NFPA 1851: 2014 Edition Released!

TIPS FROM THE TOP!  from Paul Curtis

The NFPA has recently published (August 15, 2013) the 2014 edition of 1851 Standard on Selection, Care, and Maintenance of Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting.

The new standard supersedes all previous editions and there are a few changes in the newest edition of the standard that are important for the fire service and Independent Service Providers (ISP) to incorporate into their procedures.

NFPA 1851

Standardon Selection, Care, and Maintenance of Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting:  2014edition

  • The 2014 revision on this standard, which is the second revision, was issued on July 15, 2013 with an effective date of August 15, 2013. What follows is a list of new or revised requirements effective with this edition.
  • Probably the most significant change in this document involves independent service providers. The 2008 revision of the standard contained both verified and non-verified ISPs. The 2014 edition does not recognize any but verified ISPs; in other words, in order to claim to be an ISP in accordance with the requirements of NFPA 1851, the service provider must be verified by a third party certification organization.

STANDARDS PROCESS

  • NFPA standards writing has undergone a change in an attempt to make the document more user friendly during the development stages and encourage additional public input from the start. Rather than Proposals, the Technical Committee (TC) will review INPUT and from this public input come up with First Draft, which is published in place of a Report on Proposals (ROP). The advantage here is that the entire draft document with all proposed changes can be viewed as a whole, rather than a series of proposals and committee actions.
  • The public can see this first draft and submit Public Comments proposing further changes, which the TC either accepts or rejects. This results in a Second Draft for public review; this Second Draft Report replaces the Report on Comments (ROC) and is published on NFPA Standards Development Site, together with appropriate links to all Comments, Committee Actions and Committee Statements. Once again, this is an entire draft document.
  • At this point the only thing that will hold up a standard is if someone wants to contest the publication of the document. This would be in the form of a NITMAM (Notion of Intent to Make a Motion) and this allows the dissenter to address the entire NFPA membership at the annual meeting, when the document is presented. There are only three motions that can be made:
  1. Motion to Accept a Comment. This motion seeks to add proposed text into the standard.
  2. Motion to Reject a second Revision.  This motion seeks to delete proposed text from the second draft.
  3. Motion to Return an entire NFPA standard. This motion seeks to send an entire new or revised standard back to Technical Committee for further consideration.

 CHAPTER 3

  • Chapter 3 is the definitions chapter in all NFPA documents. In 1851, the definition for standard is new; there was no definition in previous editions.
  • The NFPA definition for organization as it applies to this standard is further broken down into subcategories, including Manufacturer Trained Organization and Verified Organization and each of these subcategories has different designations throughout the standard.

CHAPTER 4: PROGRAM

  • Where the organization is a verified organization or uses a verified ISP, approval from the manufacturer is not required. This was added to ensure that a manufacturer could not withhold approval from a fire department that had chosen a specific ISP who they wanted to use for advanced inspection, advanced cleaning and/or repairs.
  • This revision to 1851 says that training does not have to be by the exact manufacturer but can be by ANY element manufacturer of the same element type, or by a verified ISP. This was added to ensure that a manufacturer could not hold an organization hostage by refusing to train their personnel unless they continued to buy a specific brand. There is an annex item that explains it may still be very beneficial for an organization to consult with their own manufacturer, even though it is not a requirement.
  • The 2008 revision included a statement that when manufacturer’s instructions regarding care or maintenance differed from a specific requirement in the standard, the manufacturer’s instructions shall take precedence. The 2014 edition added a caveat: Manufacturers shall not be permitted to override the requirements of the standard for third-party verification.

This was specifically added to clarify that manufacturers cannot “waive” the requirement for an ISP or organization to be third party verified.

 

New table added to show responsibilities for Garment Inspection, Cleaning & Repair

MFG V ISP V ORG MT ORG USER
Routine inspection (6.2)

X

Advanced inspection (6.3)

X

X

X

X

Complete liner inspection (6.4)

X

X

X

X

Routine cleaning (7.2)

X

Advanced cleaning and decontamination (7.3)

X

X

X

X

Basic repair (8.2, 8.3)

X

X

X

X

Advanced repair (8.2, 8.4)

X

X

X

Training provider

X

X

MFG: Element manufacturer. V ISP: Verified ISP. V ORG: Verified organization. MT ORG: Manufacturer- trained organization. USER: End User

 

 CHAPTER 5 :  SELECTION

  • A new category was added to the list of hazards that can be encountered by fire fighters for the purpose of risk assessment:  Specific physical areas of operation. This new requirement includes an annex item that provides an example for consideration: consider whether the hazard likely to be encountered includes the possibility of fire fighters being struck by vehicular traffic. The annex goes on to explain that the high-visibility materials required on fire fighter PPE effectively enhance visual conspicuity during the variety of fire ground operations and that the continuous use of high- visibility garments is one component of a strategy to mitigate risks from struck-by hazards, which are known to cause serious fire fighter injuries and fatalities on an annual basis. Additional high- visibility requirements for fire fighters on or near roadways are regulated by the Federal Highway Administration’s Manual on Uniform Traffic Control Devices (MUTCD, 2009 version).  It is the responsibility of the authority having jurisdiction (AHJ) to specify appropriate high-visibility apparel from the available garment options, if any, and based on a risk assessment, to establish policies for use in accordance with prevailing regulations (the MUTCD) and in compliance with applicable standards (e.g., NFPA 1971, Standard on Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting, ANSI/ISEA 107, ANSI/ISEA 207).

CHAPTER 6 :  INSPECTION

  • The term upon issue has been added to the routine inspection required to be done by each member of the fire department, so that the requirement now says “after each wearing” and “upon issue” to address the fact that some gear is re-issued. This requirement is applicable to all ensemble elements including interface components.
  • A new addition to the proximity routine inspection is to check for delamination of the outer shell.
    • This edition of the standard removed the word steel in conjunction with items to inspect for in footwear toes or midsoles for boots, since we now have high performance composite layers that no longer rely upon steel.
    • 2014 edition clarified that a manufacturer could do advanced inspection; although this had been the practice, this was intended to ensure there was no question as to who could do what.
    • Although being done in practice and fairly well understood, the 2014 edition spells out that a complete liner inspection is allowed to take the place of the light evaluation and the cup testing.
      • A verified organization does not need any written verification of training in order to perform complete liner inspection.
      • Inspecting for label integrity and legibility was formerly only in garments but was added to every element covered by NFPA 1971 (i.e. coats, pants, helmets, hoods, gloves, and footwear).

CHAPTER 7:  CLEANING

  • In the 2008 edition, there was no provision for an ISP to be verified for cleaning, so any outside cleaner could be used if they followed the cleaning dictates of 1851. With 2014, outside cleaning can only be done by a verified ISP.
  • Under the 2014 edition, the only outside cleaning that can be done is by a Verified ISP and they must still demonstrate to the organizations satisfaction that procedures do not compromise performance.
  • Formerly the advanced cleaning was done by either a verified ISP or the organization’s trained personnel. This did not change but the requirement is more clearly spelled out to include that the garment manufacturer can perform advanced cleaning without being verified.
  • The standard now allows a verified ISP and the organization to decide the necessary level of training, without consulting the manufacturer.
  • In the 2014 revision, verified organizations can decide the level of training they feel is necessary to perform advanced cleaning without the need for any written verification.

CHAPTER 8:  REPAIRS

  • In the 2008 edition, basic repairs could be performed by any ISP; with the 2014 edition in order to qualify as an ISP under requirements of 1851, any ISP must be verified even for basic repairs.
    • Training provided by AN element manufacturer, not THE manufacturer. This is to allow for training to be by only one manufacturer, not all. However, it may still be advantageous to the organization to consult with their own manufacturer.
    • The big change, once again, is that there is no such thing as a non-verified ISP; in order to be an ISP in accordance with 1851, you must be verified.
    • Repairs of minor tears, char marks, ember burns, and abraded areas limited to where area can be covered by 160 cm² (25 in²) patch. The 2008 standard said repair area could not exceed 32cm² (5 in²).
    • A new requirement for moisture barrier repair was added: Where moisture barrier tears, holes, or abrasions are being repaired, a single width of seam tape shall be used and is required to extend at least 12.5 mm (1/2 in.) in all directions beyond the edge of the repaired damage. Where the area to be repaired measures more than 12.5 mm (1/2 in.) in diameter in any direction, or is a tear greater than 75 mm (3 in.) in length, a patch consisting of the same moisture barrier fabric shall be used for repair.
  • The 2014 edition requires that restitching of more than 1 continuous inch of a Major A or Major B seam shall require consulting the garment element manufacturer and shall be conducted in a manner consistent with the garment element manufacturer’s methods. This is the same requirement found in the 2008 edition, but that edition also included an alternative to consulting the manufacturer and that was or shall be performed by the manufacturer or by a verified ISP.
  • Another new requirement for moisture barrier repairs is that in addition to consulting the garment manufacturer, with regards to moisture barrier seams, the repair must also be done in a manner consistent with barrier manufacturer’s methods.

CHAPTER 9:  STORAGE

There are no new or revised requirements in this chapter.

CHAPTER 10:  RETIREMENT

  • The only change in text was to add references to the mandatory ten year retirement sections referencing how retired gear should be disposed of.
    • There were no exceptions to any of the ensemble elements, so the 10 year retirement, with 5 years for aluminized outer shells, is still applicable to hoods, helmets, coats, pants, gloves, and footwear.
    • The biggest concern with the 10 year mandatory retirement seems to relate to helmets, and the 10 year requirement was debated all the way up to the annual NFPA meeting.  However, it was not changed.
    • In the 2008 edition of the standard, the Technical Committee inserted language into the Annex explaining that the actual service life of ensemble elements varies depending upon the amount of use and the care they receive.  In many cases, an element will need to be retired sooner than the five or ten years mandated by the standard and this information has now been included in the introductory part of the standard, under Original and Development of NFPA 1851.

CHAPTER 11:  VERIFICATION

  • The standard now contains requirements for cleaning and inspection of garments, and includes these requirements in the verification chapter.
  • The standard allows an ISP to be verified for cleaning and inspection only; however, any ISP seeking verification for garment repairs must also be verified for cleaning and inspection.
  • The certification organization cannot issue any new verifications to the 2008 edition of the standard after August 21, 2013 and organizations and ISPs must undergo verification to the 2014 edition within 6 months of the August 21, 2013 date. All previous verifications of ISPs cease to exist on that date.
  • Where the certification listing includes the moisture barrier repair category, the listing must also include the moisture barrier manufacturer and trade name designation.
    • For verification of the organization’s or ISP’s services, the certification organization must conduct both inspection and testing.
    • For verification of advanced cleaning services, the certification organization must evaluate the organization’s or ISP’s procedures.
    • For verification of advanced inspection services, the certification organization must evaluate the organization’s or ISP’s procedures.
    • The certification organization must be notified if the verified organization or ISP changes the designated person.

CHAPTER 12: TESTING

  • The only change to the testing section is to the Light Test and that change is under Results. The change is that to further investigate a suspected area [of the quilt batt] of shifting or migration, a complete liner inspection shall be performed. In the 2008 edition, an advanced inspection was done to further investigate a suspect area.

Compared to prior revisions, these revisions are minimal and are primarily driven by fire department members of the committee who seek to ensure firefighter member safety with the equipment and tools that they wear and use.

Be safe!

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