As with other fire service standards, the National Fire Protection Association (NFPA) is undertaking consolidation of different standards to aid in how different topics are addressed across the formerly 100+ standards that impact firefighters. In this case, work has been ongoing for the past several years on NFPA 1850, which combines the requirements for selection, care and maintenance of both protective clothing (now covered in NFPA 1851) and SCBA that has been found in NFPA 1852. The standard is currently moving forward where the respective technical committees have nearly finished the second drafts for their portions of the consolidated standard. It is expected that the new standard could issue as early as April or as late as September 2025.
Selection, care and maintenance practices are becoming increasingly more important for firefighter PPE, partly due to broader awareness for minimizing contaminant transfer to firefighters, but also due to the fact that many items are becoming more complex and questions still abound relative to individual product service life and continued performance. Several parts of the new standard for clothing and SCBA will impact these areas. While the standard is not yet fully finished, this article provides a preview of some of the key expected changes.
NEW PPE PROGRAM AND SELECTION APPROACHES
Within the NFPA 1852 standard and as a general practice for SCBA, specific responsibilities have been in place for a technician, who is an individual that is qualified and authorized by the SCBA manufacturer to provide care and maintenance of SCBA that includes performing inspection, repair, and testing beyond normal competency levels for individual firefighters. The NFPA 1852 requirements remain unchanged in this regard. However, for protective clothing, new categories for a PPC (personal protective clothing) manager and technician have been defined within the portion of the consolidated standard that addresses protective clothing. This change has come about to address a long-standing need for fire departments to have specially trained individuals with minimum levels of competence for addressing some of the details for increasingly more complex protective clothing items, especially as related to how they are cleaned and repaired.
The proposed NFPA 1851 portion of the standard provides flexible requirements that allow departments with varying resources to accomplish how these roles may be fulfilled. Additional information is provided in a non-mandatory annex of the new standard to assist as a starting point for how departments can set up their own specific PPC programs around these criteria. A separate annex also identifies the individual areas of responsibility that apply to the PPC Manager and PPC Technician.
The importance of training with respect to different groups providing guidance to firefighters and fire departments is also being addressed. Historically, protective clothing manufacturers have been empowered by the standard to provide this training as well as verified independent service providers (ISPs). These requirements have been clarified as to which entities are qualified to provide training in different aspects of selection, care, and maintenance. NFPA 1850 stipulates that training be provided within one year following the issuance of NFPA 1850.
The hazard/risk assessment portion of the standard has been supplemented to provide additional guidance to fire departments. Much of this guidance has been moved to a separate informative annex that helps instruct fire departments on how they can make decisions when selecting gear. There is also new information related to how departments can manage providing replacement clothing when gear is taken out of service for cleaning and decontamination.
In the area of turnout clothing selection, there is a new requirement to consider restricted substances and the compliance of PPE with state/local regulations as part of the selection process. These criteria have become pertinent as the new NFPA 1970, issued in late September 2024, now mandates that certain toxic or hazardous substances (e.g., formaldehyde) in key materials used in the construction of turnout clothing not exceed maximum levels through independent testing. To further address this topic, the proposed new standard also recommends that clothing be subjected to advanced cleaning before being issued to individual firefighters. This recommendation is being made to remove any residues on clothing that occur in its manufacture.
The NFPA 1852 part of the standard will now require more robust fire department standard operating procedures with respect to inspection and the various forms of cleaning and decontamination, including the use of preliminary exposure reduction as part of an on-scene means for reducing exterior contamination following exposures during structural firefighting.
A somewhat different approach is being applied for indicating how prior edition SCBA remain serviceable. In the past, NFPA 1852 indicated those editions of the standard for which the SCBA are certified and allowed these SCBA to still be used. Clarifications in the proposed new requirements promote retirement of SCBA following 15 years after the date of manufacture unless upgrades are performed. Nevertheless, different provisions are being made by which SCBA certified to earlier editions of NFPA 1981 can be allowed to stay in service if the department upgrades their fleet to new editions via an NFPA upgrade kit. Depending on the number of upgrades that have been applied to new editions, some older edition SCBA can have their service life extended for approximately 20 years after the year of manufacture, depending on the specific edition of the SCBA product standard used for certification.
Some of the fire service will be disappointed that there has been no change in the mandatory 10-year retirement requirement for NFPA 1971 compliant protective clothing. Every time this topic comes up, there is considerable debate within the committee as to whether to permit an extended service life past 10 years based on certain factors, such as the amount of clothing use or nonuse and if specific techniques are available to evaluate whether item service life can be extended. No agreements were reached in this area and therefore the requirements remain essentially unchanged.
EXPANSION OF CLEANING AND DECONTAMINATION PROCEDURES
As with the last edition of NFPA 1851, a substantial amount of the revision activity was focused on addressing cleaning and decontamination of turnout clothing. A number of changes were specifically proposed to enable more modern cleaning methods to be applied to different elements of clothing or to identify parameters that could improve contaminant removal efficiency. For example, some elements of turnout clothing were originally only indicated for handwashing. The new edition of the standard will recognize existing or emerging machine-based cleaning/decontamination technology so that these procedures can be more easily implemented, when available and when found not to damage the clothing. Not only have liquefied carbon dioxide cleaning procedures made their way into the marketplace since the last edition, but so has other machines that are capable of cleaning items such as helmets and SCBA. Specific to SCBA, provisions now exist where specific types of machine cleaning can be performed if approved by the respective SCBA manufacturer.
A very large change that has occurred for cleaning clothing has been raising the maximum wash temperature for advanced cleaning from 105°F to 120°F. Previously, there had been some resistance to increasing the temperature because of concerns related to the durability of certain components on protective clothing. Many of those concerns have been allayed and it is well-established that a 15°F increase in temperature can significantly improve removal of certain contaminants. Part of the advanced cleaning procedures also now include a maximum limit on water hardness. When excessive, high levels of water hardness can diminish cleaning effectiveness. The need to routinely clean and disinfect washer/extractors will also now be a requirement, as well as monitoring federal, state and local requirements for the discharge of wastewater, or other effluent from the cleaning process.
The matrix for determining when to apply the different cleaning/decontamination approaches has also been updated, principally to address lithium-ion battery fires originating from vehicles or storage facilities as a form of specialized cleaning, depending on the circumstances of exposure for the engaged firefighters and their PPE. A placeholder has also been put in for this topic to provide more extensive requirements and guidance information into the standards once research yields findings that help establish best practices for any of the unique contaminants associated with these fires and related events.
The NFPA 1852 portions of the new consolidated standard have further been aligned with NFPA 1851 for using the same terminology related to primary exposure reduction, advanced cleaning, sanitization or disinfection and specialized cleaning. The consolidation of both standards is perceived as one of the ways that cleaning approaches is being harmonized among the different types of PPE that require cleaning and decontamination.
UPDATED INSPECTION, REPAIR, AND STORAGE PROCEDURES
More robust requirements have been set for protecting individuals that must handle and clean various forms of contaminated fire service PPE. The new provisions are more specific as to the types of gloves, face/eye protection, protective clothing, and respirators, where warranted, for personnel that engage in inspecting and cleaning clothing that has not yet been subject to advanced or specialized cleaning.
With the addition of the PPC Manager and Technician roles within the NFPA 1851 part of the consolidated standard, fire departments will be required to ensure that advanced inspection and advanced cleaning will be performed by trained individuals. New inspection details are further provided for some the elements and are augmented by simple tests that can help evaluate the continued barrier qualities of gloves, footwear and particulate blocking hoods. Some additional clarifications have been added to the types of repairs that can be undertaken by fire departments versus those by a verified ISP, manufacturer or other qualified facility.
Different approaches are now prescribed for storing protective clothing, whether on duty, off-duty or for transport to an ISP or verified cleaning facility. The new requirements are intended to help minimize continued exposure to personnel by having them isolated from firefighters in practical ways until needed for use.
IMPROVEMENT AND ADVANCEMENT OF CLEANING/DECONTAMINATION VERIFICATION
A pivotal part of the new 2020 edition for NFPA 1851 was the establishment of verification for ISPs and other facilities for cleaning of firefighter protective clothing. These procedures that are now nearly 3 years into their implementation have resulted in the verification of over 80 different facilities in North America with a couple in other continents. The verification process conducted by independent certification organizations, including Intertek Testing Services and UL Solutions, has established accountability for commercial organizations that provide inspection, cleaning and repair of firefighter PPE. Cleaning effectiveness against representative contaminants is quantitatively verified.
A large part of the discussion for cleaning verification for the new edition was whether to increase the current minimum effectiveness requirement for certain organic and heavy metal contaminants from 50% to 70%. However, that change was not undertaken because of a number of other revisions affecting the verification procedures and changes in permissible cleaning parameters that made it difficult to judge whether the higher efficiencies could be achieved. While an increased level of decontamination effectiveness is not being added at this time, this topic remains an area of keen interest for the committee to address in the near term future. Still, the new standard will require greater disclosure of cleaning effectiveness information from the different facilities that become verified under the new standard.
In the new proposed edition of NFPA 1850, changes are being sought to streamline the verification process that make it both more precise and accessible to different organizations. Furthermore, verification has been extended in a number of different ways for assessing cleaning of different garment material layers beyond the outer shell as well as hoods. For example, separate optional verification procedures have been established for removing the highly hazardous and persistent polycyclic aromatic hydrocarbons (PAHs) encountered in nearly all fires and certain PFAS chemicals. Optional procedures have also been added to assess the impact of repeated cleaning on gear in terms of how a specific process can degrade performance properties over a large number of cleaning cycles. Lastly, placeholders have been put into the standard for verification to address lithium-ion battery fire contaminants and the means for simulating certain fireground contamination from small-scale burn tests.
OVERALL DIRECTION AND IMPLEMENTATION
As indicated in the introduction, the new consolidated NFPA 1850 is expected to be promulgated late spring or summer of 2025. The technical committees responsible for the standard have yet to ratify all the changes that have been proposed as part of the near final draft. Nevertheless, the process will conclude in early 2025 and there still will be an opportunity for any additional consideration for the proposed changes through an open, public process that the NFPA permits for completing any standard. Moreover, there is an expectation that certain amendments may be proposed in parallel to either update or clarify some of the new proposed content going into the standard. Regardless, the majority of end users that have been involved in the revision process feel that the advancements being made in the areas of selection, care and maintenance for firefighter PPE are likely to promote their health and safety within the fire service. In about another year, the final revised standard should start to have positive impacts on firefighters.
