Optional CBRN Terrorism Agent Liquid andParticulate Contamination Protection.

A compliant structural fire fighting protective ensemble that is also certified as an entire ensemble to meetthe optional requirements for protection from specific CBRN terrorism agents liquid and particulatecontaminants .


This term has been revised to be consistent with the new edition of NFPA 1971 and addresses the new optional category of liquid and particulate contamination protective ensembles.







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Structural Fire Fighting Protective Barrier Hood

Structural Fire Fighting Protective Hood. The interface element of the protective ensemble thatprovides limited protection to the coat/helmet/SCBA facepiece interface area. This type of hoodincorporates a additional Barrier layer designed to prevent penetration of liquids and particulates throughtthe hood.


There is not currently a definition for "Barrier Hoods" that have become very prevalent in the market place






Submitter Full Name: Bruce Varner

Organization: BHVarner & Associates

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3.3.111 Verified Organization.

See 3.3.63.2 Verified Organization .






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4.2.4.6

Manufacturer trained organizations performing Organizations who wish to perform advanced cleaning andadvanced inspection shall be trained by an element manufacturer of the same element type or by a verifiedISP. The element manufacturer or verified ISP shall provide documentation that the organization hasreceived the necessary training.


The Editorial Task Group suggests these changes to make the section clearer and easier to understand. The changes do not affect the meaning of the section.




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4.3.4

The organization shall compile and maintain records as required by 4.3.3 on fire fighting protectiveensembles with CBRN liquid and particulate contamination protection. The records shall include a list ofspecific required elements and interface components necessary for structural fire fighting protectiveensembles with optional CBRN terrorism agent liquid and particulate contamination protection andproximity fire fighting protective ensembles with optional CBRN terrorism agent liquid and particulatecontamination protection.


This paragraph is no longer needed as the CBRN option has been removed from NFPA 1971 and there are no certified ensembles that meet these optional requirements. The proposed changes address the new optional category of liquid and particulate contamination protective ensembles.







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A.4.5.4

Public facilities include but are not limited to the home, home laundries, public laundries, commerciallaundries, dry cleaners, stores, offices, private cars, and private homes. All efforts must be made to preventexposing the public to soil and contaminants.


The Editorial Task Group suggests adding an annex item to expand on the change in 4.5.4.



Public Input No. 120-NFPA 1851-2017 [Section No. 4.5.4] This is the annex item for 4.5.4




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4.5.4

Soiled or potentially contaminated ensembles or ensemble elements shall not be brought into the home,washed in home laundries taken to public facilities , or washed transported in public laundries privatevehicles .


The Editorial Task Group suggests this change to clearly state that the public cannot be exposed to soil and contaminants. Because the original statement limits the restriction to home, home laundries, and public laundries, it’s missing public dry cleaners and all other public places dirty gear should not go (like grocery stores). This language makes the restriction more in line with what the committee intended.



Public Input No. 121-NFPA 1851-2017 [New Section after 4.5.4]




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4.6.3

The organization shall request written acknowledgment from the that the report of health and safetyconcerns was received by the element manufacturer and certification organization. Writtenacknowledgment must be received within 30 days of the date of the report of health and safety concerns .


The Editorial Task Group would like to specify what the written acknowledgment is acknowledging. The meaning of the section is not changed, but it is much clearer.




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Public Input No. 42-NFPA 1851-2016 [ Sections 5.1.1, 5.1.2 ]

Sections 5.1.1, 5.1.2

5.1.1*

Prior to starting the selection process of structural fire fighting ensembles and ensemble elements andproximity fire fighting ensembles and ensemble elements, the organization shall perform a risk assessment.

5.1. 1.1*

The organization shall distinguish between the use of structural fire fighting ensembles and proximity firefighting ensembles based on the operating area and mission responsibilities of the organization. The riskassessment shall be based on both the frequency and severity of exposure to specific hazards as a meansfor determining the selection of appropriate firefighting protective ensembles.

5.1.1. 2 *

The organization shall review the risk assessment or conduct a new risk assessment at least every twoyears or under the following circumstances including but not limited to:

(1) When there are changes that affect the findings of the current risk assessment in terms of the specificidentification of hazards or availability of fire fighting ensemble product technology

(2) When there are changes in the organization’s standard operating procedures for the use of structuralfire fighting ensembles or proximity fire fighting ensembles

(3) When any personal protective ensemble or ensemble elements are being considered for selection andpurchase

5.1.2

The risk assessment shall include, but not be limited to, the hazards that can be encountered by structuralor proximity fire fighters based on the following:

(1)

Frequency of use of ensemble elements

(2) * Distinguishing response activities for different potential incidents

(3) Organization’s experiences

(4) Incident operations

(5) Geographic location and climate

(6)

(7)


NFPA 1851 addresses the organization’s selection of appropriate fire fighting protective ensembles. Currently, insufficient detail exists within the standard to distinguish between the decision for selecting protective ensembles for either structural or proximity fire fighting. The lack of detail in both the mandatory and nonmandatory parts the standards does not provide adequate information for organizations to consider which type of protective ensemble to have available for the respective hazards that the organization may face as part of its firefighting responsibilities. In fact, this deficiency has led some organizations to dismiss the need for proximity fire fighting protective ensembles on the basis of an overly simplistic hazard assessment that does not recognize the specific risks and potential for those fire fighter injury or fatalities in high radiant fire environments, such as aircraft fires. Such hazards require additional radiant protection afforded by proximity fire fighting protective ensembles.

Outside organizations rely on the specific requirements and guidance provided in NFPA 1851 to support selection decisions that they make. Therefore it is incumbent that the NFPA 1851 standard includes the appropriate provisions to aid in the selection of protective ensembles that are commensurate with the specific hazards and risks faced by the fire fighters. This includes the requirements for different organizations to select structural,

* Type of duties performed

* Specific physical area of operation

* Likelihood of or response to CBRN terrorism incident


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proximity, or both types of fire fighting protective ensembles.

This language was developed by the NFPA 1851 Risk Assessment Task Group chaired by Earl Hayden.



Public Input No. 43-NFPA 1851-2016 [Sections A.5.1, A.5.1.1, A.5.1.2(1), A.5.1.2(6),A.5.1.2(7)]




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5.1.5.1*

Organizations shall specifically consider the tradeoffs in the level of thermalinsulation, as measured by material composite thermal protective performance, andthermal comfort, as measured by material composite total heat loss and evaporativeresistance, for their selection of protective garments.


A substantial decision for organizations in selecting protective garments is to consider the tradeoffs between the protection from heat and the stress induced by the garment. Thermal protective performance, total heat loss, and evaporative resistance of the principal material composite offer information that is helpful to the fire department. The balance in these properties affects fire department tactics and protection strategies and should be highlighted. It is further proposed that additional language be prepared for the annex that explains the differences in the performance properties and how these properties can be viewed in making decisions on the selection of protective garments.




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TITLE OF NEW CONTENT


Add new section after 5.1.6*

Based on the risk assessment, the organization shall ensure that eye and face protection components orseparate devices are specified to provide adequate eye and face protection for each type of incidentidentified in the risk assessment.

Related Annex:

More than one type of eye and face protection component as provided with the helmet or separate eye andface protection devices may be needed to cover the full range of activities for which the organizationconducts emergency response operations. For example, while the full facepiece of the self-containedbreathing apparatus (SCBA) provides primary eye protection during structural fires including overhaul,organizations may rely on faceshields and goggles provided with helmets for eye and face protection whennot wearing the SCBA facepiece. To fulfill this requirement, an organization may have to specify separateeye and face protection devices that are suitable for providing individual member protection during othertypes of emergency operations.


Fire fighters may encounter a variety of differnt eye and face exposure hazards for which different forms of eye and face protection are needed. While some of this protection may be offered by the SCBA facepiece, the different types of components provided with the helmet , either faceshields, goggles, or both, should be further considered in how the organization determines the suitable ensemble for protecting its members.


Submitter Full Name: Robert Tutterow

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Submittal Date: Tue Jan 03 16:40:33 EST 2017


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5.1.8*

Where the organization develops purchase specifications, at least the following criteria shall be included:

(1) Purchase specifications shall require that the ensemble or ensemble element(s) to be purchased shallbe compliant with the current edition of NFPA 1971, Standard on Protective Ensembles for StructuralFire Fighting and Proximity Fire Fighting. Purchasers shall consider that ensembles that are certified tothe optional CBRN requirement liquid and particulate contamination protection requirement are testedand certified as ensembles and must be worn as an ensemble with all elements and interfacecomponents present as stated on the element label.

(2)

(3)

(4)

(5)


This paragraph should be modified as the CBRN option has been removed from NFPA 1971 and there are no certified ensembles that meet these optional requirements. The proposed changes address the new optional category of liquid and particulate contamination protective ensembles.







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* Where the organization selects criteria that exceed the minimum requirements of the current editionof NFPA 1971, such criteria shall be stipulated in the purchase specifications.

* Purchase specifications shall require that manufacturers’ bids include substantiation of certificationfor each element and model stated in the bid.

* Where applicable, the purchase specifications shall define the process for determining proper fit.

* The organization shall compare each bid submittal against purchase specifications.


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Initial Inspection.

Protective ensemble and ensemble elements shall inspected before initial use with requirements specifiedin Chapter 6 .


Issuing new uninspected ensemble may result in unserviceable ensemble being used by firefighters. Advanced gear inspection is necessary to insure the ensemble is serviceable. We have found a 40 to 80 percent failure rate of various lots of items upon receipt from the distributor. Specifically, boots and gloves fail water resistance test, and helmet skull caps with soft spots in excess of manufacture's recommendation.These are not manufacture specific and have been recorded during our initial inspections from several different manufactures.


Submitter Full Name: Douglas Pool

Organization: Bryan Fire Department

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Submittal Date: Mon Dec 12 10:12:09 EST 2016


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Public Input No. 90-NFPA 1851-2017 [ Sections 6.1.4.1, 6.1.4.2 ]

Sections 6.1.4.1, 6.1.4.2

6.1.4.1

As a minimum, any necessary cleaning or decontamination shall be done in accordance with therequirements specified in Chapter 7. Where a condi on exists that is beyond rou ne cleaning in accordance

with 7.2, the element shall be removed from service, tagged and referred to personnel responsible for Advanced

Cleaning.

6.1.4.2

As a minimum, any necessary repairs shall be made in accordance with the requirements specified inChapter 8. Where a condi on exists that is beyond basic repair in accordance with 8.3, the element shall be

removed from service, tagged and referred to personnel responsible for Repair.


This additional requirement provides the end user with more detail on what to do if something is found during the inspection process. There is similar language in NFPA 1852.




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6.2.1

Individual members shall conduct a routine inspection of their protective ensembles and ensembleelements upon issue and , at the beginning of each duty period and after each use.


A routine inspection should also be conducted at the beginning of each duty period to ensure the elements are fit for use.




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Public Input No. 123-NFPA 1851-2017 [ Section No. 6.2.2 [Excluding any Sub-Sections] ]

The routine inspection shall include, as at a minimum, the inspections specified in 6.2.2.1 through 6.2.2.7.


The Editorial Task Group thinks “at” is correct usage. The meaning of the statement is not changed.




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6.2.2.2

Hood elements shall be inspected for the following:

(1) Soiling

(2) Contamination

(3) Physical damage such as the following:

(4) Rips, tears, and cuts

(5) Thermal damage

(

(a) such as charring, burn holes, melting, or discoloration of any layer

)

(a)

(6) Loss of face opening adjustment

(7) Loss of seam integrity and broken or missing stitches


The Editorial Task Group suggests making these sections consistent with the respective tables in the annex (Thermal damage only).



Public Input No. 136-NFPA 1851-2017 [Section No. 6.2.2.4] Legislative text related to annex edit




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6.2.2.2


(1) Soiling

(2) Contamination



(5) Thermal damage (charring, burn holes, melting, discoloration of any layer)

(6) Loss of face opening adjustment

(7) Loss of seam integrity and broken or missing stitches, any damage to the barrier material (BarrierHoods Only)


Barrier Hoods are not currently addressed by 1851, this and other proposed changes address this problem


Submitter Full Name: [ Not Specified ]


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6.2.2.4

Glove elements shall be inspected for the following:

(1) Soiling

(2) Contamination



(5) Thermal damage (charring, burn holes, melting, discoloration of any layer)

(6) Inverted glove liner

(7) Shrinkage

(8) Loss of elasticity or flexibility

(9) Loss of seam integrity and broken or missing stitches


The Editorial Task Group suggests changing the legislative text to match the tables and maintain consistency between the legislative text and annex for "Inverted glove liner"..



Public Input No. 134-NFPA 1851-2017 [Section No. A.6.2.2] Legislative text related to edits to annex





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Public Input No. 178-NFPA 1851-2017 [ Section No. 6.3.2.1 [Excluding any

Sub-Sections] ]

The ensemble or ensemble element manufacturer or a verified ISP and the organization shall determine thelevel of training required to perform advanced inspections. The ensemble or ensemble elementmanufacturer or verified ISP shall provide written verification of training. The organization shall bere-trained on advanced inspection procedures by either the manufacturer or a verified ISP upon each newrevision of this standard.


There have been several changes since the first Edition of 1851, and significant changes to the next edition are likely. There is, however, no requirement for organizations to receive updated training. This is especially important when considering that this standard is an end user document allowing for organizations to perform cleaning, inspections and basic repairs in-house. It should be required that organizations receive training on the most current edition of this standard and stay abreast of any changes to be able to continue to perform in-house cleaning, inspections and repairs on their PPE.


Submitter Full Name: Tim Tomlinson

Organization: Addison Fire Department

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6.3.5.2


(1) Soiling

(2) Contamination



(5) Thermal damage

(

(a) such as charring, burn holes, melting, or discoloration of any layer

)

(a)

(6) Shrinkage

(7) Loss of material elasticity or stretching out of shape

(8) Loss of seam integrity or broken or missing stitches

(9) Loss of face-opening adjustment

(10)


The Editorial Task Group suggests making these sections consistent with the respective tables in the annex (Thermal damage only).




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* Label integrity and legibility


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6.3.5.2


(1) Soiling

(2) Contamination



(5) Thermal damage (charring, burn holes, melting, discoloration of any layer

(6) Damage to the internal moisture barrier, thermal barrier or other barrier material. (See 6.4 )

(7) Shrinkage

(8) Loss of material elasticity or stretching out of shape

(9) Loss of seam integrity or broken or missing stitches

(10) Loss of face-opening adjustment

(11)


Barrier hoods are not addressed by the current edition. This adds text to address those products



Public Input No. 140-NFPA 1851-2017 [New Section after 3.3.100] Adds Barrier hood text




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6.3.5.4

Glove elements shall be inspected for the following:

(1) Soiling

(2) Contamination

(3)

(4)

(5)

(6)

liner

(a)

(b)

(7) Shrinkage

(8) Loss of flexibility

(9) Loss of elasticity and shape in wristlets

(10) Accessories for compliance with 4.2.3

(11)


The Editorial Task Group suggests changing the legislative text to match the tables and maintain consistency between the legislative text and annex for "Inverted glove liner"



Public Input No. 134-NFPA 1851-2017 [Section No. A.6.2.2] Legislative text related to annex edit




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* Physical damage such as the following:

Rips, tears, and cuts

Thermal damage (charring, burn holes, melting or discoloration of any layer)

Inverted

glove liner

Loss of seam integrity or broken or missing stitches



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6.3.7 Additional Advanced Inspection Criteria for Ensembles with Optional CBRN Liquid and ParticulateContamination Protection.

6.3.7.1*

CBRN Liquid and particulate contamination protective ensembles shall be inspected according to themanufacturer’s instructions.

6.3.7.2

Complete liner inspection of all garment elements shall be conducted at a minimum after 2 years in serviceand annually thereafter or whenever advance inspections indicate that a problem might exist.

6.3.7.3*

CBRN Liquid and particulate contamination protective ensembles shall be inspected for loss of integrity,including but not limited to:

(1) Loss of interface functionality

(2) Excessive material or component shrinkage or stretching









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Complete liner inspection of all garment elements shall be conducted as part of the advanced inspection ata minimum after 3 years in service and every 12 months and annually thereafter or whenever a problemmight exist. The liner system shall be opened to expose all layers for inspection and testing.


The Complete Liner Inspection is a critical method for evaluating the thermal barrier and moisture barrier. It is also relatively easy and quick to perform as part of the Advanced Inspection and has become routine practice requested by fire departments. Since the performance of these two components is critical to the performance of the garment, it is appropriate for the Complete Liner Inspection to become a required part of the Advanced Inspection annually. This will both improve the Advanced Inspection and simplify the inspection interval criteria currently written in the standard.








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6.4.3.1*

A complete liner inspection of all garment elements shall be conducted after 2 years in service andconducted every 12 months and annually thereafter following replacement of the moisture barrier, theCBRN barrier, or both.


The Complete Liner Inspection is a critical method for evaluating the thermal barrier and moisture barrier. It is also relatively easy and quick to perform as part of the Advanced Inspection and has become routine practice requested by fire departments. Since the performance of these two components is critical to the performance of the garment, it is appropriate for the Complete Liner Inspection to become a required part of the Advanced Inspection annually regardless of the component being a replacement. This will both improve the Advanced Inspection and simplify the inspection interval criteria currently written in the standard.



Public Input No. 179-NFPA 1851-2017 [Section No. 6.4.3 [Excluding any Sub-Sections]]





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6.4.3.1*

A complete liner inspection of all garment elements shall be conducted after 2 years in service and annuallythereafter following replacement of the moisture barrier, the CBRN barrier, or both .


This paragraph should be modified as the CBRN option has been removed from NFPA 1971 and there are no certified ensembles that meet these optional requirements.







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7.1 General.

7.1.1 *

Organizations shall provide a means for having ensemble elements cleaned and decontaminated.

7.1.2

Ensembles and ensemble elements shall be evaluated by the wearer for application of appropriatecleaning level after each use.

7.1.3

Ensembles and ensemble elements contaminated by CBRN terrorism agents shall be immediately retiredafter confirmed exposure and shall not be subjected to cleaning or decontamination.

7.1.4 *

Ensembles and ensemble elements that are known or suspected to be contaminated with hazardousmaterials shall be evaluated on the incident scene by members of the organization authorized by theorganization to conduct a preliminary assessment of the extent of contamination and the need forensemble or ensemble elements to be isolated, tagged, and bagged on scene.

7.1.4.1

Contaminated ensembles and ensemble elements shall be isolated during the incident personneldecontamination process and removed from service until the contaminant or suspected contaminant isidentified and the elements can receive specialized cleaning as necessary to remove the specificcontaminant(s).

7.1.4.2 *

Where possible and where the contaminant and its source have been identified, the organization shallconsult the supplier of the contaminant and the manufacturer of the ensemble and ensemble elements foran appropriate decontamination agent and process.

7.1.4.3

A member(s) of the organization who has received training in the cleaning of ensembles and ensembleelements shall be responsible for performing or managing specialized cleaning of elements contaminatedwith hazardous materials.

7.1.5

Ensembles and ensemble elements that are known or suspected to be contaminated with body fluids shallbe evaluated on the incident scene by members of the organization authorized to conduct a preliminaryassessment of the extent of contamination and need for the ensemble or ensemble elements to beisolated, tagged, and bagged at the incident scene.

7.1.6 *

Organizations shall have written procedures detailing the decontamination and cleaning processes forensembles and ensemble elements contaminated with body fluids. Universal precautions shall beobserved at all times by members handling elements known or suspected to be contaminated with bodyfluids.

7.1.7

Soiled or contaminated elements shall not be brought into the home, washed in home laundries, or washedin public laundries unless the public laundry has a dedicated business to handle protective ensembles andensemble elements.

7.1.8 *

Commercial dry cleaning shall not be used as a means of cleaning or decontaminating ensembles andensemble elements unless approved by the ensemble or ensemble element manufacturer.


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7.1.9 *

When a verified ISP is used for cleaning or decontamination, the verified ISP shall demonstrate to theorganization’s satisfaction that the procedures for cleaning and decontamination do not compromise theperformance of ensembles and ensemble elements.

Replace with attached revised section 7.1



Chapter_7_Cleaning_and_Decontamination_Section_7_1_changes.docxComprehensive changes to Section 7.1


The current language provided in A.7.1.1 should be tied to A.7.1.Extensive changes are proposed for this section to reflect work and discussion by the NFPA 1851 task group on cleaning of protective ensembles. The principal change involves defining a decision process by which determinations are made on the handling, potential for cleaning, and disposition of the ensemble and ensemble elements using a hierarchy of cleaning approaches. The recommended changes reflect the incorporation of the new concepts with existing language within NFPA 1851. It is recognized that additional work will be required to more effectively establish specific requirements by which organizations can apply effective cleaning for the removal of soiling and contamination.








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Chapter 7 Cleaning and Decontamination

7.1* General.

7.1.1* Organizations shall provide a means for having ensemble elements cleaned and decontaminated.

7.1.1.1 Organizations shall establish specific capabilities and procedures for cleaning and

decontaminating ensemble elements from soiling and expected contamination. These capabilities shall be

permitted to be provided by one or more verified ISPs.

7.1.1.2 As part of providing a means for having ensemble element cleaned and decontaminated,

organizations shall use the decision tool provided in Figure 7.1.1.2(a) and 7.1.1.2(b).

7.1.1.3 Organizations shall determine their specific limitations for carrying out cleaning and

decontamination of ensemble elements internally and identify a means by which these limitations can be

addressed.

7.1.2 Ensembles and ensemble elements shall be evaluated by the wearer for application of appropriate

cleaning level after each use.

7.1.3 7.1.2.1 Ensembles and ensemble elements contaminated by CBRN terrorism agents shall be

immediately retired after confirmed exposure and shall not be subjected to cleaning or decontamination.

7.1.2.2 Ensembles and ensemble elements that were used in a hazardous materials incident shall be

assessed by qualified member of the Hazardous Materials team or other experts with knowledge about the

specific exposures that took place. The information gained from the Hazardous Materials team or other

experts shall be used to determine if cleaning is possible. If a determination is made that cleaning is

possible, an appropriate form of specialized cleaning shall be applied for removal of contamination from

the affected ensemble elements. If a determination is made that cleaning is not possible, the affected

ensembles and ensemble elements shall be retired and not subjected to cleaning or decontamination.

7.1.4* 7.1.2.3* Ensembles and ensemble elements that are known or suspected to be contaminated with

hazardous materials shall be evaluated on the incident scene by members of the organization authorized

by the organization to conduct a preliminary assessment of the extent of contamination and the need for

ensemble or ensemble elements to be isolated, tagged, and bagged on scene and the type of cleaning or

decontamination that is to be applied as specified in 7.1.3.

7.1.2.4 Ensemble and ensemble elements that are soiled but not contaminated shall be subject on scene

(preliminary cleaning) as specified in Section 7.2.

7.1.3 Where ensembles have been suspected or found to have contamination from bulk chemicals,

asbestos or other designated hazardous materials, body fluids or other forms of biological contamination,

and combustion products or soot, the organization shall follow the follow steps based on Figure 7.1.1.2(a)

and following steps as applied to the specific form of contamination suspected or confirmed to be present.

7.1.4.1 7.1.3.1 Contaminated ensembles and ensemble elements shall be isolated during the incident

personnel decontamination process and removed from service until the contaminant or suspected

contaminant is identified and the elements can receive specialized cleaning as necessary to remove the

specific contaminant(s).

7.1.3.2 If spare ensembles or ensemble elements are not available, the organization shall provide other

forms of clothing to minimize any cross-contamination to the apparatus, other vehicles, station, or other

facilities until any uniform or underlying clothing can be cleaned.

7.1.4.2* 7.1.3.3* Where possible and where the contaminant and its source have been identified, the

organization shall consult the supplier of the contaminant and the manufacturer of the ensemble and

ensemble elements for an appropriate decontamination agent and process.

7.1.4.3 7.1.3.4 A member(s) of the organization who has received training in the cleaning of ensembles

and ensemble elements shall be responsible for performing or managing specialized cleaning of elements

contaminated with hazardous materials.

7.1.3.5 Where ensembles or ensemble elements have been exposed to asbestos or other designated highly

hazardous substances, the exposure shall be evaluated by members of the organization authorized by the

organization to conduct a preliminary assessment of the extent of the contamination and if the exposure

warrants cleaning and reuse of the ensemble. If the determination is made that cleaning and

decontamination can be performed, then the respective ensemble elements shall be subjected to an

appropriate form of specialized cleaning.

7.1.5 7.1.3.6* Ensembles and ensemble elements that are known or suspected to be contaminated with

body fluids or other forms of biological contaminants shall be evaluated on the incident scene by

members of the organization authorized to conduct a preliminary assessment of the extent of

contamination and need for the ensemble or ensemble elements to be isolated, tagged, and bagged at the

incident scene.

7.1.6* 7.1.3.7* Organizations shall have written procedures detailing the decontamination and cleaning

processes for ensembles and ensemble elements contaminated with body fluids or other forms of

biological contaminants. Where used, these processes shall only employ disinfectants or sanitizers that

have are registered and have been properly validated as to the specific claims of disinfection and

sanitization. Selected disinfectants and sanitizers shall not degrade the performance properties of

protective ensemble elements. Any disinfectant used on clothing ensemble elements shall be validated for

its effectiveness as specified in 7.X. Universal precautions shall be observed at all times by members

handling elements known or suspected to be contaminated with body fluids.

7.1.3.8 Ensembles and ensemble elements that have been significantly exposed to combustion products

shall be assumed to be contaminated and shall be subjected to on scene (preliminary) cleaning, isolated,

tagged, and bagged at the incident scene. The exposure shall be evaluated by members of the organization

authorized by the organization to conduct a preliminary assessment of the extent of the contamination and

if the exposure warrant either advanced cleaning or specialized cleaning. If the determination is made that

specialized cleaning is needed, then the respective ensemble elements shall be subjected to an appropriate

form of specialized cleaning.

7.1.7 7.1.4 Soiled or contaminated elements shall not be brought into the home, washed in home

laundries, or washed in public laundries unless the public laundry has a dedicated business to handle

protective ensembles and ensemble elements.

7.1.8* 7.1.5* Commercial dry cleaning shall not be used as a means of cleaning or decontaminating

ensembles and ensemble elements unless approved by the ensemble or ensemble element manufacturer.

7.1.9* 7.1.6* When a verified ISP is used for cleaning or decontamination, the verified ISP shall

demonstrate to the organization’s satisfaction that the procedures for cleaning and decontamination do not

compromise the performance of ensembles and ensemble elements.

Substantiation:

The current language provided in A.7.1.1 should be tied to A.7.1.

Extensive changes are proposed for this section to reflect work and discussion by the NFPA 1851 task

group on cleaning of protective ensembles. The principal change involves defining a decision process by

which determinations are made on the handling, potential for cleaning, and disposition of the ensemble

and ensemble elements using a hierarchy of cleaning approaches. The recommended changes reflect the

incorporation of the new concepts with existing language within NFPA 1851. It is recognized that

additional work will be required to more effectively establish specific requirements by which

organizations can apply effective cleaning for the removal of soiling and contamination.

Figure 7.1.1.2(a) Approach for Deciding Handling, Cleaning and Disposition of Ensemble Elements

Incident/response

CBRN Event?

Contami-nation?

HazMat Incident?

Condemn and dispose of PPE

Have PPE assessed by HazMat team or

other expert(s)

Cleaning Possible?

Soiling?

Apply appropriate Specialized Cleaning

Classify type of contamination

Apply On Scene Cleaning

PPE fit for reuse

Advanced Cleaning

Due?

Apply Advanced Cleaning

See Page 2

Yes

Yes

Yes

Yes

Yes

Yes

No No

No

No

No No

Figure 7.1.1.2(b) Approach for Addressing Specific Types of Contamination

Contamination Suspected

Bulk Chemicals?

Asbestos/ other

subs*?

Body Fluids**?

Combustion products/ soot***?

Condemn and dispose of PPE

Have PPE assessed by HazMat team or

other expert(s)

Cleaning Possible?

Apply appropriate Specialized Cleaning for contaminant type

Apply On Scene Cleaning; isolate and

contain PPE

Isolate and contain PPE


Determine if exposure warrants cleaning and

reuse


Specializedcleaning needed?

Apply Advanced Cleaning

Yes

Yes

Yes

Yes

Yes

Yes

No

No

Conta

min

an

ts s

how

n in r

ela

tive h

iera

rchy o

f exposure

ris

k; m

ultip

le

form

s o

f co

nta

min

ation m

ay a

pply

; cle

an a

ccord

ing t

o h

ighest risk

* And other designated substances; ** Includes other biological contamination; *** Includes any significant structural fire exposure




Add a new section after 7.1.2*

Eye and face protection components that are provided as part of the helmet or as separate devices shall becleaned after each use.

Related Annex:

A.7.1.2 The manufacturer's guidlines for the proper cleaning of protective faceshield, flip-downs orgoggles should be followed. Most manufacturers list specific products that will clean these componentswithout causing damage. For example, repeatedly using ammonia-based window cleaner will eventuallycause fogging that will decrease visibility.


Additional instructions are needed to ensure that fire fighters clean their eye and face protection devices. The annex language provides some factors to be considered in conducting this cleaning.



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7.1.4*

Ensembles and ensemble elements that are known or suspected to be contaminated with hazardousmaterials shall be evaluated on the incident scene by members of the organization authorized by theorganization to conduct a preliminary assessment of the extent of contamination and the need forensemble or ensemble elements to be isolated, tagged, and bagged on scene. This shall include PPEused at a structural fire that cannot be cleaned completely on scene.

7.1.4.1

Contaminated ensembles and ensemble elements shall be isolated during the incident personneldecontamination process and removed from service until the contaminant or suspected contaminant isidentified and the elements can receive specialized cleaning as necessary to remove the specificcontaminant(s).

7.1.4.2*

Where possible and where the contaminant and its source have been identified, the organization shallconsult the supplier of the contaminant and the manufacturer of the ensemble and ensemble elements foran appropriate decontamination agent and process. Special consideration to the chemicals and byproductsof combustion shall be evaluated as these can be as dangerous as a gross exposure on a Hazmat scene.

7.1.4.3 3a

A member(s) of the organization who has received training in the cleaning of ensembles and ensembleelements shall be responsible for performing or managing specialized cleaning of elements contaminatedwith hazardous materials. Proper PPE shall be worn while conducting this decontamination and cleaningPPE disposed of after use if applicable.

7.1.4.3b Protectivie ensembles shall be replaced with clean ensembles as soon as possible. At a minimum,hoods, and gloves should be replaced if immediate return to service is necessary. The contaminated hoodsand gloves will be bagged and sealed while weating latex or equivelant PPE and washed in appropriatewashing machine.


As fire service professionals, we have an inherent duty to reduce risk and the frequency of injury or illness. Therefore, proper cleaning and maintenance of the protective ensembles we rely on will reduce the time we are exposed to an unseen risk, carcinogens from the products of combustion. The changes suggested will help reduce the exposure to substances as well as the time of exposure.

Setting new standards in the care and maintenance of protective ensembles and PPE is the cultural change needed to help the present and future generations of the fire service, and will stand as a memorial to those who have developed cancer(s) before the connection was realized.

Science, technology, research and data analysis should be used in the process of developing the new revisions of NFPA Standard 1851. It also follows with the Firefighter Sixteen Life Safety Initiatives. Data should be collected to evaluate the progress and effectiveness of these changes, as well as plans to corrects negative outcomes. “Formative evaluation is a dynamic process. Even after the injury prevention program has begun, formative evaluation should continue” (Thygerson, 2008, p. 100).

Thygerson, A. L. (2008). Injury Prevention: Competencies for Unintentional Injury Prevention Professionals, 3rd Edition. [Bookshelf Online]. Retrieved from https://online.vitalsource.com/#/books/9781284036404/


Submitter Full Name: William Smith


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Organization: Weisenberg Volunteer Fire Department

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7.1.10 (New) When one element is connected to another element and they are not permanently attachedto each other, individual elements shall be disassembled from each other prior to beginning the cleaningprocess of elements and all disassembled elements shall undergo a separate cleaning process.


For proper and safe cleaning, elements should be separated whenever possible.


Submitter Full Name: Paul Curtis

Organization: L.N. Curtis and sons

Affilliation: L.N. Curtis and sons

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7.1.11 (New) When one element is connected to another element and they are not permanently attachedto each other and are subsequently disassembled from each other prior to beginning the cleaning process,they shall be reassembled prior to any return to service in a like manner to their original manufacturedstate.


Ensures reassembly of elements prior to return to service





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7.2 Routine On Scene (Preliminary) Cleaning.

7.2.1*

The end users shall be responsible for the routine on scene (preliminary) cleaning of their issuedensemble and ensemble elements.

7.2.2

Organizations shall examine the manufacturer’s label and user information for instructions or restrictionsfor on scene or preliminary cleaning and drying that the manufacturer provided with the ensemble orensemble element. In the absence of manufacturer’s instructions or manufacturer’s approval of alternativeprocedures for the ensemble or ensemble element, the routine cleaning and drying on scene (preliminary)cleaning procedures provided in this section shall be used.

7.2.3

Routine Cleaning

Organization shall have their members initiate on scene (preliminary) cleaning as soon as possiblefollowing the incident. Where possible, organizations shall direct their members to conduct on scenecleaning immediately after exiting the emergency area.

7.2.3 On Scene (Preliminary) Cleaning Process.

7.2.3.1*

Where possible, the contamination levels shall be evaluated and cleaning shall be initiated at theemergency scene.

7.2.3.2

Ensembles and element layers shall be isolated whenever possible to avoid cross contamination.

7.2.3.3

Any dry debris shall be brushed off.

7.2.3.4

Other debris shall be gently rinsed off with water. Heavy scrubbing or spraying with high-velocity water jetssuch as a power washer shall not be used.

7.2.3.5

Where necessary, a soft bristle brush shall be used to gently scrub, and the ensemble or element shall berinsed off again.


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Mild detergents with a pH range of not less than 6.0 pH and not greater than 10.5 pH as indicated on theproduct MSDS or original product container shall be used.

Element(s) shall be gently scrubbed using a soft bristle brush.

Element(s) shall be thoroughly rinsed.

Element(s) shall be inspected and, where necessary, shall be rewashed or submitted for advancedcleaning procedures. The manufacturer shall be consulted if stronger cleaning agents are required.

Elements shall be dried in accordance with Section 7.

7.2. 3.6

Where necessary, elements for routine cleaning shall be cleaned in a utility sink designated for personalprotective equipment (PPE) cleaning and decontamination using the following procedures:

4

.

Following the routine cleaning procedure, the utility sink shall be rinsed.

7.2.4 Additional Requirements for Routine On Scene (Preliminary) Cleaning of Garment Elements.

7.2.4.1

Routine cleaning procedures for cleaning garment elements shall be used only for spot cleaning of theelement and shall be performed in a utility sink .

7.2.4.2

To avoid cross contamination, garment element layers shall be isolated whenever possible.

7.2.4.3

Cleaning of the entire garment element shall be accomplished using advanced cleaning procedures.

7.2.5 Additional Requirements for Routine On Scene (Preliminary) Cleaning of Helmet Elements.

7.2.5.1

If it is necessary to totally immerse the helmet, the impact cap shall be separated from the helmet shell.Each element component shall be washed and dried separately before reassembly.

7.2.5.2

Solvents shall not be used to clean or decontaminate helmets or helmet components. The manufacturershall be consulted if stronger cleaning agents are required.

7.2.5.3

Helmets shall not be machine dried using equipment that produces mechanical action from tumbling oragitation.

7.2.6 Additional Requirements for Routine On Scene (Preliminary) Cleaning of Glove Elements.

Glove elements shall not be machine dried using equipment that produces mechanical action from tumblingor agitation.

7.2.7 Additional Requirements for Routine On Scene (Preliminary) Cleaning of Footwear Elements.

Footwear elements shall not be machine dried using equipment that produces mechanical action fromtumbling or agitation.

* Heavily soiled or spotted areas shall be pretreated. Chlorine bleach, chlorinated solvents, active-ingredient cleaning agents, or solvents shall not be used without the ensemble or element manufacturer’sapproval.

* Water temperature shall not exceed 40°C (105°F).

* Protective gloves and eye/face splash protection shall be worn.


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7.2.8 Additional Requirements for Routine On Scene (Preliminary) Cleaning of Proximity Fire FightingEnsembles and Ensemble Elements.

Outer shell and other radiant reflective components of proximity fire fighting protective ensembles andensemble elements shall not be cleaned with a brush or any other abrasive cleaning devices.

7.2.9

Where routine on scene cleaning fails to render the ensemble or ensemble element(s) sufficiently cleanfrom soiling for service, the ensemble or ensemble element(s) shall receive advanced cleaning.


Other proposed changes to NFPA 1851 have modified the hierarchy of cleaning as applied to soiled and contaminated ensemble elements. These proposed changes reflect initial modification of the section to adopt this philosophy. The NFPA 1851 task group on cleaning has determined that utility sink cleaning is of little utility and that routine cleaning should reflect initial cleaning that is performed on scene or as soon as possible practical after the emergency event.







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7.2.3.1*

Where possible, the contamination levels shall be evaluated and cleaning shall be initiated at theemergency scene. For maximum safety for the fire fighter from carcinogens do not turn off scba air orremove masks on leaving the fire scene. Instead proceed immediately into an ANSI # 113 compliantdecontamination shower that has been pre-set up on site. Through the use of copious amounts ofwater/detergents/and light or heavy scrubbing (based on decon protocols) remove as much of the soot andcontaminants as is feasible. Only then exit the shower area and turn off the SCBA air and remove maskand PPE.

Bag and tag all wet but modestly cleaned on scene PPE for proper cleaing and washing back at station.

By use of this procedure the fire fighter is protected, the PPE is rendered neutral, and the fire engine seatsare far cleaner.


The health of the fire fighter would be protected. This standard is great as written in the protection of the fire fighter by ensuring his PPE is cleaned after an incident. BUT fire fighter protection should start immediately on exiting the fire scene and before any PPE is shut off or removed at all. This is accomplished via an immediate decon shower using copious amounts of water, and detergents and scrubbing/washing as may be agreed to by the various PPE manufacturers.


Submitter Full Name: mark conron

Organization: FSI North America

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Submittal Date: Thu Sep 15 15:56:50 EDT 2016


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7.2.3.6


(1)

(2)

(3) Mild detergents with a pH range of not less than 6.0 pH and not greater than 10.5 pH as indicated onthe product MSDS or original product container shall be used.

(4)

(5) Element(s) shall be gently scrubbed using a soft bristle brush.

(6) Element(s) shall be thoroughly rinsed.

(7) Element(s) shall be inspected and, where necessary, shall be rewashed or submitted for advancedcleaning procedures. The manufacturer shall be consulted if stronger cleaning agents are required.

(8) Elements shall be dried in accordance with Section 7.4.

(9) Following the routine cleaning procedure, the utility sink shall be rinsed.


The section does not tell the user what material should be used when pretreating.


Submitter Full Name: James Baker

Organization: Lion

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* Heavily soiled or spotted areas shall be pretreated using a mild detergent or spotting agent .Chlorine bleach, chlorinated solvents, active-ingredient cleaning agents, or solvents shall not be usedwithout the ensemble or element manufacturer’s approval.




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7.2.3.6


(1)

(2)


(4) Universal precautions shall beobserved, as appropriate, when handling ensemble elements.







This statement makes language consistent with other areas of the standard. See 6.1.1



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* Heavily soiled or spotted areas shall be pretreated. Chlorine bleach, chlorinated solvents, active-ingredient cleaning agents, or solvents shall not be used without the ensemble or elementmanufacturer’s approval.




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7.2.3.6


(1)

(2)


(4)







This clarifies what materials should be used when pretreating the element.



Organization: Lion

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* Heavily soiled or spotted areas shall be pretreated with mild detergent or spotting agent . Chlorinebleach, chlorinated solvents, active-ingredient cleaning agents, or solvents shall not be used withoutthe ensemble or element manufacturer’s approval.




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Additional Requirements for Routine Cleaning of Hood Elements

Fire fighter protective hoods shall be washed after every fire or emergency service use.


To keep the same order as Inspection, this new section for hoods should be placed after garment elements (presumably coat and trousers) and before helmet elements.

A Correlating Committee task group led by Bruce Varner drafted a safety alert and seven pages of supporting documentation. Parts of the safety alert are addressed in the standard but cleaning hoods after every fire or emergency service use is not. This addition will tie the standard back to the safety alert, should NFPA determine it should be released. The draft safety alert is included here:

Proposal for NFPA alert notice/ bulletin From the NFPA Project on Fire and Emergency Services Protective Clothing and Equipment.

Fire fighter protective hoods are intended to provide a protective interface between the helmet, SCBA facepiece, and protective coat. Fire fighter protective hoods should be washed and inspected for damage/continued serviceability, per the manufacturer’s instructions, after every fire or emergency service use, as a “best practice”. The face and neck have been identified as a significant area of dermal exposure to products of combustion and potential carcinogens. Fire fighter protective hoods are potential carriers of these products. Washing and inspecting protective hoods after every use may significantly reduce this exposure potential. While this bulletin is specific to fire fighter protective hoods, it is strongly recommended that the entire fire fighting protective ensemble be cleaned and washed after every fire or emergency service use. Organizations should develop procedures to provide for the maximum level of protection of individuals that are involved in fire fighting activities or the handling of post fire protective clothing and equipment. Users may reference NFPA 1851 Standard on Selection, Care, and Maintenance of Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting for additional information. Note: Hoods or any other protective clothing should NEVER be taken home or to a laundromat or dry cleaner for washing.







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This Public input is to assist Departments implementing their own in-house turnout wash /Decon program byoffering a simplistic but effective wash formula.

(1) Load the extractor (any size) ¾ up the sight glass in the front of the washer.

A .An over filled load will stop the extractor from having a good washboard effect.Lighter loads likesingle garments will be too light in the wash wheel to gain a washboard effect.

Next either program your washer / extractor with the following simple formula or find a preprogramed formulaexisting in your extractor formula list that most resembles this formula. * This is a general cleaning formulaand limited to the capabilites of the detergents being used.

(1) fill water level to medium level

(2) Agitate 2 minutes and drain ( this knocks of the large chunks)

(3) Fill water level to Medium

(4) Inject proper amount of detergent ( contact detergent manufacturer for guidance)

6. Wash/ Agitate cycle 12 minutes

(1) Drain

(2) Fill medium

(3) Rinse/agitate for 3 minutes

(4) Drain

(5) Fill Medium


(7) Drain

(8) Fill Medium


(10) Extract 5 minutes at 100 G’s

This simple formula will take care of 80 percent of all your soiled turnouts. For the remaining 20%25 ofTurnouts that are very heavily soiled make a second formula copying this formula with the addition of

Another 12 minute wash cycle.

(1) 4.1 Fill water level to Medium

(2) 5.1 Inject proper amount of detergent ( contact detergent manufacturer for guidance)

(3) 6.1 Wash/ Agitate for 12 minutes

(4) 7.1 Drain

(5) Resume with orrigonal formula above starting with line item 8.


Being a Verified ISP 2 questions I am always asked by a department is , Who makes the best Gear and 2. what is a good wash formula I could use for my gear.I never have a comment on the first question and always comment on the second question using a simple wash formula that is easily understood by 0 knowledge future laundry men and women.


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The above formula is compatible with a single phase detergent of the departments choice with enough rinses to totally flush out the garment and return to service.


Submitter Full Name: Steve Lakey

Organization: Northwest Safety Clean Inc

Affilliation: Verified Independent Service Providers Assn.

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7.3.1.2

The organization, in conjunction with the ensemble or ensemble element manufacturer or with a verifiedISP and the organization , shall determine the level of training required to perform advanced cleaning. Theensemble or ensemble element manufacturer or verified ISP shall provide written verification of training.


The Editorial Task Group suggests rewriting this section so that it is clearer and easier for the end user to interpret – this change does not affect the meaning of the section.




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Change preceding 12 months to preceding 6 months.

Substatiation:The 1st/original 1851 had 2 mandatory cleanings per year. While it is everyones desire tohave the gear cleaned after every use or contamination, that can be a subjective determination that can beaffected by culture, bias, interpretation, or cost. With the increasing awarenenss of carcinogencontamination from the byproducts of fire combustion, it should only make sense to increase the minimumcleaning to once every 6 months.


The 1st/original 1851 had 2 mandatory cleanings per year. While its everyone's desire to have the gear cleaned after every use or contamination, that can be a subjective determination that can be affected by culture, bias, interpretation, or cost. With the increasing awareness of carcinogen contamination from the byproducts of fire combustion, it should only make sense to increase the minimum cleaning to every 6 months.


Submitter Full Name: Jim Reidy

Organization: San Antonio Fire Department

Affilliation: Texas State Association of Firefighters

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Submittal Date: Tue Oct 18 19:29:42 EDT 2016


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7.3.7

The following procedures shall be used for machine washing:

(1)

(2)

(3) All closures, including pocket closures, hooks and loops, snaps, zippers, and hooks and dees shall befastened.

(4)

(5)

(6)

(7)

(8)

(9) The element shall be inspected and rewashed if necessary.

(10)


(6) Regardless if the machine can be adjusted or not, a g force in excess of 100g should not be allowed.new (7) It should be clearly specified that machines with a center post agitator not be used due to the damage this type of machine can inflict.




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* The machine shall not be overloaded.

* Heavily soiled or spotted areas shall be pretreated. Chlorine bleach, chlorinated solvents, active-ingredient cleaning agents, or solvents shall not be used without the ensemble or ensemble elementmanufacturer’s approval.


* A mild detergent with a pH range of not less than 6.0 pH and not greater than 10.5 pH as indicatedon the product MSDS or original product container shall be used.

* Washing machines with the capability of drum RPM adjustment shall be adjusted so the g forcedoes not exceed 100 g for all elements.

Machines with a center post agitator shall not be used.

* Machine manufacturer’s instructions shall be followed for proper setting or program selection for thespecific element being washed.

* Where the machine is also used to wash items other than protective ensemble elements, it shall berinsed out by running the machine without a laundry load through a complete cycle with detergent andfilled to the maximum level with water at a temperature of 49°C to 52°C (120°F to 125°F).


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Public Input No. 25-NFPA 1851-2016 [ New Section after 7.3.9.1 ]

If the garment includes fall protection, and the fall protection is removable, the fall protection shallbe removed prior to laundering. If the fall protection also requires cleaning, it shall be cleanedseparately according to the manufacture's instructions.


Fall protection (for example class 2 harnesses, belts, escape systems) are frequently integrated into NFPA 1971 garments. Cleaning of these items should be addressed in this standard.




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7.3.9.1

If the coat element has a drag rescue device (DRD) and the DRD is removable, the DRD shall be removedprior to the coat being laundered. If the DRD also requires cleaning, it shall be placed in a separate meshbag for washing and drying.


Changing wording to ensure DRD is dealt with as a separate item





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7.3.9.2 (New) Removable DRDs shall be cleaned and placed in a separate mesh bag for washing anddrying.


Reorganizing section to ensure that Removeable DRD's are cleaned and cleaned separately





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7.3.9. 2 5 *

Where the shells and liners of protective garment elements are separable, those items shall be cleaned anddecontaminated only with like items, other than as provided for in 7.3.13.


Renumbering to allow for new 7.3.9.2 proposal





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7.3.9.3 (New) If the coat or pant element has a life safety harnesses, escape belt or ladder belt and theharness or belt is removable, the harness or belt shall be removed prior to the coat or pant being laundered.


Establishing that removable harnesses and belts are separated from coats and pants prior to laundry in order to ensure proper cleaning and eliminate damage to elements.





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7.3.9.3 6

Separable liner systems shall be turned inside out aligned so the moisture barrier is on the inside for bothmachine washing and machine drying.


Renumbering to allow for proposed changes and changing design restrictive language. Not all liner systems have the moisture barrier on the inside or the outside. Using the term inside out does not accomplish the objective to protect the moisture barrier.





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7.3.9.3

Separable liner systems shall be turned inside out so oriented such that the moisture barrier is on theinside for both machine washing and machine drying.


With different types of liner systems available on the market this instruction may be limited to certain types of liner systems. The revised language makes this section more applicable to different systems.




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7.3.94.4 (New) Removable harnesses and belts shall be cleaned separately from coats and pants and inaccordance with the manufacturer's instructions.


Harnesss and belts often utilize hard objects and different fabrics in their construction. In order to protect other elements, they should be cleaned separately.





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7.3.13 Additional Requirements for Advanced Cleaning of Hood Elements.

7.3.13.1 Hoods shall be permitted to be machine washed and machine dried with garment liners.

7.3.13.2 Hoods shall be washed after every fire or emergency service use.


A Correlating Committee task group led by Bruce Varner drafted a safety alert and seven pages of supporting documentation. Parts of the safety alert are addressed in the standard but cleaning hoods after every fire or emergency service use is not. This addition will tie the standard back to the safety alert, should NFPA determine it should be released and appropriately updates the standard if it's not released. The draft safety alert is included here:

Proposal for NFPA alert notice/ bulletin From the NFPA Project on Fire and Emergency Services Protective Clothing and Equipment.

Fire fighter protective hoods are intended to provide a protective interface between the helmet, SCBA facepiece, and protective coat. Fire fighter protective hoods should be washed and inspected for damage/continued serviceability, per the manufacturer’s instructions, after every fire or emergency service use, as a “best practice”. The face and neck have been identified as a significant area of dermal exposure to products of combustion and potential carcinogens. Fire fighter protective hoods are potential carriers of these products. Washing and inspecting protective hoods after every use may significantly reduce this exposure potential. While this bulletin is specific to fire fighter protective hoods, it is strongly recommended that the entire fire fighting protective ensemble be cleaned and washed after every fire or emergency service use. Organizations should develop procedures to provide for the maximum level of protection of individuals that are involved in fire fighting activities or the handling of post fire protective clothing and equipment. Users may reference NFPA 1851 Standard on Selection, Care, and Maintenance of Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting for additional information. Note: Hoods or any other protective clothing should NEVER be taken home or to a laundromat or dry cleaner for washing.



Public Input No. 106-NFPA 1851-2017 [NewSection after 7.2.5]

Both address washing hoods after every fire oremergency service use




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7.3.14.2

Outer shell and other radiant reflective components of proximity fire fighting protective ensembles andensemble elements shall not be machine washed. Outer shell must be hand washed with a soft cloth orsponge.


Further defines the process to instruct on how to wash the outer shell.





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7.3.14.3

Outer shell and other radiant reflective components of proximity fire fighting protective ensembles andensemble elements shall not be machine dried. Outer shell must be hung without any folding of shell andair dried without any mechanical action.


Provides instruction on how to dry the element to minimize damage due to the fragile nature of the reflective components.





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7.3.14.4 (New) If a cleaning device other than a washing machine is utilized, the element manufacturershall be contacted for instructions on how best to clean the element(s).


Eliminates design/process limitation as other cleaning devices are enter the market.





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7.3.15 Additional Requirements for Advanced Cleaning of Ensembles Certified to the Optional CBRNLiquid and Particulate Contamination Requirements of NFPA 1971.

The manufacturer shall be consulted to determine if any special handling procedures or the removal ofinterface components or other components must be undertaken prior to advanced cleaning.









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7.4.2

(3) The area used for drying shall not exceed 105 F.


The standard does not permit water temperatures to exceed 105 F in cleaning. This would keep the standard consistent.



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8.2.3.4

Where moisture barrier tears, holes, or abrasions are being repaired, a single width of seam tape shall be

used and shall be required to extend at least 12.5 mm ( 1 ⁄ 2 in.) in all directions beyond the edge of the

repaired damage. Where the moisture barrier has a hole or abrasion measuring more than 12.5 mm ( 1 ⁄ 2in.) in diameter in any direction or a tear greater than 75 mm (3 in.) in length, a patch consisting of thesame moisture barrier fabric shall be used for repair.


Section 8.4.3 states "all repairs to the garment moisture barrier shall be performed consistent with the moisture barrier manufacturer's method...." Section 8.2.3.4 dictates how the moisture barrier shall be repaired by specifying a single width of tape , or, a patch depending on the size of the repair area. There are other acceptable methods for repairing these areas taught by moisture barrier manufacturers making Section 8.2.3.4 restrictive.


Submitter Full Name: Brian Sullivan

Organization: WL Gore and Associates

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8.2.3.4

Where moisture barrier tears, holes, or abrasions are being repaired, a single width of seam the repairtape shall be used and shall be required to extend at least 12.5 mm ( 1⁄2 in.) in all directions beyond theedge of the repaired damage. Where the moisture barrier has a hole or abrasion measuring more than12.5 mm ( 1⁄2 in.) in diameter in any direction or a tear greater than 75 mm (3 in.) in length, a patchconsisting of the same moisture barrier fabric shall be used for repair.


This requirement is restrictive in that only a single width of seam tape may be used. Multiple widths and multiple pieces of tapes have shown to be effective. It is unclear why a single piece may be used as long as it extends beyond the repaired area sufficiently.


Submitter Full Name: Amanda Newsom

Organization: UL LLC

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8.2.6.1

Visibility markings being replaced shall be completely removed so that no new visibility marking is sewnover an older visibility marking, unless an alternative method is approved by the garment elementmanufacturer .


Recently, new forms of NFPA compliant high visibility trim materials began to be available for use on firefighter garments. These new trims attach directly to the shell fabric without the use of thread or stitching, as has been the historic norm. To determine if any changes are in order for the 1851 document as a result of these technology changes that do not use stitching as their attachment mode, the drafting committee's consideration of the element repair sections of NFPA 1851 pertaining to high visibility material is respectfully requested. Relevant repair sections include 8.2.6, 8.2.6.1, 8.2.6.2, 8.2.6.3, 8.2.6.4, and 8.2.6.5 in Chapter 8.2: "Requirements for Both Basic and Advanced Garment Element Repair." Also in consideration is section 4.4 "Manufacturer's Instructions," which seems to create a forceful exception to strict adherence to NFPA 1851, when warranted and directed by the manufacturer.

Here is a possible direction. The proposed addition to the text of section 8.2.6.1 copies the last clause from section 8.2.6, and appends it to the end of the sentence in section 8.2.6.1, referring to visibility markings repair and sewing. This by itself, coupled with the other existing passages, would probably give explicit flexibility to address repair scenarios for new trim forms, under the direction of the garment manufacturers. It is presumed that committee discussion on this topic will determine if this or some alternate adjustment to these or other sections is the proper course to address the issue.


Submitter Full Name: Tim Gardner

Organization: 3m Company

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Submittal Date: Tue Dec 13 17:22:47 EST 2016


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8.4.4*

Repairs to garment thermal liners shall be permitted provided there is no the repair does not result in anystitching through the moisture barrier.


The Editorial Task Group feels that the current legislative text could be interpreted to mean that stitching through the moisture barrier occurred before the repair and was the determining factor. This edit makes the sentence clearer and leaves less room for misinterpretation.




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8.8 Structural Fire Fighting Hood and Proximity Fire Fighting Helmet Overcover and Proximity Fire FightingShroud Repair.

In addition to the requirements in Section 8.1, all repairs to hoods, helmet covers, and proximity shroudsshall be performed in accordance with the element manufacturers’ instructions. Repairs of these interfacecomponents or other components shall not be undertaken unless authorized by the manufacturer.


Some manufacturers may not provide instructions for the repair of their items and without a specific prohibition on authorized repairs, the proposed language would ensure that these items are not improperly repaired.




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8.9 Additional Requirements for Structural Fire Fighting Ensembles and Proximity Fire Fighting Ensembleswith Optional CBRN Liquid and Particulate Contamination Protection.

In addition to the requirements in Section 8.1, all repairs to ensembles with optional CBRN liquid andparticulate contamination protection shall be referred to the ensemble manufacturer.









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9.1.1*

Ensembles or ensemble elements shall not be stored in under fluorescent light, in direct sunlight orexposed to direct sunlight while not being worn.


The fluorescent lighting storage restriction should be a mandatory requirement versus simply mentioned in the annex. Damage to materials is occurring under this lighting type and should be restricted.




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Add new section after 9.1.9

Eye and face protection shall be readily accessible to the user and, when not in use, stored in a protectivearea that prevents at least the following:

-thermal damage

-mechanical damage

hazardous materials contamination


The current eye and face protective components are inconsistent with the level of protection provided and their application subjects them to unnecessary damage (thermal and mechanical) as well as hazardous particulate contamination. Users must be instructed on the proper way to clean and decontaminate the eye and face protection without causing damage to these components.



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10.1.2*

Structural fire fighting ensembles and ensemble elements shall be retired in accordance with 10.2.1 or10.2.2, no more than 10 years from the date the ensembles or ensemble elements weremanufactured when the ensemble or ensemble element no longer passes a regular inspection permanufactor standards for servicability .


Limiting the use to 10 years for turnout clothing, helmets or other elements of a structural ensemble is one of the most egregious examples of the disregard of NFPA to the operations of the rural fire service. With a full ensemble costing two to five thousand dollars, imposing a ten year limit with no scientific support for the limitation is a financial burden the fire service is unable to bear. In an urban environment the ensemble will likely not last ten years, but in a rural environment where a volunteer responds to a very limited number of fire or rescue incident annually the ensemble can be in near new condition at the ten year mark if it is well cared for. Annually a disproportionate amount of the Assistance to Firefighter grant funds are directed to this single requirement, diverting critical dollars from other life saving equipment. Our firefighters deserve good safe gear, but to require replacement of gear that is in excellent condition simply because of a date on the tag is an insult to the taxpayers that fund our efforts. In a state that requires us to conform to this Standard, it is a disservice to our citizens.


Submitter Full Name: Warren Peterson

Organization: East Olympia Fire Dist 6

Affilliation: Fire Chief

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Sections 10.1.2, 10.1.3

10.1.2*

Structural fire fighting ensembles and ensemble elements shall be retired in accordance with 10.2.1 or10.2.2, no more than 10 years from the date the ensembles or ensemble elements were manufactured.

We can not hold FDNY and a 10 member rural volunteer fire department to the same standard . Doing sois going to force them into non-compliance.

This is to strengent, our local volunteer departments are struggling to supply the basic needs for entry levelfirefigters.

10. 1.3

Proximity fire fighting ensembles and ensemble elements shall be retired in accordance with 10.2.1 or10.2.2, no more than 10 years from the date the ensembles or ensemble elements were manufactured.

10.1.3.1*

In all cases, the radiant reflective outer shell shall be replaced at a maximum of 5 years.


Alleviate burdens on local rural volunteer departments that may not even respond to less than 10 structure fire a year.


Submitter Full Name: Gene Ball

Organization: Orangeburg Co Fire Dist

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10.1.3.1*

In all cases, the radiant reflective outer shell of tghe garment element shall be replaced at a maximum of 5years no more than 5 years from the date the ensembles or ensemble elements were manufacturerd .


The Editorial Task Group would like to make this section clearer and consistent with section 10.1.3.




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10.1.3.1*

In all cases, the radiant reflective outer shell shall be replaced at a maximum of 5 10 years.


The five year retirement date is a number based on the fact that the radiant layer is fragile. In most cases proximity garments are not worn on a everyday basis and many times only a few times a year. Since the shells are fragile many fire group have stored back-up garments. Currently these back-up garments are being retired prior to being used. If we extend the life to 10 years these back-up garments will be used not destroyed.


Submitter Full Name: Harry Winer

Organization: HIP Consulting LLC

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10.1.4*

Structural fire fighting ensembles and ensemble elements and proximity fire fighting ensembles andensemble elements that are worn or damaged to the extent that the organization deems it not possible orcost effective to repair them shall be retired in accordance with 10.2.1.


The Editorial Task Group feels the section is easier to read without “them” and removing “them” does not change the meaning of the section.




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10.2.2

Retired structural fire fighting ensembles and ensemble elements and proximity fire fighting ensembles andensemble elements as determined to be no longer of use in accordance with 10.1.8 shall be permitted tobe used as follows:

(1) For training that does not involve live fire, provided the ensembles and ensemble elements areappropriately marked as being for non–live fire training only

(2) As determined by the organization


The Editorial Task Group suggests this edit to make the section more understandable.




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11.1.1.1

Verification of the organization or ISP shall include advanced inspection, advanced cleaning, and advancedrepairs of garment elements only. Verification of the organization or ISP shall not apply to helmet elements,glove elements, footwear elements, hood elements, or optional CBRN liquid and particulate contaminationprotective ensembles.









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11.1.1.2

An organization or ISP shall not be permitted to be verified for advanced cleaning and advanced inspectiononly. The organization must be verified for advanced cleaning, advanced inspection and repairs.


There are many ISPs that have verified to just the advanced cleaning and advanced inspection. They do not make it clear to the fire departments that they only can clean and inspect their elements and have not be tested to do repairs. This creates a great deal of confusion in the industry.



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11.1.1.4

The verified organization or ISP shall be listed. The listing shall contain advanced cleaning and advancedinspection; or advanced cleaning , advanced inspection, and /or the repair categories that the organizationor the ISP is verified to conduct. Repair categories shall be garment outer shell repairs, garment moisturebarrier repairs, and garment thermal barrier repairs.


Editorial. This removes the term "and/or" and clarifies the options for listing the ISPs. This makes 11.1.1.4 consistent with 11.1.1.1 through 11.1.1.3.




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11.1.1.5

Where the certification listing includes the moisture barrier repair category, the listing shall include themoisture barrier manufacturer and , trade name designation, and seam tape part number(s) .


Clarification is needed when multiple tapes are allowed on the same barrier.


Submitter Full Name: Jason Allen

Organization: Intertek Testing Services

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11.1.1.5

Where the certification listing includes the moisture barrier repair category, the listing shall include themoisture barrier and repair tape manufacturer and trade name designation.


Multiple tape materials may be used by the industry for the same moisture barrier. This clarifies the listing and also reflects current practice.




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11.1.2

All verification of the organization or ISP shall be performed by a certification organization that meets atleast the requirements specified in Section 11.2 and that is accredited for personal protective equipment(PPE) in accordance with ISO Guide 65, General requirements for bodies operating product certificationsystems /IEC 17065, Conformity assessment - Requirements for bodies certifying products, processes andservices . The accreditation shall be issued by an accreditation body operating in accordance with ISO17011, Conformity assessment — General requirements for accreditation bodies accrediting conformityassessment bodies.


ISO Guide 65 was replaced with ISO/IEC 17065.




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11.1.5

Organizations or ISPs verified to the 2008 2014 edition of NFPA 1851 shall undergo verification to the2014 2019 edition of NFPA 1851 within 6 months of the NFPA effective date for the 2014 edition, which isAugust 21, 2013 2019 edition .


The Editorial Task Group suggests that all similar references be updated to the correct versions




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11.2.3

The certification organization shall be accredited for personal protective equipment in accordance with ISOGuide 65, General requirements for bodies operating product certification systems /IEC 17065, Conformityassessment - Requirements for bodies certifying products, processes and services . The accreditation shallbe issued by an accreditation body operating in accordance with ISO 17011, Conformity assessment —General requirements for accreditation bodies accrediting conformity assessment bodies.


ISO Guide 65 has been replaced by ISO/IEC 17065




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11.2.13

The certification organization shall be permitted to conduct additional specific testing to verify continuedcompliance.


This clarifies that this paragraph refers to testing that is above and beyond the testing requirements for re-verification.




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Sections 11.3.7, 11.3.8

11.3.7

For verification of an organization’s or an ISP’s advanced cleaning services, the certification organizationshall evaluate the organization’s or ISP’s procedures in accordance with Section 7.3 of this standard.

11.3.8

For verification of an organization’s or an ISP’s advanced inspection services, the certification organizationshall evaluate the organization’s or ISP’s procedures in accordance with Sections 6.3 and 6.4 of thisstandard.


These requirements seem to be the same as or redundant to 11.3.10 and 11.3.11.




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11.3.9.x For moisture barrier pinhole repairs, the certification organization shall create pinholes in thematerial(s) by using a size 8 gauge sewing needle, puncturing the moisture barrier surface five times in a 1"area, located in the center of a 12" x 12" sample.

Modify Table 11.3.9(c) as per attachment



NFPA_1851-_Table_11.3.9.c_revision.xlsx modifications to Table 11.3.9 (c)


Based on moisture barrier warranty data, over 90% of claims are for pinhole leaks. Currently there is no test method to evaluate repair of pinholes. This comment presents a method of preparing a sample with pinhole damage and a method to evaluate the durability of the repair by using existing hydrostatic testing (NFPA 1851-12.3) after 5 wash dry cycles (NFPA 1971-8.1.2). For consistency of test methodology, the test methods for a hole patch and tear patch were also modified to reflect this test methodology.


Submitter Full Name: Holly Blake

Organization: WL Gore

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Table 11.3.9 ( c )

Bolded and underlined text is new

Who Makes Repair Sample Material Test

Organization5 ft seam

Maoisture barrier material(s) utilized

by the organizationNFPA 1971-7.1.13

Hole Patch

Patched hole made from the

moisture barrier material(s) utilized

by the organization

NFPA 1851-8.2.3 and

NFPA 1971 - 7.1.15 in

the as-received

condition NFPA 1851-

12.3 in as-received

and after

preconditioning in

NFPA 1971-8.1.2

Tear Patch

Patched tear made from the


by the organization

NFPA 1851-8.2.3 and

NFPA 1971 - 7.1.15 in

the as-received


12.3 in as-received

and after

preconditioning in

NFPA 1971-8.1.2

Pinhole repair

Pinhole repair made from the


by the organization

NFPA 1851-8.2.3 and

NFPA 1971 - 7.1.15 in

the as-received


12.3 in as-received

and after

preconditioning in

NFPA 1971-8.1.2

ISP5 ft seam

Maoisture barrier material(s)

repaired by the ISPNFPA 1971-7.1.13

Hole Patch

Patched hole made from the

moisture barrier material(s) repaired

by the ISP

NFPA 1851-8.2.3 and

NFPA 1971 - 7.1.15 in

the as-received


12.3 in as-received

and after

preconditioning in

NFPA 1971-8.1.2

Tear Patch

Patched tear made from the

moisture barrier material(s) repaired

by the ISP

NFPA 1851-8.2.3 and

NFPA 1971 - 7.1.15 in

the as-received


12.3 in as-received

and after

preconditioning in

NFPA 1971-8.1.2

Pinhole repair

Pinhole repair made from the

moisture barrier material(s)

repaired by the ISP

NFPA 1851-8.2.3 and

NFPA 1971 - 7.1.15 in

the as-received


12.3 in as-received

and after

preconditioning in

NFPA 1971-8.1.2

Public Input No. 130-NFPA 1851-2017 [ Section No. 11.3.9 [Excluding any Sub-Sections]

]


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For verification of an organization’s or an ISP’s repair services, the following series of tests shall berequired for each repair category for which the organization or the ISP is verified. Testing shall beconducted using new materials as outlined in Table 11.3.9(a) through Table 11.3.9(c).

Table 11.3.9(a) Outer Shell Repairs

Who MakesRepair

Sample Material Test

Organization

5 ft felled seam

5 ft overedgeseam

Outer shell material(s) utilized by the organizationNFPA 1971 —7.1.13

Small tearpatch

Patched tear made from the outer shell materialutilized by the organization

NFPA 1851 —8.2.3

ISP

5 ft felled seam

5 ft overedgeseam

7.5 osy Nomex IIIa plain weave fabricNFPA 1971 —7.1.13

Small tearpatch

Patched tear made from 7.5 osy Nomex IIIa plainweave fabric

NFPA 1851 —8.2.3

Table 11.3.9(b) Thermal Liner Repairs

Who MakesRepair


Organization

5 ft felledseam

5 ft overedgeseam

Thermal liner material(s) utilized by the organizationNFPA 1971 —7.1.13

Small tearpatch

Patched tear made from the thermal liner materialutilized by the organization

NFPA 1851 —8.2.3

ISP

5 ft felledseam

5 ft overedgeseam

Blended filament/spun face cloth quilted to two layersof E89

NFPA 1971 —7.1.13

Small tearpatch

Patched tear made from blended filament/spun facecloth quilted to two layers of E89

NFPA 1851 —8.2.3

Table 11.3.9(c) Moisture Barrier Repairs

Who MakesRepair


Organization 5 ft seamMoisture barrier material(s) utilized by theorganization

NFPA 1971 — 7.1.13

Holepatch

Patched hole made from the moisturebarrier material(s) utilized by theorganization

NFPA 1851 — 8.2.3 and NFPA 1971— 7.1.15 in the as-received condition

Tearpatch

Patched tear made from the moisturebarrier material(s) utilized by theorganization


ISP 5 ft seamAll moisture barrier materials repaired bythe ISP

NFPA 1971 — 7.1.13

Holepatch

Patched hole made from the moisturebarrier materials repaired by the ISP


Tearpatch





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The Editorial Task Group suggests updating the 1971 section references for the latest edition listed in these three tables.




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Public Input No. 182-NFPA 1851-2017 [ Section No. 11.3.9 [Excluding any Sub-Sections]

]


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For verification of an organization’s or an ISP’s repair services, the following series of tests shall be requiredfor each repair category for which the organization or the ISP is verified. Testing shall be conducted usingnew materials as outlined in Table 11.3.9(a) through Table 11.3.9(c). Initial samples submitted by theorganization or ISP for verification must be prepared by that organization.


Who MakesRepair


Organization

5 ft felled seam

5 ft overedgeseam


Small tearpatch


NFPA 1851 —8.2.3

ISP

5 ft felled seam

5 ft overedgeseam


Small tearpatch


NFPA 1851 —8.2.3


Who MakesRepair


Organization

5 ft felledseam

5 ft overedgeseam


Small tearpatch


NFPA 1851 —8.2.3

ISP

5 ft felledseam

5 ft overedgeseam


NFPA 1971 —7.1.13

Small tearpatch


NFPA 1851 —8.2.3


Who MakesRepair


Organization 5 ft seamMoisture barrier material(s) utilized bythe organization

NFPA 1971 — 7.1.13

Holepatch


NFPA 1851 — 8.2.3 and NFPA 1971— 7.1.15 in the as-receivedcondition

Tearpatch




NFPA 1971 — 7.1.13

Holepatch



Tearpatch


NFPA 1851 — 8.2.3 and NFPA 1971— 7.1.15 in the as-received


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Who MakesRepair


condition


Currently it has been the practice of some verified organizations and/or ISP’s to purchase pre-made seam kits and submitting those as if they are an original submittal of verification samples. The ability to create the seams required for submittal for verification should be considered as valuable a part of the verification process as performing the required repairs. ISP’s, even though considered “repair” facilities many times perform major repairs larger than what would be considered small patches. The ability to purchase pre-made seams kits does not provide confidence that the ISP or verified organization has the skill, knowledge or ability to perform to the scope which is portrayed not only to the industry but the fire service and violates the intent of the committee.



Public Input No. 184-NFPA 1851-2017 [Sections 11.3.9.1, 11.3.9.2]


Public Input No. 187-NFPA 1851-2017 [Section No. 11.3.9.3 [Excluding any Sub-Sections]]




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For verification of an organization’s or an ISP’s repair services, the following series of tests shall be requiredfor each repair category for which the organization or the ISP is verified. Testing shall be conducted usingnew materials as outlined in Table 11.3.9(a) through Table 11.3.9(c).


Who MakesRepair

Sample MaterialTest or

Evaluation

Organization

5 ft felled seam

5 ft overedgeseam


Small tearpatch


NFPA 1851 —8.2.3

ISP

5 ft felled seam

5 ft overedgeseam


Small tearpatch


NFPA 1851 —8.2.3


Who MakesRepair

Sample MaterialTest or

Evaluation

Organization

5 ft felledseam

5 ft overedgeseam


Small tearpatch


NFPA 1851 —8.2.3

ISP

5 ft felledseam

5 ft overedgeseam


NFPA 1971 —7.1.13

Small tearpatch


NFPA 1851 —8.2.3


Who MakesRepair

Sample Material Test or Evaluation

Organization 5 ft seamMoisture barrier material(s) utilized bythe organization

NFPA 1971 — 7.1.13

Holepatch



Tearpatch




NFPA 1971 — 7.1.13

Holepatch



Tearpatch





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This clarifies that the requirement for 8.2.3 is an evaluation and not a test to be performed.




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11.3.9.1

For repairs to tears in the outer shell, moisture barrier, and thermal barrier, the certification organizationshall create the tear in the material(s) to be repaired in accordance with Figure 11.3.9.1. Repairsperformed by the organization being verified must be completed onsite at the organization ’ s facility andwitnessed by the certifying organization. Figure 11.3.9.1 Tear Repairs.


Currently there are two different verification practices by certification laboratories. One, which perform an onsite damaging of seams and then witnessing of the repairs, and a second, which performs damaging of samples remotely and allows for the organization requesting verification perform the repairs un-witnessed at the organizations locations. It is my recommendation that the damaging and repair of all samples is performed onsite at the location being verified and is witnessed by the certifying organizations qualified representative. This would provide for consistency among verifying organizations and also provide the confidence expected by the fire service that the verification of an organization or ISP truly represents the requirements stated in this standard.










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Sections 11.3.9.1, 11.3.9.2

11.3.9.1

For repairs to tears in the outer shell, moisture barrier, and thermal barrier, the certification organizationshall create the tear in the material(s) to be repaired in accordance with Figure 11.3.9.1. Repairsperformed by the organization being verified must be completed onsite at the organization ’ s facility andwitnessed by the certifying organization. Figure 11.3.9.1 Tear Repairs.


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11.3.9.2

For moisture barrier hole repairs, the certification organization shall create the hole in the material(s) to berepaired in accordance with Figure 11.3.9.2.

Figure 11.3.9.2 Hole Repairs.


Currently there are two different verification practices by certification laboratories. One practice is onsite. Where the seam is damaged and the certifying organization witnesses the repairs on-site. The second practice is remote. In this case the verification organization does not witness the damage or the repair. It is my recommendation that the damaging and repair of all samples is performed onsite at the location being verified and is witnessed by the certifying organization’s qualified representative. This would provide for consistency among verifying organizations and also provide the confidence expected by the fire service that the verification of an organization or ISP truly represents the requirements stated in this standard.









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Sections 11.3.9.1, 11.3.9.2

11.3.9.1

For repairs to tears in the outer shell, moisture barrier, and thermal barrier, the certification organizationshall create inspect the tear in the material(s) to be repaired in accordance with Figure 11.3.9.1 and shallwitness the repair of the samples to be tested .

Figure 11.3.9.1 Tear Repairs.


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11.3.9.2

For moisture barrier hole repairs, the certification organization shall create inspect the hole in thematerial(s) to be repaired in accordance with Figure 11.3.9.2 2 and shall witness the repair of thesamples to be tested .



The proposed changes will lead to the traceability of the repaired samples and ensure that the repairs comply with the manufacturers documentation. Additionally, instead of the Certification Organization actually making the damage, the CO is inspecting the damage and witnessing the actual repair.




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Delete 11.3.9.2 section and associated figure (figure 11.3.9. 2 . Hole Repair)

Also remove references to hole patch in Table 11.3.9(c) for both the organization and ISP

11.3.9.2

For moisture barrier hole repairs, the certification organization shall create the hole in the material(s) to berepaired in accordance with Figure 11.3.9.2.



Based on several years of moisture barrier warranty claims,holes that are 1" in diameter are infrequently encountered. Other more common repair causes, e.g. pinholes, are seen but there is no test method to verify they can be adequately repaired.


Submitter Full Name: Holly Blake

Organization: WL Gore

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Sub-Sections] ]

Sample seams shall be prepared and submitted to the certification organization for verification testing by anNFPA 1971, Standard on Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting,certified manufacturer, verified organization, or verified ISP. Initial sample seams submitted for verificationby a certified manufacturer, verified organization, or verified ISP shall be prepared by the organization beingverified for repairs.


Currently is has been the practice of some verified organizations and/or ISP’s to purchase pre-made seam kits already for original submittal of verification samples. The ability to create the seams required for submittal for verification should be considered as much of a valuable part to the verification process as performing the required repairs. ISP’s, even though considered “repair” facilities many times perform major repairs larger than what would be considered small patches. The ability to purchase pre-made seams kits does not provide confidence that the ISP or verified organization has the skill, knowledge or ability to perform to the scope which is portrayed not only to the industry but the fire service.









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Public Input No. 104-NFPA 1851-2017 [ Section No. 11.3.9.3.1 ]

11.3.9.3.1

Where a verified organization or verified ISP performs repairs for more than one manufacturer, then onlyone set of seam samples shall be required for verification testing of Outer Shells or Thermal Liners .


Clarification is needed that this statement doesnt apply to moisture barriers which require different handling and procedures for repair from manufacturer to manufacture and even amongst different models within the same manufacturer


Submitter Full Name: Jason Allen

Organization: Intertek Testing Services

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11.3.9.3.1

Where a verified organization or verified ISP performs repairs for more than one garment manufacturer,then only one set of seam samples shall be required for verification testing.


This clarifies that the requirement applies to the multiple garment manufacturers and not the moisture barrier fabric manufacturers.




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Public Input No. 36-NFPA 1851-2016 [ Sections 11.3.9.3.2, 11.3.9.3.3 ]

Sections 11.3.9.3.2, 11.3.9.3.3

11.3.9.3.2

For moisture barrier seam repairs, the certification organization ISP shall damage the sample seams bycutting multiple stitches and the seam tape to a distance of 75 mm (3 in.) +12.5 mm/-0.00 mm (+ 1⁄2in./-0 in.). The certification organization shall inspect the damaged seams and witness the repair of thesamples to be tested.

11.3.9.3.3

For outer shell and thermal barrier seam repairs, the certification organization ISP shall damage thesample seams by cutting multiple stitches to a distance of 75 mm (3 in.) +12.5 mm/-0.00 mm (+ 1⁄2in./-0 in.). The certification organization shall inspect the damaged seams and witness the repair of thesamples to be tested.


The proposed changes will lead to the traceability of the repaired samples and ensure that the repairs comply with the manufacturers documentation. Additionally, instead of the Certification Organization actually making the damage, the CO is inspecting the damage and witnessing the actual repair.




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Sections 11.3.10, 11.3.11

11.3.10

For verification of an organization’s or ISP’s advanced inspection services, the documentation andmeasurements specified in Table 11.3.10 shall be evaluated and verified to be compliant by thecertification organization.

Table 11.3.10 Advanced Inspection Evaluation

NFPA 1851 Clause

to be Evaluated

Method of

Evaluation

6.3.2 Audit or review of organization’s or ISP’s procedures and documentation bycertification organization


6.3.5.1 (1)–(4) and(6)–(15)

Audit or review of organization’s or ISP’s procedures and documentation bycertification organization

6.3.5.7 Audit or review of organization’s or ISP’s procedures and documentation bycertification organization

6.3.6.1 Audit or review of organization’s or ISP’s procedures and documentation bycertification organization





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11.3.11

For verification of an organization’s or ISP’s advanced cleaning services, the documentation andmeasurements specified in Table 11.3.11 shall be evaluated and verified to be compliant by thecertification organization.

Table 11.3.11 Advanced Cleaning Evaluation

NFPA 1851 Clause

to be Evaluated

Method of

Evaluation




7.3.7 (1)–(3) and(5)–(9)


7.3.7(4) Direct measurement or observation by a representative of the certificationorganization





7.4.3 (1)–(3) and(5)–(6)


7.4.3(4) Direct measurement or observation by a representative of the certificationorganization


The Editorial Task Group suggests adding a placeholder to make sure all referenced 1851 sections ("clauses") are verified and updated before the final draft.




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12.1 Light Evaluation of Liners.

12.1.1 * Application.

This evaluation method shall apply to liner composites found in structural and proximity fire fightingprotective garment elements that are in service.

12.1.2 Evaluation Areas.

12.1.2.1

At a minimum, the front and back body panels of each protective garment element shall be evaluated.

12.1.2.1.1

Specific areas of the body panels that shall be evaluated include the upper back, shoulders, underarms,sleeves, waist area, and crotch area.

12.1.2.1.2

Liner evaluation areas shall also be any areas of the garment where damage or loss of thermal protectionis detected or expected.

12.1.3 Evaluation Apparatus.

The apparatus used to perform the light evaluation shall have the following characteristics:

(1) The apparatus shall consist of a light source that provides enough light to show the changes indensity of the liner materials when viewed.

(2) The light source shall not produce enough heat to damage the liner composite.

(3) The light source shall be configured to prevent the bulbs from directly contacting the linercomposite.

(4) The light source shall be appropriately sized to fit into the sleeves of the liner.

12.1.4 Procedure.

12.1.4.1

The evaluation procedure shall be performed at room temperature.

12.1.4.2

The evaluation shall be conducted using the following procedure:

(1) If possible, separate the liner from the outer shell.

(2) Orient the liner so that the thermal barrier is on the outside.

(3) Position the light source near the moisture barrier so that the light passes through the moisturebarrier and then through the thermal barrier.

(4) Evaluate the liner by examining the amount of light coming through the thermal liner.

12.1.5 Results.

12.1.5.1

Results shall be determined by evaluating areas where the light is brighter through some areas thanothers.

12.1.5.2

Brighter areas could be an indication of insulating material shifting or migrating, resulting in a thin or barespot.


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12.1.5.3

To further evaluate a suspected area of shifting or migration, a complete liner inspection shall beperformed.


The recommendation of the public input is to remove the Light Test from the standard. The Light Test was originally included in the Standard to provide an easy method of evaluating the thermal barrier without opening the liner assembly. At the time, the rationale was sound. Now, however, after several years of experience with NFPA1851, I believe we have learned the Light Test is neither easy to conduct or as effective as opening the liner up and visually inspecting all layers for possible issues. The inclusion of this test in the Standard, along with the Complete Liner Inspection, also adds confusion to the inspection process.

The Complete Liner Inspection is clearly the more effective method for evaluating the thermal barrier. It is also relatively easy and quick to perform. Since the performance of the thermal barrier is critical to the performance of the garment, it is appropriate for the Complete Liner Inspection to become a required part of the Advanced Inspection. This will both improve the Advanced Inspection and simplify the inspection criteria.




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12.1.2.1


12.1.2.1.1


12.1.2.1.2

Liner evaluation areas shall also be any areas of the garment where damage or loss of thermal protectionis detected or expected.



(1) The apparatus shall consist of a light source that provides enough light to show the changes indensity of the liner materials when viewed.


(3) The light source shall be configured to prevent the bulbs from directly contacting the linercomposite.


12.1.4 Procedure.

12.1.4.1


12.1.4.2




(3) Position the light source near the moisture barrier so that the light passes through the moisturebarrier and then through the thermal barrier.


12.1.5 Results.

12.1.5.1

Results shall be determined by evaluating areas where the light is brighter through some areas thanothers.

12.1.5.2



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12.1.5.3

To further evaluate a suspected area of shifting or migration, a complete liner inspection shall beperformed.


The light test was initially placed in the standard because there was no way at that time for performing a liner inspection. At that time the only other way to inspect the inside of a liner was with a patented liner viewing port. The committee went with the light test since there were no options at that time. The previous patents have expired and viewing ports are very common today. The light test is also very subjective in nature and with some new lining systems can not be performed. The fire fighter doesn't know that the light test can not performed on certain systems which could lead to a dangerous situation. my recommendation is to replace the light test with a total inspection of the inner portion of the lining system.


Submitter Full Name: Harry Winer

Organization: HIP Consulting LLC

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12.1.1* Application.



12.1.2.1


12.1.2.1.1


12.1.2.1.2

Liner evaluation areas shall also be any areas of the garment where damage or loss of thermal protection isdetected or expected.



(1) The apparatus shall consist of a light source that provides enough light to show the changes in densityof the liner materials when viewed.


(3) The light source shall be configured to prevent the bulbs from directly contacting the liner composite.


12.1.4 Procedure.

12.1.4.1


12.1.4.2




(3) Position the light source near the moisture barrier so that the light passes through the moisture barrierand then through the thermal barrier.


12.1.5 Results.

12.1.5.1

Results shall be determined by evaluating areas where the light is brighter through some areas than others.

12.1.5.2



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12.1.5.3

To further evaluate a suspected area of shifting or migration, a complete liner inspection shall be performed.


It is not clear whether this inspection method is sufficient for evaluating the Gore-tex Parallon orother possible concepts.


It is not clear whether this inspection method is sufficient for evaluating the Gore-tex Parallon or other possible concepts.


Submitter Full Name: Michael Salvato

Organization: STEDFAST

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Submittal Date: Sun Jan 01 09:51:08 EST 2017


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12.2 Leakage Evaluation.


This evaluation method shall apply to moisture and thermal barrier liners found in structural or proximity firefighting protective garment elements that are in service.


12.2.2.1

At a minimum, the front and back body panels of each protective garment element shall be evaluatedusing three different moisture barrier material areas and three different moisture barrier areas with a seam.

12.2.2.1.1

Liner evaluation areas shall be from high-abrasion areas of the garment elements, including, but not limitedto:

(1) Broadest part of the shoulders

(2) Back waist area of the coat

(3) Knees

(4) Crotch area

(5) Seat area

12.2.2.1.2

In addition to the areas listed in 12.2.2.1.1 where potential damage to the garment outer shell or thermalbarrier has been detected, the evaluation shall be conducted on the corresponding area of the moisturebarrier. Where potential damage to the garment moisture barrier has been detected, the evaluation shallalso be conducted on that area.

12.2.2.2

The liner composite shall be positioned in the evaluation apparatus so that the moisture barrier is orientedupward and is contacted with the liquid exposure in the evaluation apparatus.

12.2.2.3

Moisture barrier material areas with seams shall be positioned on the evaluation apparatus so that theseam divides the specimen into two equal halves.


12.2.3.1 *

An alcohol–tap water mixture shall be made by combining 1 part rubbing alcohol (70 percent isopropanolalcohol) with 6 parts tap water.

12.2.3.2

A 5 gal bucket or similar container shall be used to support the liner during evaluation.

12.2.4 Procedure.

12.2.4.1



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12.2.4.2



(2) Orient the liner so that the moisture barrier is on the outside.

(3) Position the dry liner over the bucket with the thermal barrier facing down and the moisture barrierside facing up.

(4) Cup the liner area that is being evaluated, so that it is lower than the surrounding liner.

(5) Pour 1 cup of the alcohol–tap water mixture specified in 12.2.3.1 onto the moisture barrier in thecupped area of the liner.

12.2.5 Results.

12.2.5.1

The liner shall be visually inspected for leakage on the thermal barrier side after 3 minutes.

12.2.5.2

If any liquid passes through the moisture barrier and wets the thermal barrier, the liner shall be removedfrom service and repaired or replaced.

12.2.5.3

After the evaluation procedure has been performed, the liner shall be cleaned and allowed to completelydry to remove all traces of the alcohol–tap water mixture.


The recommendation of the input is to remove the Puddle Test from this standard. The Puddle Test was originally included in the Standard to provide an easy method of evaluating of the moisture barrier without opening the liner assembly or having the ability to perform the hydrostatic test. At the time, the rationale was sound. Now, however, after several years of experience with NFPA1851, I believe we have learned the Puddle Test is neither easy to conduct or as effective as opening the liner up and performing the hydrostatic test. The inclusion of this test in the Standard, along with the Complete Liner Inspection, also adds confusion to the inspection process and is a very time consuming task and further more is not used commonly in the industry.

The Hydrostatic Test as the recommended procedure to evaluate leakage of the moisture barrier while performing the Complete Liner Inspection is clearly the more effective method for evaluating the moisture barrier layer. It is also relatively easy and quick to perform. Since the performance of the moisture barrier is critical to the performance of the garment, it is appropriate for the hydrostatic test to be the recommended leakage evaluation within the Complete Liner Inspection. This will both improve the Advanced Inspection and simplify the inspection criteria.




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Sub-Sections] ]

At a minimum, the front and back body panels of each protective garment element shall be evaluated usingthree different moisture barrier material areas and three different moisture barrier areas with a seam.

Recommend changing as follows:

12.2.2.1 At a minimum, the front and back body panels of each protective garment element shall beevaluated using three different moisture barrier material areas in each ‘liquid barrier’ layer and threedifferent moisture barrier areas with a seam sealed seams.


There are new composites on the market where the Moisture Barrier Layer is no longer the only liquid resistant/liquid proof barrier necessary to protect the firefighter.




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12.2.2.1.2

In addition to the areas listed in 12.2.2.1.1 where potential damage to the garment outer shell or thermalbarrier has been detected, the evaluation shall be conducted on the corresponding area of the moisturebarrier. Where potential damage to the garment moisture barrier has been detected, the evaluation shallalso be conducted on that area of the moisture barrier .


The Editorial Task Group suggests making this specific so there is no room for misinterpretation.




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12.2.2.2

The liner composite shall be positioned in the evaluation apparatus so that the moisture barrier is orientedupward and is contacted with the liquid exposure in the evaluation apparatus.

Recommend revising as follows:

12.2.2.2 The liner composite Each ‘liquid barrier’ layer shall be individually positioned in theevaluation apparatus so that the moisture barrier garment shell-side of the ‘barrier’ is oriented upwardand is contacted with the liquid exposure in the evaluation apparatus.






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12.2.2.3



12.2.2.3 Moisture barrier material Seam sealed ‘liquid barrier’ layer areas for each ‘liquid barrier’with seams shall be positioned on the evaluation apparatus so that the seam divides the specimen intotwo equal halves. The garment shell-side of the seam sealed ‘liquid barrier’ is oriented upward andis contacted with the liquid exposure in the evaluation apparatus.






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12.2.4.2



(2) Orient the liner so that the moisture barrier is on the outside.

(3) Position the dry liner over the bucket with the thermal barrier facing down and the moisture barrier sidefacing up.

(4) Cup the liner area that is being evaluated, so that it is lower than the surrounding liner.

(5) Pour 1 cup of the alcohol–tap water mixture specified in 12.2.3.1 onto the moisture barrier in thecupped area of the liner.


12.2.4.2 The evaluation shall be conducted on each ‘liquid barrier’ layer using the followingprocedure:

(1) If possible, separate each ‘liquid barrier’ layer the liner from the outer shell and from each other.

(2) Orient the liner so that the moisture barrier ‘liquid barrier’ layer so that the garment shell-side ison the outside.

(3) Position the dry liner ‘liquid barrier’ layer over the bucket with the thermal barrier garmentlining-side of the ‘liquid barrier’ layer facing down and the moisture barrier side garment shell-sideof the ‘liquid barrier’ layer facing up.

(4) Cup the liner ‘liquid barrier’ layer area that is being evaluated, so that it is lower than thesurrounding liner ‘liquid barrier’ layer .

(5) Pour 1 cup of the alcohol-tap water mixture specified in 12.2.3.1 into the moisture barrier ‘liquidbarrier’ layer in the cupped area of the liner .






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12.2.5.1

The liner shall be visually inspected for leakage on the thermal barrier side after 3 minutes.


12.2.5.1 The liner shall be visually inspected for leakage on the thermal barrier side garment lining-sideof the ‘liquid barrier’ layer after 3 minutes.






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12.2.5.2

If any liquid passes through the moisture barrier and wets the thermal barrier, the liner shall be removedfrom service and repaired or replaced.


12.2.5.2 If any liquid passes through the moisture barrier ‘liquid barrier’ layer and wets the thermalbarrier garment lining-side of the ‘liquid barrier’ layer , the liner ‘liquid barrier’ layer shall beremoved from service and repaired or replaced.






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12.2.5.3

After the evaluation procedure has been performed, the liner shall be cleaned and allowed to completelydry to remove all traces of the alcohol–tap water mixture.


12.2.5.3 After the evaluation procedure has been performed on each ‘barrier’ layer , the liner ‘barrier’layers shall be cleaned and allowed to completely dry to remove all traces of the alcohol-tap watermixture.






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12.3.1 Application.

This evaluation method shall apply to moisture barrier materials and moisture barrier seams found instructural or proximity fire fighting protective garment elements that are in service.


12.3.1 Application. The evaluation method shall apply to moisture barrier each ‘liquid barrier’ layermaterial s and moisture barrier seams found on each ‘liquid barrier’ layer in structural or proximity firefighting firefighting protective garment elements that are in service.






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Sub-Sections] ]

A minimum of three moisture barrier material areas and a minimum of three moisture barrier areas with aseam shall be tested on each garment element.


12.3.2.1 A minimum of three moisture barrier material areas areas on each ‘liquid barrier’ layer and aminimum of three moisture barrier areas with a seam seam sealed areas on each ‘liquid barrier’ layershall be tested on each garment element.






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12.3.2.1.1

Moisture barrier material areas shall be from high-abrasion areas of the garment elements, including, butnot limited to:


12.3.2.1.1 Moisture barrier ‘Liquid barrier’ layer material areas shall be from high abrasion areas of thegarment element, including but not limited to:

(1) Broadest part of the shoulders

(2) Back waist area of the coat

(3) Knees

(4) Crotch area

(5) Seat area






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12.3.2.1.2

In addition to the areas listed in 12.3.2.1.1 where potential damage to the garment outer shell or thethermal barrier has been detected, the evaluation shall be conducted on the corresponding area of themoisture barrier. Where potential damage to the garment moisture barrier has been detected, theevaluation shall also be conducted on that area of the moisture barrier .


The Editorial Task Group suggests making this specific so there is no room for misinterpretation.




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12.3.2.1.2

In addition to the areas listed in 12.3.2.1.1 where potential damage to the garment outer shell or thethermal barrier has been detected, the evaluation shall be conducted on the corresponding area of themoisture barrier. Where potential damage to the garment moisture barrier has been detected, theevaluation shall also be conducted on that area.


12.3.2.1.2 In addition to the areas listed in 12.3.2.1.1 where potential damage to the garment outer shell orthe thermal barrier any layer has been detected, the evaluation shall be conducted on the correspondingarea of the moisture barrier each ‘liquid barrier’ layer . Where potential damage to the garmentmoisture barrier has been detected, the evaluation shall also be conducted on that area.






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12.3.2.2

Moisture barrier material areas shall be positioned in the evaluation apparatus such that the side of thebarrier that is against the outer shell faces the water in the evaluation apparatus.


12.3.2.2 Moisture barrier ‘Liquid barrier’ layer material areas shall be positioned in on theevaluation apparatus such that the side of the barrier that is against the outer shell garment shell-side ofthe ‘liquid barrier’ layer faces the water in the evaluation apparatus.






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12.3.2.3



12.3.2.3 Moisture barrier ‘Liquid barrier’ layer material areas with seams shall be positioned on theevaluation apparatus so that the seam divides the specimen into two equal halves and the garmentshell-side of the ‘liquid barrier’ layer faces the water in the evaluation apparatus .






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12.3.3.1*

The apparatus used to evaluate water penetration shall have the following characteristics:

(1) The apparatus shall consist of a means of clamping the area to be evaluated in a horizontal position,providing a watertight seal with the pressurized portion of the apparatus and water reservoir.

(2) The apparatus shall accommodate evaluations of moisture barriers 'liquid barrier' layers and seamswithout the removal of the specimens.

(3) The apparatus shall have a clamping area that provides a water exposure and viewing area that is atleast 50 mm (2 in.) in diameter.

(4) The apparatus shall have a water reservoir containing sufficient water for carrying out the evaluation.

(5) The apparatus shall provide for the pressurization of water against the garment element moisturebarrier area at a pressure of 6.9 kPa (1 psi) for at least 15 seconds. The 6.9 kPa (1 psi) pressure shallbe achieved within 10 seconds.

(6) The apparatus shall be equipped with a pressure gauge that is accurate to the nearest 0.2 kPa(0.1 psi).

(7) The apparatus shall be equipped with a means of bleeding air pressure and permit the drainage ofwater from the pressurized portion of the apparatus.






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12.3.4.1


(1) The selected area of moisture 'liquid barrier shall ' layer shall be replaced in the apparatus andclamped to provide a watertight seal with the apparatus.

(2) A water pressure of 1 psi shall be introduced against the moisture barrier for a period of not less than15 seconds.

(3) The visible side of the moisture 'liquid barrier shall ' layer shall be visually inspected after15 seconds to determine if water penetration has occurred.






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12.3.5.1

If any water passes through the moisture barrier or moisture barrier seam, the liner shall be removed fromservice and repaired or replaced.


12.3.5.1 If any water passes through the moisture barrier any ‘liquid barrier’ layer or moisture barrierany ‘liquid barrier’ layer sealed seam, the liner leaking ‘liquid barrier’ layer shall be removed fromservice and repaired or replaced.






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12.3.5.2

If no water passes through the moisture barrier or moisture barrier seam, the liner shall be allowed to drycompletely before being returned to service.


12.3.5.2 If no water passes through the moisture barrier or moisture barrier ‘liquid barrier’ layer and‘liquid barrier’ layer sealed seam s , the liner layers shall be allowed to dry completely before beingreturned to service.






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Public Input No. 148-NFPA 1851-2017 [ New Section after A.3.2.4 ]

A.3.3.5 Carcinogen/Carcinogenic.

Lists of carcinogens may be found at the following sources:

U.S. National Toxicology Program (NTP): https://ntp.niehs.nih.gov/pubhealth/roc/index-1.html#toc1

International Agency for Research on Cancer (IARC): http://monographs.iarc.fr/ENG/Classification/

National Institute for Occupational Safety and Health (NIOSH):

https://www.cdc.gov/niosh/topics/cancer/npotocca.html

American Conference of Governmental Industrial Hygienists (ACGIH):

2016 Threshold Limit Values (TLVs) and Biological Exposure Indices (BEIs)

Each organization uses a different way of classifying specific substances or activities as being carcinogenic.


The proposed annex item provides a source for lists of different carcinogens.







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A.3.3.5 Cancer-causing substances are often identified in one of several published lists, such as the NIOSHPocket Guide to Chemical Hazards, the Hazardous Chemicals Desk Reference, and the ACGIH TLVs andBEIs publication.


Places the information on carcinogenic lists in a better location. Also updates ACGIH publication (now 2016).










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Public Input No. 58-NFPA 1851-2016 [ Section No. A.3.3.8 ]

A.3.3.8 CBRN Barrier Layer.

While it is recognized that the entire composite will affect the performance of the ensemble in preventingthe penetration of CBRN agents, the identification of the CBRN barrier layer is intended to assistapplication of specific ensemble and element tests.


This paragraph is no longer needed as the CBRN option has been removed from NFPA 1971 and there are no certified ensembles that meet these optional requirements.







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Public Input No. 205-NFPA 1851-2017 [ Sections A.3.3.13.1, A.3.3.13.2, A.3.3.13.3 ]

Sections A.3.3.13.1, A.3.3.13.2, A.3.3.13.3

A.3.3.13.1 Advanced Cleaning.

Advanced cleaning usually requires that ensemble elements be temporarily taken out of service. Examplesinclude hand washing, machine washing, and contract cleaning.

A.3.3.13.2 Routine Cleaning On Scene (Preliminary) Cleaning .

The primary intent for on scene or preliminary cleaning is to reduce the exposure of the individual end userto soiling and persistent contamination and the spread of that contamination to apparatus, vehicles, andthe outside environment. In some cases, on scene cleaning may be sufficient, but in other cases, on sceneor preliminary cleaning will be followed by advanced cleaning or specialized cleaning. Examples includebrushing off dry debris, rinsing off debris with a water hose, and spot cleaning. This form of cleaning isintended to begin the removal of soiling and contamination as soon as practically possible following theexposure of the individual on the fireground or at the emergency scene. Ideally, this form of cleaning,conducted by the end user, is performed immediately following his or her exit from the fireground oremergency scene with the removal and containment of the exposed ensemble elements prior to leavingthe scene if contaminated. It is realized that circumstance may not allow for this immediate action due toresources, inclement weather, and other factors. Therefore, on scene or preliminary cleaning may takeplace some time or distance away from the specific exposure event.

A.3.3.13.3 Specialized Cleaning.

This level of cleaning involves specific procedures and specialized cleaning agents and processes.Different approaches may be used for removing specific types of contaminatio. Specialized cleaning mayalso be an enhanced form of advanced cleaning.


Additional detail is needed to explain the role of on scene or preliminary cleaning and indicate the practical limitations for its application.







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Public Input No. 170-NFPA 1851-2017 [ Section No. A.3.3.13.2 ]

A.3.3.13.2 Routine Cleaning.

Examples include brushing off dry debris, rinsing off debris with a low pressure water hose, and spotcleaning and for non-aluminized elements, brushing off dry debris with a brush . For aluminized elementsonly a soft cloth or sponge should be used to remove debris.


Clarifies different procedures for aluminized vs non and clarifies type of water hose in order to minimize damage to elements.





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Public Input No. 144-NFPA 1851-2017 [ New Section after A.3.3.13.3 ]

A.3.3.15 Contamination.

Ensembles and ensemble elements may be exposed to hazardous materials in several waysthrough contact with gases/vapors, liquids, or particulates. The extent and persistency of thecontamination in the ensemble or ensemble element will vary with the type of contaminant, thelength of the contamination period, and the manner by which the ensemble or ensemble elementsare contaminated. In general, contamination that is persistent represents the greatest concern.Contamination may also be preferential to certain materials, components, or portions of anensemble element or ensemble. For example, the textile fabric components of a protective helmetmay be more easily contaminated that the hard surface of the helmet shell.


The proposed annex language further clarifies the process of contamination and its significance.







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Public Input No. 150-NFPA 1851-2017 [ New Section after A.3.3.13.3 ]

A.3.3.22 Disinfectant. Disinfectants are only intended for hard, non-porous surfaces.Hard, non-porous surfaces do not include the textile products used in fire fighterprotective clothing. All disinfectants must be registered with the EPA and meetspecific labeling requirements. A listing of currently registered disinfectants can befound at http://www.epa.gov/oppad001/chemregindex.htm.

Disinfectants are classified as:

Limited – Must be supported by efficacy testing against either Salmonellacholerasuis (gram-negative bacteria) or Staphylococcus aureus (gram-positivebacteria). Limited disinfectants are found mostly in household use.

General – Must be supported by efficacy testing against both Salmonella cholerasuisand Staphylococcus aureus. General disinfectants are used in commercial areas.

Hospital – Must be supported by Association of Analytical Communities (AOAC) UseDilution or AOAC Germicidal Spray efficacy testing against Staphylococcus aureus,Salmonella cholerasuis and Pseudomonas aeruginosa. The bacteria Pseudomonasaeruginosa hides behind biofilm and is difficult to eliminate. Killing of this bacteria isrequired for Hospital Disinfectants.

The EPA’s definition of a general or “broad spectrum” disinfectant is one that haspublic health claims for all three of the major classes of organisms:

Bacteria – effective against gram-negative and gram-positive bacteria

Fungi – effective against at least one pathogenic fungi (usually Trichophytonmentagrophytes)

Viruses – effective against pathogenic viruses (at least one enveloped virus such asInfluenza A and one non-enveloped virus such as Adenovirus).

Sanitizers are not considered broad spectrum by EPA’s definition since they are onlymeant to reduce bacteria levels.


The proposed annex language clarifies how a disinfectant is qualified and its relative effectiveness.







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A.3.3.X Sanitizer. Sanitizers reduce levels of microorganism to safe levels. The EPA requires as aminimum that a sanitizer reduce the level of Staphylococcus aureus and Klebsiella pneumoniae orEnterobacter aerogenes by 99.9%25 on non-food contact surfaces within 5 minutes.


The proposed annex item further elaborates on the definition of a sanitizer.



Public Input No. 151-NFPA 1851-2017 [New Section after 3.3.80]




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A.3.3.87 Soiling.

Soiling excludes contaminants that may adversely affect the wearer such as hazardous materialsincluding toxic, corrosive, or sensitizing chemicals, potentially infectious body fluids, otherinfectious microorganisms, and CBRN terrorism agents. Since many fireground exposures withentry into a structure will involve exposure to combustion products that contain hazardouschemicals and other substances including carcinogens, any extended exposure to theseconditions will result in contamination.


Additional clarification is needed for the definition of soiling, particularly in how soiling is different from contamination. This additional information also indicates how ordinary fireground exposures to combustion products are actually a form of contamination.







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A 3.3.100 Barrier Hoods (Proposed)

Claims of stopping cancer causing contaiments (moisture, vapor, particulates) from reaching the wearershould be substaitiated through scientific testing by an approved independant testing laboratory.


provides appendix material for Barrier Hoods definition




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A.4.2.3

Emergency response organizations are cautioned that accessories could degrade the protection orperformance of the certified ensemble or ensemble element; interfere with form, fit, or function of thecertified ensemble or ensemble element; or become a hazard to the wearer.

Accessories are not part of the certified ensemble or ensemble element but could be attached to a certifiedensemble or ensemble element by means not engineered, manufactured, or authorized by the certifiedensemble or ensemble element manufacturer. If an accessory or its means of attachment causes thestructural integrity of the certified ensemble or ensemble element to be compromised, the certifiedensemble or ensemble element might not be compliant with the standard with which it was originallycertified.

Additionally, if an accessory or the accessory’s means of attachment is not designed and manufacturedfrom suitable materials for the hazardous environments of emergency incidents, the failure of the accessoryor the means of attachment could cause injury to the emergency responder.

Users are also cautioned that the means of attachment for an accessory that fails to safely and securelyattach the accessory to a certified ensemble or ensemble element can allow the accessory to becomeinadvertently dislodged from the certified ensemble or ensemble element, possibly posing a risk toemergency response personnel in the vicinity.

Organizations should consider evaluating the ensemble with tests provided in NFPA 1971, Standard onProtective Ensembles for Structural Fire Fighting and Proximity Fire Fighting, in which the accessory couldnegatively impact the performance of the ensemble element, when in place. One test that is not part ofNFPA 1971 but could be used to evaluate the performance of an externally placed accessory is ASTM F1930 F1930 , Standard Test Method for Evaluation of Flame Resistant Clothing for Protection Against FlashFire Simulations Using an Instrumented Manikin. This test provides a simulation of a flash fire exposureusing a static manikin. The effects of the flash fire on the accessory can be determined and compared to anensemble that does not have the accessory in place. A minimum exposure time of 10 seconds isrecommended for evaluating structural or proximity fire fighting ensembles. While this test provides ademonstration of ensemble/accessory performance under emergency conditions, it does not simulate allfire ground hazards, and other evaluations should be considered.

Another test that could be helpful is contained in ASTM F2702, Standard Test Method for Radiant HeatPerformance of Flame Resistant Clothing Materials with Burn Injury Prediction. This test method measuresthermal protective characteristics of flame resistant textile materials subjected to a standardized radiantheat exposure relative to a predicted second degree skin burn injury. A vertically positioned test specimen

is exposed to a radiant heat source with an exposure heat flux of either (a) 21 kW/m 2 (0.5 cal/cm 2 s) or

(b) 84 kW/m 2 (2 cal/cm 2 s). The transfer of heat through the test specimen is measured using a copperslug calorimeter. The change in temperature versus time is used, along with the known thermophysicalproperties of copper to determine the respective thermal energy delivered. The results are used to predictthe degree of second degree skin burn injury expected. The test specimen is much smaller than that inASTM F1930.


This provides information on another alternative for assessing the flame resistance of the protective ensemble.






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Public Input No. 43-NFPA 1851-2016 [ Sections A.5.1, A.5.1.1, A.5.1.2(1), A.5.1.2(6),

A.5.1.2(7) ]

Sections A.5.1, A.5.1.1, A.5.1.2(1), A.5.1.2(6), A.5.1.2(7)

A.5.1

The organization should consider establishing a committee to oversee the process of selecting ensemblesor ensemble elements. The committee should consist of interested individuals representing a cross sectionof the organization (i.e., from both labor and management who collectively have several years ofexperience in fire fighting activities). The role of the committee should be to set and define goals andrequirements and identify areas of responsibility for each member, plus provide recommendations to theauthority making the final decisions.

Copies of specifications on Each committee member should receive a copy of the organization’s currentensembles ensemble and ensemble elements should be distributed to the committee elementspecification and the risk assessment it was based upon to use as a point of reference. Even with theprevious work as a point of reference, the new risk assessment is the driver for the new specification andthe committee should understand that the new specifications may be very different from the reference pointspecifications based on that new risk assessment .

The committee should consider if there are possible areas for improvement to the existing specifications.Examples of improvement criteria over existing specifications include heat stress, SOPs, what types andfrequency of calls the organization responds to, the impact of the local climate, differences in responseactivities with the operating area and any additional factors considered important in the risk assessment todetermine garment specifications. Once the risk assessment is complete, the specification should focus ondifferent areas, including but not limited to heat stress, a portion of which may be managed through TPPand THL, garment weight, design, style, interface with other components, durability, comfort, flexibility,safety, performance, price, customer service, delivery, compliance, reliability, and warranty.

The organization should consider completing a wear trial before finalizing the garment specification. Ifresources are not available to complete a wear trial, the organization should consider working with otherdepartments who have completed or which are completing a wear trial to see if relevant information can beapplied to the organization’s specification.


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A.5.1.1


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In general, some hazards that When performing the risk assessment, the committee should identifyhazards that are common to members operating under the organization. Some hazards that can beencountered include, but are not limited to, physical, environmental, thermal, chemical, biological, electrical,radiation, operational, and ergonomic hazards. The organization should also consider the frequency andseverity of the identified hazards when conducting the risk assessment.

The safety officer is may be the logical individual to perform this function or lead the risk assessmentsince that is one of his or her role in the organization. The safety officer should consider national trendswhen performing this task. NFPA 1500, within the organization. However, risk assessments can also beperformed by qualified individuals within the department, or outside organizations, which may offer anunbiased perspective for identifying hazards and risks. For example, a fire department that is part of amunicipality or other regional public organization may choose to have another part of that entity conductthe review. NFPA 1500, Standard on Fire Department Occupational Safety and Health Program,substantiates OSHA’s regulations as follows:

(1) Section 4.3: Mandatory evaluation of safety and health programs

(2) Subsection 4.4.2: Mandatory compliance with state and federal laws

(3) Section 4.7: Safety officer’s responsibilities also defined in NFPA 1521, Standard for Fire DepartmentSafety Officer

(4) Section 7.1: Requirements for ensembles and ensemble elements

In the identification of addition to identifying hazards, the organization should consider those hazards thatfire fighters are likely to encounter in their specific operating area and account for the differences in bothtypes of hazards and the severity of those hazards . A list of potential hazards is provided in Table A.5.1.1.Table A.5.1.1 provides a list of general hazards that may be further broken down into different categoriesbased on the organization’s experience and knowledge of their specific operating areas. In determiningrisk, the organization should consider the frequency or likelihood of exposure to the hazard along with itspotential severity (consequence) if exposure occurs.

The organization should consider rating (1) the severity of hazards, (2) the potential for exposure, and (3)the consequences of exposure in order to assign the relative risk for each hazard. Hazards that aredetermined as those posing the greatest risk warrant specific attention in the development of theorganization’s development of minimum requirements as part of their purchase specifications and the typeof protective ensemble selected for use. The rating chart could include control measures to mitigate risks,especially those posing the greatest risk (i.e. Standard Operating Procedures (SOP), ensembles and orother equipment specifications.

Table A.5.1.1 List of Potential Fire Ground and Other Related Emergency Hazards

Physical Hazards Chemical Hazards

Falling objects Inhalation

Flying debris Skin absorption or contact

Projectiles or ballistic objects Chemical ingestion or injection

Abrasive or rough surfaces Liquefied gas contact

Sharp edges Chemical flashover

Pointed objects Chemical explosions

Slippery surfaces Electrical Hazards

Excessive vibration High voltage

Environmental Hazards Electrical arc flashover

High heat and humidity Static charge buildup

Ambient cold Radiation Hazards

Wetness Ionizing radiation

High wind Non-ionizing radiation

Insufficient or bright light Person–Position Hazards

Excessive noise Daytime visibility

Thermal Hazards Nighttime visibility

High convective heat Falling


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Low radiant heat Drowning

High radiant heat Person–Equipment Hazards

Flame impingement Material biocompatibility

Steam Ease of contamination

Hot liquids Thermal comfort

Molten metals Range of motion

Hot solids Hand function

Hot surfaces Ankle and back support

Biological Hazards Vision clarity

Bloodborne pathogens Communications ease

Airborne pathogens Fit (poor)

Biological toxins Ease of donning and doffing

Biological allergens


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A.5.1. 1.1

Those organizations with both structural and proximity firefighting requirements should provide guidanceas part of operating procedures identifying where and when the different types of ensembles (structuralfire fighting or proximity fire fighting) are to be worn.

A.5.1.1. 2

The basis of the initial risk assessment ( climate, types and frequencies of hazards encountered, SOPs,injuries related to PPE, etc.) used for the selection of the structural fire fighting or proximity fire fightingprotective ensembles may change over time and should be reviewed at a minimum every two years. Thisprocess may validate the original selection decisions or identify the need to perform a new riskassessment. The risk assessment review should take in to account changes in the organization’sresponsibilities and operating procedures as related to PPE selection and use, as well as the availabilityof new PPE technology.

A.5. 1 .2(1 )

In performing the risk assessment, the organization should consider all of its responsibilities. In somedepartments there might be stations or units that require different types of ensembles such as Structuraland Proximity fire Fighting Protective Ensembles . Organizations should specifically make a determinationas part of their hazard and risk assessment if any of their fire fighting operations involve structural and/orproximity fire fighting operations.

Based on the results of the risk assessment, an organization may have stations that fall into one or moreof the following three groups:

(1) Structural Ensembles Only

(2) Proximity Ensembles Only

(3) Structural and Proximity Ensembles

Therefore, each member of the organization performing structural firefighting operations should be issuedstructural protective clothing. Each member of the organization performing proximity firefighting operationsshould be issued proximity protective clothing. And, each member of the organization performingstructural and proximity firefighting should be issued both ensembles and their associated elements.

A.5.1.2( 2)

While reviewing response activities, the ensemble selection committee should consider different responsetypes (e.g. structure fire, vehicle fire, vehicle accident, EMS response, search and rescue, fuel fire, aircraftincident, etc.) and related SOPs to identify gear performance requirements.

A.5.1.2( 6)


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Examples of physical areas of operations include but are not limited to:

(1) One of the hazards faced by fire fighters is being struck by vehicular traffic. The high-visibility materialsrequired on fire fighter PPE effectively enhance visual conspicuity during the variety of firegroundoperations. The continuous use of high-visibility garments is one component of a strategy to mitigaterisks from struck-by hazards, which are known to cause serious fire fighter injuries and fatalities on anannual basis. Additional high-visibility requirements for fire fighters on or near roadways are regulatedby the Federal Highway Administration's Manual on Uniform Traffic Control Devices (MUTCD, 2009version). It is the responsibility of the authority having jurisdiction (AHJ) to specify appropriatehigh-visibility apparel from the available garment options, if any, and based on a risk assessment, toestablish policies for use in accordance with prevailing regulations (the MUTCD) and in compliancewith applicable standards (e.g., NFPA 1971, Standard on Protective Ensembles for Structural FireFighting and Proximity Fire Fighting, ANSI/ISEA 107, ANSI/ISEA 207).

(2) The use of personal flotation devices might need to be considered for operations near waterways.

(3) Fire fighters operating at elevation might need some form of fall protection, which might or might notbe incorporated into their protective clothing.

(4) Firefighters conducting proximity firefighting operations at locations or facilities involving the potentialfor high levels of radiant heat including but not limited to, bulk flammable fuel fires, bulk flammable gasfires, bulk flammable metal fires, and aircraft fires.

A.5.1.2(7)

In determining the need for CBRN protection, the organization should determine homeland securitypriorities for its jurisdiction, including, but not limited to, whether the organization would be responding to aCBRN terrorism incident, the specific roles and missions to be undertaken in response to a CBRN terrorismincident, the expected types of hazards that might be encountered for its members during a CBRNterrorism incident, and the capabilities of the organization to provide sufficient training and support for theuse of CBRN protective ensembles (e.g., decontamination for safe doffing of ensemble elements).

If it is determined that CBRN protection is needed, the organization should review both the CBRN terrorismagent protection option in NFPA 1971, Standard on Protective Ensembles for Structural Fire Fighting andProximity Fire Fighting , the (1) the different classes of ensembles addressed in NFPA 1994, Standard onProtective Ensembles for First Responders to Hazardous Materials and CBRN Terrorism Incidents, and (2)the protective ensemble defined in NFPA 1991, Standard on Vapor-Protective Ensembles for HazardousMaterials Emergencies, together with its intended CBRN terrorism agent response or action plan todetermine the suitability of requiring dual certification of firefighting protective ensembles meeting theCBRN terrorism agent protection option of NFPA 1971, Standard on Protective Ensembles for StructuralFire Fighting and Proximity Fire Fighting , versus obtaining separate ensembles that comply with specificclasses of ensembles for to the appropriate specific class of NFPA 1994, Standard on ProtectiveEnsembles for First Responders to Hazardous Materials CBRN Terrorism Incidents, or using ensemblesmeeting NFPA 1991, Standard on Vapor-Protective Ensembles for Hazardous Materials Emergencies.


NFPA 1851 addresses the organization’s selection of appropriate fire fighting protective ensembles. Currently, insufficient detail exists within the standard to distinguish between the decision for selecting protective ensembles for either structural or proximity fire fighting. The lack of detail in both the mandatory and nonmandatory parts the standards does not provide adequate information for organizations to consider which type of protective ensemble to have available for the respective hazards that the organization may face as part of its firefighting responsibilities. In fact, this deficiency has led some organizations to dismiss the need for proximity fire fighting protective ensembles on the basis of an overly simplistic hazard assessment that does not recognize the specific risks and potential for those fire fighter injury or fatalities in high radiant fire environments, such as aircraft fires. Such hazards require additional radiant protection afforded by proximity fire fighting protective ensembles.

Outside organizations rely on the specific requirements and guidance provided in NFPA 1851 to support selection decisions that they make. Therefore it is incumbent that the NFPA 1851 standard includes the appropriate provisions to aid in the selection of protective ensembles that are commensurate with the specific hazards and risks faced by the fire fighters. This includes the requirements for different organizations to select structural, proximity, or both types of fire fighting protective ensembles.

Additional corrections are made to appendix language to address the removal of the option for CBRN protection.


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CBRN protection is solely addressed in NFPA 1994 and NFPA 1991. It is possible for an ensemble to dual certified to a specific class of CBRN protection as defined in NFPA 1994.

This public input was prepared by the NFPA 1851 Risk Assessment Task Group chaired by Earl Hayden.



Public Input No. 42-NFPA 1851-2016 [Sections 5.1.1, 5.1.2] Related annex material




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A.5.1.4

Certification of protective elements can be checked by examination of the product label for the mark of thecertification organization. The organization should further check the certification of the specific protectiveelement by contacting the certification organization and asking if the item is listed as being certified ascompliant with NFPA 1971, Standard on Protective Ensembles for Structural Fire Fighting and ProximityFire Fighting. Finally, the organization can check the legitimacy of the certification organization by asking fordocumentation that shows that the certification organization has been accredited to ISO Guide 65, Generalrequirements for bodies operating product certification systems /IEC 17065 Conformtiy assessment -Requirements for bodies certifying products, processes and services .


ISO Guide 65 has been replaced by ISO/IEC 17065.




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A.5.1.5


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The majority of tests in NFPA 1971, Standard on Protective Ensembles for Structural Fire Fighting andProximity Fire Fighting, provide quantitative results; however, some tests are established on the basis ofpass or fail results and cannot be readily compared. Specific tests that offer comparative performanceresults include, but are not limited to, the following:

(1) Protective garment elements

(2) Thermal protective performance of the material composite

(3) Total heat loss of the material composite

(4) Conductive and compressive heat resistance of reinforcements

(5) Thermal shrinkage of the material layers (outer shell, moisture barrier, thermal barrier)

(6) Flame resistance of material layers and other components (outer shell, moisture barrier, thermalbarrier, other material layers and components)

(7) Tear resistance of the material layers (outer shell, moisture barrier, thermal barrier)

(8) Cleaning shrinkage of the material layers (outer shell, moisture barrier, thermal barrier)

(9) Water absorption resistance of the outer shell

(10) Tensile strength of the outer shell

(11) Seam strength of outer shell, moisture barrier, and thermal barrier layers

(12) Visibility properties of the trim

(13) Radiant reflectance of the outer shell (for proximity fire fighting protective clothing)

(14) Protective helmet elements

(15) Impact resistance (top and acceleration) after selected preconditions

(16) Flame resistance

(17) Heat resistance (level of sagging)

(18) Protective glove elements

(19) Thermal protective performance of glove body and, if present, wristlet

(20) Conductive heat resistance of glove body

(21) Thermal shrinkage of glove and innermost material

(22) Cut resistance of glove body

(23) Puncture resistance of glove body

(24) Burst strength of wristlet material

(25) Dexterity of whole gloves

(26) Grip of whole gloves

(27) Protective footwear elements

(28) Flame resistance

(29) Radiant heat resistance of upper

(30) Conductive heat resistance of sole and upper

(31) Puncture resistance of sole and upper

(32) Cut resistance of upper

(33) Abrasion resistance of sole

(34) Protective hood interface elements


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(35) Thermal protective performance of hood material

(36) Flame resistance of hood material

(37) Thermal shrinkage of hood material

(38) Burst strength of hood material

(39) Moisture barrier material: base fabric, film, or coating

(40) Cleaning shrinkage of hood material

Additional testing can also be specified for performance properties not addressed in NFPA 1971, Standardon Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting, based on theorganization's hazard and risk assessment. When additional testing is specified, standard test methodsshould be used when available, and testing should be conducted at accredited, independent laboratories.

Organizations should consider the use of an RFI (Request for Information) or an RFP (Request forProposal) format when soliciting quotations for structural or proximity fire fighting protective ensembleelements. The advantage of an RFI or an RFP proposal is that it allows manufacturers the option ofproviding all of the most current technologies for organization review (the offering is then not limited to therequirements of the specification). The organization can then choose among proposals for offered itemsfinally accepted. Typically an RFI and an RFP have the following characteristics:

(1) Minimum requirements, such as NFPA product certification, required materials, or available options

(2) Inclusion of current specifications and a requirement that each manufacturer explain how its offeringdiffers from the currently specified product

(3) Background on the offering firm's finances, capabilities, and references

(4) Field test procedures and results (see 5.1.6) of offered products

Using this approach, the organization can then employ a rating system that assigns values and weights toseveral factors, including, but not limited to, product design, manufacturer references, and field test results.

In this approach, a separately sealed cost proposal is opened only after the point ratings have beenassigned to each offering. The organization can then apply separate criteria considering both technicalmerits and cost. This approach allows fire departments to compare prices and product acceptability.

Organizations should also consider integrated PPE programs that address various levels of care andmaintenance as provided by or coordinated by the manufacturer of the fire fighter personal protectiveequipment. These programs can address many of the aspects of care and maintenance that are addressedin this standard, including, but not limited to, cleaning, inspection, and repairs, in addition to the offer ofprogram guidance and reporting and documentation of procedures.


Adds text for Barrier Hoods




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A.5.1.8


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Specifications translate the organization’s needs into performance or design requirements that can be metby manufacturers of protective equipment. Specifications should clearly address every aspect of thedepartment’s needs and expectations in regard to both the performance and the delivery of the ensemblesor ensemble elements.

Organizations should specify delivery time requirements and, if appropriate, penalty assessments for notmeeting delivery dates. Warehousing requirements, if desired, should also be established in theprocurement specification.

Organizations should be careful not to write specifications that are redundant or contradictory or that cannotbe met by manufacturers of ensembles or ensemble elements. For example, the organization should besure the thermal protection performance (TPP) specified can be achieved with the materials specified. Aprebid meeting with participation by potential bidders or manufacturers is useful in eliminatinginconsistencies and explaining requirements that might be unclear in the specifications.

Organizations should continuously review and document how their specifications and ensembles andensemble elements meet their needs and applicable standards. There are many ways to improve thequantity and quality of information received from prospective bidders. Additionally, increased purchasingpower potential can be gained by forming collective buys with other organizations for possible volumediscounts.

Purchase specifications should indicate the organization’s selection of choice for the following requiredNFPA 1971, Standard on Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting,ensemble element components:

(1) Garments

(2) Outer shell material: fabric, weight, color

(3) Thermal liner material


(5) Trim: configuration, material, color

(6) Closure system

(7) Wristlets: material, design

(8) Hoods

(9) Material

(10) Face opening design


(12) Gloves

(13) Composite materials

(14) Wristlet or gauntlet

(15) Wristlet material

(16) Helmets

(17) Material

(18) Color

(19) Retention system

(20) Trim configuration

(21) Trim color

(22) Ear cover material

(23) Ear cover dimension


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(24) Eye protection

(25) Boots: composite materials


Addresses Barrier Hoods



Public Input No. 140-NFPA 1851-2017 [New Section after 3.3.100] Barrier Hood Material




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Public Input No. 168-NFPA 1851-2017 [ Section No. A.5.1.8(2) ]


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A.5.1.8(2)


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An organization should consider its needs for performance or features in excess of the minimumrequirements of NFPA 1971, Standard on Protective Ensembles for Structural Fire Fighting and ProximityFire Fighting, such as the following:

(1) Garment elements

(2) Any styling issues

(3) Any specific range-of-motion requirements

(4) Any sleeve retraction requirements

(5) Any garment rise with overhead reach requirements

(6) Any winter liner requirements

(7) Any additional reinforcement needs (recognizing that multiple layering can modify protectiveperformance in several areas, especially breathability)

(8) Any specific additional thread requirements

(9) Any specific additional requirements for stitch characteristics

(10) Any customized sizing requirements

(11) Any attachment requirements for liners and outer shells

(12) Any specific requirements for placement of visibility marking, visibility marking materials, andreflective lettering

(13) Any specific material choices

(14) Any requirements for weight reduction

(15) Any specific details of required suspender construction or suspender/garment interface

(16) Any requirements for spot or localized enhanced insulative performance

(17) Any requirements for field interchangeability or replacement of reinforcement pieces

(18) Any requirements for enhanced flexibility at movement-sensitive areas

(19) Any requirements for notification systems to indicate liner absence

(20) Any requirements for moisture barrier substrate or thermal fill accessibility to allow fieldinspection

(21) Any requirements for lumbar support systems

(22) Any customization requirements

(23) Any passport or accountability system requirements

(24) Any specialized or additional pocketing requirements

(25) Any flashlight clips required

(26) Any PASS (personal alert safety system) interface features required

(27) Any requirements for personal escape or rescue features

(28) Any requirements for sizing adjustment

(29) Any requirements for temperature-sensing features

(30) Any requirements for interface area compatibilities

(31) Helmet elements

(32) Any styling requirements


(34) Any faceshield or goggles requirements

(35) Any reflective marking requirements



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(38) Any specific requirements for earflaps (design, materials, dimensions, attachment to shellspecifics)

(39) Any specific requirements for suspension construction


(41) Glove elements


(43) Any overall styling requirements

(44) Any details of cuff styling (wristlet or gauntlet)

(45) Boot elements



(48) Any trouser interface requirements

(49) Hood interface elements




(53) Any coverage requirements

(54) All ensemble elements

(55) Any additional certification requirements (e.g., Project FIRES, state OSHA, federal OSHA)

(56) Any requirements for interface with existing elements of the protective ensemble

(57) Any warranty requirements

(58) Any requirements for cleaning and repair support

(59) Any requirements for manufacturer or dealer references

(60) CBRN ensembles

(61) Method of deploying the CBRN protection

(62) Position of CBRN barrier layer in the material systems of each element and its ease of itsinspection

(63) Manner in which ensemble interfaces are designed to prevent inward leakage

(64) Specialized donning or doffing procedures in the wearing of the ensemble

(65) Ensemble resistance to contamination and ease of ensemble doffing for safe exit of wearer fromensemble

(66) Specific types of SCBA for which ensemble is certified


Address Barrier Hoods


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A.5.1.8(2)


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An organization should consider its needs for performance or features in excess of the minimumrequirements of NFPA 1971, Standard on Protective Ensembles for Structural Fire Fighting and ProximityFire Fighting, such as the following:

(1) Garment elements

(2) Any styling issues

(3) Any specific range-of-motion requirements

(4) Any sleeve retraction requirements

(5) Any garment rise with overhead reach requirements

(6) Any winter liner requirements

(7) Any additional reinforcement needs (recognizing that multiple layering can modify protectiveperformance in several areas, especially breathability)

(8) Any specific additional thread requirements

(9) Any specific additional requirements for stitch characteristics


(11) Any attachment requirements for liners and outer shells

(12) Any specific requirements for placement of visibility marking, visibility marking materials, andreflective lettering



(15) Any specific details of required suspender construction or suspender/garment interface

(16) Any requirements for spot or localized enhanced insulative performance

(17) Any requirements for field interchangeability or replacement of reinforcement pieces

(18) Any requirements for enhanced flexibility at movement-sensitive areas

(19) Any requirements for notification systems to indicate liner absence


(21) Any requirements for lumbar support systems


(23) Any passport or accountability system requirements

(24) Any specialized or additional pocketing requirements

(25) Any flashlight clips required

(26) Any PASS (personal alert safety system) interface features required

(27) Any requirements for personal escape or rescue features

(28) Any requirements for sizing adjustment

(29) Any requirements for temperature-sensing features

(30) Any requirements for interface area compatibilities

(31) Helmet elements



(34) Any faceshield or goggles requirements

(35) Any reflective marking requirements



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(38) Any specific requirements for earflaps (design, materials, dimensions, attachment to shellspecifics)

(39) Any specific requirements for suspension construction


(41) Glove elements



(44) Any details of cuff styling (wristlet or gauntlet)

(45) Boot elements



(48) Any trouser interface requirements

(49) Hood interface elements



(52) Any coverage requirements

(53) All ensemble elements

(54) Any additional certification requirements (e.g., Project FIRES, state OSHA, federal OSHA)

(55) Any requirements for interface with existing elements of the protective ensemble

(56) Any warranty requirements

(57) Any requirements for cleaning and repair support

(58) Any requirements for manufacturer or dealer references

(59) CBRN ensembles Liquid and particulate contamination protective ensembles

(60) Method of deploying the

CBRN protection

(a) liquid and particulate contamination protection

(b) Position of

CBRN

(a) barrier layer in the material systems of each element and its ease of its inspection

(b) Manner in which ensemble interfaces are designed to prevent inward leakage

(c) Specialized donning or doffing procedures in the wearing of the ensemble

(d) Ensemble resistance to contamination and ease of ensemble doffing for safe exit of wearer fromensemble

(e) Specific types of SCBA for which ensemble is certified


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A.6.2.2

Table A.6.2.2 provides a quick reference guide to routine inspection criteria.

Table A.6.2.2 Routine Inspection Criteria

CriteriaCoats andTrousers Hoods Helmets Gloves Footwear DRD

Soiling X X X X X X

Contamination X X X X X X

Tears and cuts X X X X X X

Damaged missing hardware or closuresystem

X

Charring, burn holes, melting X X X X X X

Shrinkage X X X X X

Material discoloration X X X X X X

Damaged or missing visibility markings X

Loss of face opening elasticity oradjustability

X

Cracks, dents, abrasions X X

Bubbling, soft spots, warping X

Damaged or missing components ofsuspension or retention systems

X

Damaged or missing components offaceshield/goggle system, includingdiscoloration and scratched lenses

X

Inverted glove liner X

Exposed or deformed steel toe, steelmidsole, or shank

X

Loss of water resistance X

Closure system component damage andfunctionality

X

Earflaps: rips, tears, or cuts; thermaldamage such as charring, burn holes, ormelting

X

Size compatibility

Correct assembly and size compatibility of shell, liner, and DRD X X


The Editorial Task Group suggests making "Inverted liner" and "Size compatibility" consistent with the same item in table A.6.3.5 so they will say, "Inverted glove liner" and "Correct assembly and size compatibility of shell, liner, and DRD".




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A.6.2.2

Table A.6.2.2 provides a quick reference guide to routine inspection criteria.

Table A.6.2.2 Routine Inspection Criteria

Criteria Coats and Trousers Hoods Helmets Gloves Footwear DRD

Soiling X X X X X X


Tears and cuts

Rips, tears,cuts and abrasion X X X X X X

Damaged missing hardware or closure system X


Shrinkage X X X X X

Material discoloration or degradation including ultra violet, or chemical damage X X X X X X

Damaged or missing visibility markings

Visibility marking integrity; separation of attachment to garment, reflectivity damage X x x x x x

Loss of face opening elasticity or adjustability X


Bubbling, soft spots, warping X

Damaged or missing components of suspension or retention systems X

Damaged or missing components of faceshield/goggle system, including discoloration andscratched lenses

X

Inverted liner X

Exposed or deformed steel toe, steel midsole, or shank X

Loss of water resistance X

Closure system component damage and functionality X

Earflaps: rips, tears, or cuts; thermal damage such as charring, burn holes, or melting X

Size compatibility

Delamination as evidenced by separation or peeling of the outer shell

X

xx x x x X


Clarifies the table relative to several conditions for a more thorough inspection process to find unsafe elements





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A.6.3.5


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Table A.6.3.5 provides a quick reference guide to advanced inspection criteria.

Table A.6.3.5 Advanced Inspection Criteria


Soiling X X X X X X


Rips, tears, cuts, and abrasion X X X X X X

Damaged or missing hardware or closuresystem

X X X X X


Shrinkage X

Material degradation (UV or chemicaldamage)

X X X X X X


Visibility marking integrity, attachment togarment, reflectivity damage

X X


X


Bubbling, soft spots, warping X X

Damaged or missing components of thesuspension and retention systems

X

Earflaps: rips, tears or cuts, thermaldamage

(

such as charring, burn holes, melting

)

, or discoloration of any layer X

Damaged or missing components of faceshield/goggle system, including discoloration andscratched lenses

X


Exposed or deformed steel toe, steel midsole, or shank X

Loss of water resistance X X

Evaluation of system fit and coat/trouser overlap X

Loss of seam integrity X X X

Broken or missing stitches X X X X

Loss or shifting of liner material X X

Loss of wristlet elasticity, stretching, runs, cuts, or holes X X

Label integrity and legibility X X X X X X

Hook and loop functionality X X X X

Liner attachment system X X

Material elasticity, stretching out of shape X

Damage to the impact cap X

Loss of flexibility X

Punctures, cracking, or splitting X X X


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Excessive tread wear X

Condition of lining: tears, excessive wear, separation from outer layer X

Correct assembly and size compatibility of shell, liner, and DRD X X

Closure system functionality X

Accessories for compliance with 4.2.3 X X

Conduct the light evaluation of liners (12.1) and the leakage evaluation (12.2), or thecomplete liner inspection (6.4)

X


The Editorial Task Group suggests making "Earflaps: rips, tears, or cuts; thermal damage such as (charring, burn holes, or melting, or discoloration of any layer)" consistent with the same item in table A.6.2.2 and the legislative text in 6.3.5.2(3)(b).




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A.6.3.5


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Soiling X X X X X X




X X X X X


Shrinkage X


X X X X X X



X X


X




X

Earflaps: rips, tears or cuts, thermaldamage (charring, burn holes, melting)

X


X



X


Evaluation of system fit and coat/trouseroverlap

X




Loss of wristlet elasticity, stretching, runs,cuts, or holes

X X










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Condition of lining: tears, excessive wear,separation from outer layer

X

Correct assembly and size compatibility ofshell, liner, and DRD

X X



Conduct the light evaluation of liners (12.1)and the leakage evaluation (12.2), or thecomplete liner inspection (6.4)

X X


Address Inspection for Barrier Hoods



Organization: BHVarner &Associates

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A.6.3.5


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Soiling X X X X X X




X X X X X


Shrinkage

Delamination as evidenced by separation orpeeling of the outer shell

x x xX

xx


X X X X X X



X X


X




X

Earflaps: rips, tears or cuts, thermaldamage (charring, burn holes, melting)

X


X



X


Evaluation of system fit and coat/trouseroverlap

X




Loss of wristlet elasticity, stretching, runs,cuts, or holes

X X








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Condition of lining: tears, excessive wear,separation from outer layer

X

Correct assembly and size compatibility ofshell, liner, and DRD

X X



Conduct the light evaluation of liners (12.1)and the leakage evaluation (12.2), or thecomplete liner inspection (6.4)

X


Clarifies table and seeks to align table with Table A.6.2.2





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Public Input No. 175-NFPA 1851-2017 [ Section No. A.6.3.5.1(3) ]

A.6.3.5.1(3)

All charred, burned, or discolored areas should be thoroughly checked for strength and integrity byaggressive flexing of the material (except for aluminized materials) and attempts to push a finger or thumbthrough the fabric. Any loss of strength or weakening of the materials to the degree that the material can betorn with manual pressure is a sign of deterioration, and the garment should be removed from service.Aluminized materials should not be agressively flexed but should be checked for strength and integrity.


Aluminized materials should not be aggressively flexed due to the fragile nature of the product.





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A.6.3.7.1

Organizations should consult with the manufacturer of the ensemble with optional CBRN liquid andparticulate contamination protection for any additional or specific advanced inspection requirements for thistype of ensemble.









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A. Also remove asterisk from 6.3.7.3

Loss of integrity can be determined by evaluating the inward leakage for representative CBRN protectiveensembles

.

One evaluation method that could be used is the CBRN Ensemble Inward Leakage Resistance Evaluation.The procedure in this section is based on procedures established by the Occupational Safety and HealthAdministration (OSHA) for the evaluation of totally encapsulated suits, as found in Appendix A of OSHA29 CFR 1910.120, “Hazardous Waste Operations and Emergency Response.” Modifications to theprocedures have been made to evaluate structural fire fighting protective ensembles that do notencapsulate both the wearer and the breathing apparatus.

For this testing, the entire CBRN protective ensemble should be evaluated, including protective garments,gloves, footwear, and hood. The protective helmet should be included, if it is part of the CBRN protectiveensemble. The appropriate CBRN SCBA should be included as specified as part of the CBRN ensemble.

The suggested test procedure involves placement of commercially available colorimetric dosimeters(sensors) on the ensemble wearer’s body at different locations at or near interface areas of the ensemble.An ammonia challenge atmosphere is then created by the placement of a volume of household ammonia(aqueous ammonium hydroxide, approximately 58 percent by weight) in a shallow pan in a closed room,such as a large closet. The procedure generates an ammonia atmosphere of approximately 500 to 1500ppm; the test concentration can be assessed using length of stain detection tubes specific for ammonia.After the placement of the colorimetric dosimeters, the ensemble wearer dons the ensemble and respiratorwell away from the test area, enters the test area, and goes through a series of exercises to stress variousparts of the ensemble. Following the exercises, the ensemble wearer goes to an area well away from thetest area, the ensemble is removed, and the colorimetric dosimeters are examined for color changes.Indications of color change for any of the colorimetric dosimeters that cannot be rationalized from crosscontamination or error in procedure are then deemed as requiring the ensemble to be removed forreevaluation, inspected, and repaired, if necessary.

The CBRN ensemble should be evaluated as specified in Test B, totally encapsulating chemical protectivesuit qualitative leak test, in Appendix A of 29 CFR 1910.120, with the following modifications:

(1) All safety precautions must be followed.

(2) The CBRN protective ensemble should be substituted for the totally encapsulating chemicalprotective suit.

(3) Specific colorimetric dosimeters should be used in lieu of bromophenol blue–indicating paper thathave a specific range of sensitivity of at least 1 ppm when exposed to ammonia for a period of2 minutes.

(4) Eight colorimetric dosimeters should be placed on the test subject at the following locations underthe CBRN ensemble:

(5) Neck area

(6) Center lower front chest near waist

(7) Center lower back near waist

(8) Each wrist

(9) Front of each leg above the ankle

(10) Forehead above where the SCBA facepiece and the test subject’s face form the seal

These placements are intended to evaluate possible inward leakage in interface areas.Additional colorimetric dosimeters can be added at other locations where inward leakage issuspected to occur. Colorimetric indicators that have been found suitable are the Permea-Tec™aliphatic amine sensors, part no. 3005, available from CLI Laboratories, 1261A Rand Road, DesPlaines, IL 60016-3402, 847-803-3737, www.clilabs.com. These adhesive bandage-like sensorsare placed on the skin at the recommended locations. The sensors turn a reddish-purple ifammonia at concentrations over 1 ppm is detected.


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(11) Performance is deemed as passing if no color changes are noted for any of the colorimetricdosimeters. If color changes are found, a determination should be made that the procedures weredone correctly and that no cross contamination of the colorimetric dosimeters occurred. If the resultsare determined to be valid, the ensemble should be removed from service, repaired, or replaced.


This section no longer applies as the CBRN option has been removed from NFPA 1971 and there are no certified ensembles that meet these optional requirements. It is further not relevant to the new optional category of liquid and particulate contamination protective ensembles.







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A.6.4.3

It should be noted that this standard's requirement that a complete liner inspection be performed after thefirst 3 years of service performed every 12 months and every year thereafter should not negate thenecessity of conducting a complete liner inspection sooner than the required time frame if circumstances orappearances dictate. For example, inside layers that show marked discoloration or physical deteriorationshould trigger a complete liner inspection.


The Complete Liner Inspection is a critical method for evaluating the thermal barrier and moisture barrier. It is also relatively easy and quick to perform as part of the Advanced Inspection and has become routine practice requested by fire departments. Since the performance of these two components is critical to the performance of the garment, it is appropriate for the Complete Liner Inspection to become a required part of the Advanced Inspection annually. This will both improve the Advanced Inspection and simplify the inspection interval criteria currently written in the standard.







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A.6.4.3.1

The 2-year requirement for the complete liner inspection after moisture barrier replacement is to ensurethat the thermal barrier — which has not been replaced but has remained in service — continues to beinspected in a timely manner, as opposed to going another 3 years without being inspected.


The removal of this section is contingent on the committee accepting PI’s proposed on section’s 6.4.3, 6.4.3.1 and A.6.4.3.1. This section will no longer be needed if the referenced changes are accepted.







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A.7.1.9


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For ensembles and ensemble elements that are to be cleaned or decontaminated by contract cleaning, thefollowing questions should be asked to determine if the ISP is knowledgeable enough to provide adequateservice and not cause damage to the ensembles and ensemble elements:

(1) Can the ensembles or ensemble elements be effectively cleaned or decontaminated? (Seeinformation following this list.)

(2) Does the ISP have references for cleaning and/or decontamination of ensembles and ensembleelements?

(3) Does the ISP have liability insurance to clean protective clothing (i.e., for the repair or replacement ofensembles and ensemble elements damaged in laundry, from wash water contamination, etc.)?

(4) Does the ISP take reasonable precautions to protect its personnel from contaminant exposures whilehandling ensembles and ensemble elements?

(5) Is the ISP familiar with the requirements of NFPA 1971, Standard on Protective Ensembles forStructural Fire Fighting and Proximity Fire Fighting, and NFPA 1581, Standard on Fire DepartmentInfection Control Program, as well as federal, state, and local regulations?

(6) Does the ISP have a quality assurance program?

(7) What type of process does the ISP use? Are material safety data sheets (MSDS) available? If theprocess is proprietary, is it approved by the manufacturer of the ensemble or the ensemble element?

(8) Does the ISP take appropriate steps to prevent cross contamination between any and all productslaundered in the facility?

(9) How does the ISP demonstrate the effectiveness of the cleaning process?

(10) What testing or evaluation method(s) are used to ensure that decontaminated ensembles or ensembleelements are truly decontaminated and safe to wear?

(11) Does the ISP comply with applicable federal, state, and local wastewater discharge regulations andstandards?

(12) Does the ISP provide delivery and pick-up services for soiled and/or contaminated ensembles andensemble elements?

(13) Does the ISP have the capability to restore water-repellent properties of ensembles and ensembleelements?

(14) What is the turnaround time?

It is important that the organization request information from the ISP or the cleaning agent supplier aboutthe effectiveness of cleaning agents and cleaning procedures and about the effects of the cleaning agentsand cleaning procedures on ensembles and ensemble elements. Although there are few establishedprocedures for making these determinations, the following guidelines are offered:

(1) Request information about the cleaning effectiveness of the process or the cleaning agent. Actualcleaning effectiveness should be demonstrated by washing ensembles or ensemble elements that eitherhave become soiled from use or have been intentionally soiled. Cleaning effectiveness is typicallyconfirmed by a visual comparison of the before and after cleaned samples. It is important to note thatensembles and ensemble elements that appear clean might not be fully clean and can contain chemicalcontaminants.

(2) Request data about the effects of the cleaning process or cleaning agent on protective ensembles orensemble elements.

Move the Requirements from this portion of the Annex Section of A.7.1.9 to Chapter 7

The effects of the cleaning agent or cleaning process should shall be judged determined on the basis oftests performed on representative material samples following several cleaning cycles (washing and drying).The samples should be subjected to at least 10 cleaning cycles; however, organizations might wantsuppliers or the ISP to demonstrate effects after as many as 25 cleaning cycles. Ideally, ensembleEnsemble element(s) should shall be evaluated for each of the performance properties listed inNFPA 1971, Standard on Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting;however, key properties can be selected. Table A.7.1.9 provides a list of recommended key properties forevaluation.

Table A.7.1.9 Recommended 9 Performance Tests for Evaluating Effects of Cleaning Agents or CleaningProcedures


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PerformanceProperty

Test Method

(Section Number)*Type of Sample(s) Specimens Required†

Thermal protectiveperformance

8.10 Composite Three 150 mm (6 in.) squares

Flame resistance 8.2Outer shell, moisturebarrier, thermal barrier

Five 75 mm × 305 mm (3 in. ×12 in.) rectangles (in each materialdirection)

Tear strength 8.12Outer shell, moisturebarrier, thermal barrier

Five 75 mm × 150 mm (3 in. × 6 in.)rectangles (in each materialdirection)

Tensile strength 8.49 Outer shellFive 100 mm × 200 mm (4 in. ×8 in.) rectangles (in each materialdirection)

Water absorption 8.25 Outer shell Three 200 mm (8 in.) squares

Cleaning shrinkage 8.24Outer shell, moisturebarrier, thermal barrier

Five 375 mm (15 in.) squares

Fuel C penetrationresistance

8.27 Moisture barrier seams Three 75 mm (3 in.) squares

Viral penetration 8.28 Moisture barrier seams Four 75 mm (3 in.) squares

Retroreflectivity andfluorescence

8.45 Trim sections Four 305 mm (12 in.) lengths

*Sections are from NFPA 1971, Standard on Protective Ensembles for Structural Fire Fighting andProximity Fire Fighting.

†Either specimens removed from ensemble elements or representative material samples

Other properties can shall be permitted to be evaluated that are of interest to the organization, includingthe following:

(1) Composite weight

(2) Composite thickness

(3) Composite total heat loss (breathability)

(4) Outer shell colorfastness to washing

(5) Outer shell colorfastness to light exposure

(6) Outer shell or thermal barrier abrasion resistance

The effects of cleaning properties are shall be evaluated by comparing the measured property afterwashing with the same property measured for new material. It is important to review both the after-cleaninglevel and the change for the measured property. Properties should shall remain at or above the minimumperformance requirements established in NFPA 1971, Standard on Protective Ensembles for Structural FireFighting and Proximity Fire Fighting. It is also important to take note of large changes in clothing materialproperties. For example, the tear strength of a material can be measured at a level of 11.4 kg (25 lb) beforecleaning and then 10 kg (22 lb) after several cycles, whereas a different material could begin at 18.2 kg (40lb) and drop to 11.4 kg (25 lb) after the same number of cleaning cycles. This particular case points out thatone material might be more susceptible to cleaning.

It is also possible for some measured properties to increase after multiple cleaning cycles. For example,thermal insulation as measured in the thermal protective performance test often improves after cleaningbecause the thickness (or loft) of the materials increases. Conversely, the total heat loss (THL) value of thesame ensemble can decrease as a result of cleaning.

The loss of water absorption resistance for an outer shell can be reduced by the reapplication of water-repellent finishes. It is essential that chemicals used in this process be determined to be safe and withoutany adverse effects on the ensemble element(s).

In evaluating the effects of cleaning agents or cleaning procedures on ensembles and ensemble elements,it is important to realize that applying multiple cleaning cycles does not simulate its use. Cleaning is butone factor in the “wear” of protective ensemble and ensemble elements. Cleaning, when properly applied,


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might also extend the life of the ensemble and ensemble element.


Mandatory requirements should be imposed to determine the impact of cleaning process on the performance properties of protective clothing with this requirement added to Chapter 7.




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A.7.2.1

Routine cleaning is a light cleaning of ensembles and ensemble elements performed by the end userwithout the elements being taken out of service. Routine cleaning can be accomplished by brushing off drydebris, rinsing off debris with a low pressure water hose, and spot cleaning and for non-aluminizedelements brushing off dry debris . For aluminized elements only a soft cloth or sponge should be used toremove debris.


Clarifies type of water hose to use and the difference between treating aluminized vs non-aluminized elements in order to protect the element from damage.





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A.7.3.2

Advanced cleaning is a thorough cleaning of ensembles and ensemble elements accomplished by washingthem with cleaning agents. Advanced cleaning usually requires elements to be temporarily taken out ofservice. Advanced cleaning can be accomplished by hand washing in a utility sink, by machine washing, orby an ISP. Elements with aluminized fabric should be washed without any mechanical action that mightcause abrasion to the fabric.

Soiling is not always visible and can be difficult to observe on darkly colored materials. In addition,exposure can occur where ensemble elements are contaminated with fire gases, resulting in ensembleelements that can be relatively unsafe for use. Ensemble elements that have not been cleaned and appearto be unsoiled have been shown to contain numerous fire gas chemicals, including carcinogenicpolynuclear aromatic compounds. Periodic cleaning is required to avoid use of ensemble elements thatcould be contaminated without visible evidence of soiling.


Clarifies proper cleaning of aluminized fabric due to the fragile nature of the product.





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A.7.3.6

Machine cleaning is the most effective method for cleaning ensemble elements such as structural coats,structural trousers, coveralls, and hoods. It is the most effective means of loosening and removing dirt,soot, and other debris. Presently there are two basic types of automatic washing machines commonlyavailable for use by end users: top-loading agitator-style machines and front-loading washer/extractors.New technologies are emerging every day in the cleaning industry that will affect the options available toboth the end user as well as the ISP for all ensemble elements. At this time, it is generally accepted thatfront-loading machines are more appropriate for protective ensembles and ensemble elements, whereallowed by the element manufacturer. It is very important for machine operators to ensure correct watertemperatures and proper detergent and additive selection and to carefully monitor and adjust the g forces ofthe spinning/extraction cycle for each element type being laundered. Careful adherence to manufacturers'recommendations of cleaning processes has a significant impact on cleaning thoroughness andmaintenance of protection factors inherent in each element, as well as extending the life expectancy ofelements. Some of the advantages and disadvantages of each type of machine are as follows.

(1) Top-Loading Washers. Top-loading machines are similar to those used in most homes. They use acenter post agitator to whisk water through the fibers of garments. They are designed to clean multiplegarments of minimum bulk. As a result of the center post agitation, it is generally accepted that top-loadingmachines are more damaging to ensembles and ensemble elements than front-loading machines.Top-loading, agitating machines have the potential to reduce the longevity of garments due to mechanicaldamage. If top-loading machines are used, stainless steel wash tubs are recommended to protect againstrusting, chipping, and the associated wear on garments.

(2) Front-Loading Washers. Front-loading washers have a door on the front of the machine through whichgarments are loaded. They clean by lifting garments out of the water and gently dropping them back intothe water. These units provide better mechanical action because of the size and type of rotation, as well asthe degree of extraction. They have various capacities and are designed to handle heavy loads of bulkyitems and also to save water and energy. For those reasons, it is generally accepted that front-loadingmachines are more appropriate for protective clothing.


Clarifies that machine washing is for strucutral elements due to the fragile nature of aluminized fabric.





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A.7.3.7(2)

The structural garments should be soaked according to the detergent manufacturer’s instructions. Thegarment should be removed and the soak water should be drained. If necessary, a soft bristle brush shouldbe used to gently scrub the structural garment. Extra care should be taken with liner assemblies. Proximity garments should not be soaked, scrubbed or brushed. Use a soft cloth or sponge whencleaning proximity garments.


Clarifies proper procedures for use with proximity garments due to the fragile nature of the fabric.





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A.7.3.9.2 5

Ensembles and ensemble elements should be cleaned and decontaminated only with like elements,including, but not limited to, outer shells with outer shells, liners with liners, hoods with hoods, gloves withgloves, and boots with boots. Accesory items should only be cleaned with accessory items, i.e., Life SafetyHarnesses and Drag Rescue Devices should be removed (whenever possible) from coats and/or pantsprior to cleaning, and washed separately. It is highly recommended that garment liner systems be removedif possible and cleaned separately to avoid contamination with the debris found in the shell. Because themoisture barrier will limit the flow of water through the outer shell fabric, removing the liner will result inbetter cleaning. Separating the liner from the outer shell will also reduce drying time.


Renumbering to align with submitted proposals and adding clarification to clean accessory items separate from other elements in order to minimize damage potential to elements.





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A.7.3.10.1

Detachable items can include helmet covers, liners, suspension sweat bands or covers, ear covers, certaintypes of faceshield/goggle components, identification shields, and various accessories. Advanced cleaningincludes washing both the inside and outside surfaces of the helmet carefully, using a soft brush to reachbetween components and into difficult-to-access spaces, and washing the eye/face protection. Proximityitems should not be brushed. Only a soft cloth or sponge should be used to wash proximity items thatutilize aluminized fabric. It is usually not necessary to completely submerge a helmet for cleaning unless itis being inspected for damage or repairs are being performed in conjunction with the cleaning. The helmetshould be thoroughly washed prior to disassembly to prevent the migration of dirt and contamination.


Providing further instruction on items that should be separated from helmets when cleaning to provide for more thorough cleaning.Clarifies that proximity items should not be brushed due to the fragile nature of the fabric.





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A.10.1.3.1

Specific to proximity elements, the consensus of the technical committee is that the life of a proximity outershell is considerably less than that of a structural shell and that the life span is entirely dependent on thetype and amount of field use to which each separate element has been exposed. Given the characteristicsof the aluminized outer materials necessary to obtain the required radiant and reflective properties, this typeof fabric is especially susceptible to abrasion, which can result in a loss of the protective qualities in a veryshort time. Regardless of when the element was originally produced, it is imperative that the protectiveelements be routinely inspected to ensure that they are clean, well maintained, and still safe. Just knowingthe age of the elements cannot do that.

It should be noted that most manufacturer's of Proximity protective garments can make a replacementouter shell for a liner system that is less than 10 years old from the date of manufacture. If a replacementouter shell is not obtainable the entire garment may need to be retired.


The disposition of the liner system is not addressed in the 5 year outer shell retirement requirement for Proximity garments. Something should be provided in the annex to advise the end user that if a replacement shell cannot be obtained then the entire garment may need to be retired.




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Public Input No. 103-NFPA 1851-2017 [ Chapter B ]

Annex B Informational References

B.1 Referenced Publications.

The documents or portions thereof listed in this annex are referenced within the informational sections ofthis standard and are not part of the requirements of this document unless also listed in Chapter 2 for otherreasons.

B.1.1 NFPA Publications.



NFPA 1521, Standard for Fire Department Safety Officer, 2008 2015 edition.

NFPA 1581, Standard on Fire Department Infection Control Program, 2010 2015 edition.


NFPA 1991, Standard on Vapor-Protective Ensembles for Hazardous Materials Emergencies, 2005 2016edition.



B.1.2 Other Publications.

B.1.2.1 AATCC Publications.

American Association of Textile Chemists and Colorists, P.O. Box 12215, Research Triangle Park, NC27709-2215.

AATCC 127, Water Resistance: Hydrostatic Pressure Test, 2003 2014 .

B.1.2.2 ANSI Publications.

American National Standards Institute, Inc., 25 West 43rd Street, 4th Floor, New York, NY 10036.

ANSI/ASSE Z87.1, Occupational and Educational Personal Eye and Face Protection Devices, 2003 2015 .

ANSI/ISEA 107, American National Standard for High Visibility Safety Apparel and HeadwearDevices Accessories , 2010 2015 .

ANSI/ISEA 207, American National Standard for High Visibility Public Safety Vests, 2011.

B.1.2.3 ASTM Publications.

ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959.

ASTM F 1731, Standard Practice for Body Measurements and Sizing of Fire and Rescue ServicesUniforms and Other Thermal Hazard Protective Clothing, 1996 (2002) edition 2013 .

ASTM F 1930, Standard Test Method for Evaluation of Flame Resistant Clothing for Protection AgainstFlash Fire Simulations Using an Instrumented Manikin, 2000 2015 .

ASTM STP 1237, Performance of Protective Clothing, 5th Volume, 1996.


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B.1.2.4 EPA Publications.

U.S. Environmental Protection Agency publications provided by the U.S. Government Printing Office,Superintendent of Documents, Washington, DC 20402-9325.

EPA SW-846, Test Methods for Evaluating Solid Waste, Physical/Chemical Methods (The specific methodscited can be downloaded at http://www.epa.gov/epaoswer/hazwaste/test/SW846.htm): Method 3015,“Microwave Assisted Acid Digestion of Aqueous Samples and Extracts,” September 1994; Method 3540,“Soxhlet Extraction,” Revision 3, December 1996; Method 6010, “Inductively Coupled Plasma-AtomicEmission Spectrometry,” Revision 2, December 1996; and Method 8270, “Semivolatile Organic Compoundsby Gas Chromatography/Mass Spectrometry (GC/MS),” Revision 3, December 1996.

B.1.2.5 IAFC Publications.

International Association of Fire Chiefs, 4025 Fair Ridge Drive, Suite 300, Fairfax, VA 22033-2868,www.iafc.org.

“LODD Response Plan” (downloadable from IAFC website; click on Resources, Download Documents,Health & Safety, Line of Duty Deaths, Investigation.)

B.1.2.6 IAFF Publications.

International Association of Fire Fighters, 1750 New York Avenue, N.W., Washington, DC 20006.

“Line of Duty Notification, Assistance, and Investigation Policy,” www.iaff.org/safe/lodd.html.

B.1.2.7 ISO Publications.

International Organization for Standardization, 1, rue de Varembé, Case postale 56, CH-1211 Geneve 20,ISO Central Secretariat, BIBC II, Chemin de Blandonnet 8, CP 401, 1214 Vernier, Geneva, Switzerland.

ISO/IEC Guide 65, General requirements for bodies operating product certification systems , 1996edition. 17065 Conformity assessment - Requirements for bodies certifying products, processes andservices, 2012

B.1.2.8 USFA Publications.

U.S. Fire Administration, 16825 South Seton Avenue, Emmitsburg, MD 21727.

Research, Testing, and Analysis on the Decontamination of Fire Fighting Protective Clothing andEquipment.

B.1.2.9 U.S. Government Publications.

U.S. Government Printing Office, Superintendent of Documents, Washington, DC 20402-9325, Phone:202-512-1800 (www.gpo.gov)

FHA Manual on Uniform Traffic Control Devices, 2009 2012 .

Title 29, Code of Federal Regulations, Part 1910.120, “Hazardous Waste Operations and EmergencyResponse,” August 22, 1994.

B.2 Informational References. (Reserved)

B.3 References for Extracts in Informational Sections. (Reserved)


Updates to standards, editions and addresses.Several NFPA standards will require updates of editions in second revision.




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Public Input No. 28-NFPA 1851-2016 [ Section No. B.1.2.2 ]

B.1.2.2 ANSI Publications.

American National Standards Institute, Inc., 25 West 43rd Street, 4th Floor, New York, NY 10036.

ANSI/ASSE Z87.1, Occupational and Educational Personal Eye and Face Protection Devices, 2003.

ANSI/ISEA 107, American National Standard for High Visibility Safety Apparel and Headwear Devices,2010 2015 .

ANSI/ISEA 207, American National Standard for High Visibility Public Safety Vests, 2011.


ANSI/ISEA 107 standard has updated to the 2015 version


Submitter Full Name: Tim Gardner

Organization: 3m Company

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B.1.2.3 ASTM Publications.

ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959.

ASTM F 1731 F1731 , Standard Practice for Body Measurements and Sizing of Fire and Rescue ServicesUniforms and Other Thermal Hazard Protective Clothing, 1996 (2002 2013 ) edition.

ASTM F 1930 F1930 , Standard Test Method for Evaluation of Flame Resistant Clothing for ProtectionAgainst Flash Fire Simulations Using an Instrumented Manikin, 2000 2015 .

ASTM F2702, Standard Test Method for Radiant Heat Performance of Flame Resistant Clothing Materialswith Burn Injury Prediction, 2015.

ASTM STP 1237, Performance of Protective Clothing, 5th Volume, 1996.


date updates - also ad standard proposed in separate public input.







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Public Input No. 201-NFPA 1851-2017 [ New Section after B.1.2.9 ]

B.1.2.10 ACGIH Publications. American Conference of Governmental

Industrial Hygienists, 1330 Kemper Meadow Drive, Cincinnati, OH 45240.

ACGIH Publication No. 0107, 2016 TLVs and BEIs.


Moves reference to annex and updates









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B.1.2.9 U.S. Government Publications.

U.S. Government Printing Office, Superintendent of Documents, Washington, DC 20402-9325, Phone:202-512-1800 (www.gpo.gov)

FHA Manual on Uniform Traffic Control Devices, 2009.

Title 29, Code of Federal Regulations, Part 1910.120, “Hazardous Waste Operations and EmergencyResponse,” August 22, 1994.

NIOSH Publication No. 2005-149, NIOSH Pocket Guide to Chemical Hazards, 3rd Printing, September2007.


The NIOSH guide has been updated and is place din the annex because that is where it is referenced.









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