By Jeffrey and Grace Stull
Likely the most controversial of all changes that went into the new NFPA 1970: Standard on Protective Ensembles for Structural and Proximity Firefighting, Work Apparel, Open-Circuit Self-Contained Breathing Apparatus (SCBA) for Emergency Services, and Personal Alert Safety Systems (PASS) involves per- and polyfluorinated alky substances (PFAS) and restricted substances. PFAS became a serious topic related to firefighter protective clothing beginning in 2018, following the approval of the 2018 edition of NFPA 1971 – the original standard on protective ensembles for structural and proximity firefighting. At that time, PFAS in turnout clothing was an emerging issue, as individual states were ramping up legislation to mandate at least the disclosure of PFAS in PPE.
Moreover, substances other than PFAS had come under scrutiny over the years for their use in protective clothing; this includes heavy metals like antimony, various brominated and chlorinated fire retardants, plasticizers such as phthalates, and other chemicals that are considered to represent human health and environmental concerns when used in excess in materials and components. The ensuing positions taken by state governments, some fire departments, trade organizations and individual firefighters drove this topic to be addressed in standards.
PFAS requirements in NFPA 1970
NFPA 1970 handles PFAS in two ways:
- An optional labeling requirement permits manufacturers of turnout clothing products to make a claim about limited PFAS in their product. This claim is based on independent testing of key materials used in the construction of the item.
- Separate requirements mandate that manufacturer suppliers have their materials and components independently tested for certain PFAS chemicals. The respective materials and components can only be used in the manufacturer of the clothing item when the respective materials and components are shown to be absent or at very low levels of PFAS.
The optional labeling requirement appears in the following form: “THIS [type of protective element] UPON CERTIFICATION HAS A PFAS (TOTAL FLUORINE) CONCENTRATION OF NO MORE THAN 100 PPM.”
Of note is the fact that the statement does not say “PFAS free” or “No intentionally PFAS added to the product.” These omissions were intentional for several reasons:
- There is no current standardized methodology by which all 10,000+ PFAS chemicals can be analyzed and quantified. This is because there is such a range of different PFAS chemicals that no single analytical technique is capable of their measurement. There are only 100 or so standards for specific quantification of PFAS using appropriate measurement approaches. Some types of PFAS, particularly polymers that are part of moisture barrier films that have historically included PFAS, cannot be directly measured. Instead, the total amount of PFAS in a given material or component is based on the proxy measurement of total fluorine.
- To date, the only commonly available means for representing total PFAS in a solid sample has been the use of equipment called combustion iron chromatography where the sample is fully burned and decomposed into its various atoms allowing the determination of how many of those atoms are fluorine. If the assumption is made that any fluorine atoms are associated with PFAS chemicals, then an overall value can be assigned to that particular material or component. The shortcoming of this analytical technique is that some fluorine may not be associated with PFAS chemicals and instead includes other types of fluorine, such as fluoride, a common component found in toothpaste and drinking water. Thus, the total fluorine number may over-report the actual level of PFAS in the product.
- Claiming a product is “PFAS free” is also misnomer because PFAS contamination has become so ubiquitous where very small levels can be found in many products even when not intentionally added. The sources of these residual PFAS levels might include certain raw materials that can be contaminated with PFAS that was not added, some processes for textiles using water that can contain PFAS, and machinery that has PFAS that can contaminate products during the fabrication process.
- The 100-ppm limitation is based on what is considered to be the most significant constraint for PFAS in a range of textile products, including apparel from the California, which, beginning this year (2025), limits total organic fluorine to a level of 100 ppm. According to the same state regulations, that limit will be reduced to 50 ppm in early 2028. Even when a manufacturer cannot or chooses not to make a PFAS-related claim under NFPA 1970, the manufacturer material/component supplier is still obliged to report the total fluorine level.
PFAS has been historically used in two ways for turnout clothing:
- First, as a durable water repellent (DWR) on outer shells, some moisture barriers, and for some other material components. It has also had limited use in very few thermal barriers and other textile components.
- Second, it has been the backbone functional polymer barrier film in the form of expanded polytetrafluoroethylene (ePTFE) for garment moisture barriers and barriers in many gloves and footwear products.
Its use as a DWR on outer shells and thermal barriers has been generally phased out over the past few years by current material suppliers and garment manufacturers. This transition is also occurring in moisture-barrier technology with the introduction of a few moisture barriers during 2024 that no longer rely on ePTFE. With the new requirements in NFPA 1970, along with other changes being addressed by industry, it is expected that additional moisture-barrier materials will be offered that do not rely on PFAS.
It is important to understand that only key materials are evaluated from respective products, and some materials have been excluded altogether. Right now, NFPA 1970 focuses mainly on the major textile-based materials found in each of the five different elements of the ensemble – garments, helmets, gloves, footwear and hoods. Certain materials, such as leather and some plastics, are excluded. This is mainly because effective methods for their characterization for PFAS levels has not yet been established.
An important takeaway from the PFAS restrictions in NFPA 1970 is that manufacturers will still be able to sell PFAS-containing products, though some of the substances will be restricted to very low levels, and manufacturers can make a non-PFAS product claim only when demonstrated. The most important accomplishment in this approach for standardizing this topic is that manufacturers and material/component suppliers are now being held accountable through required independent verification in conjunction with the certification process.
Other restricted substances
PFAS represents only one category of restricted substances that are being addressed in NFPA 1970. To be more proactive in the safety of gear to the wearer, the new standard also provides for the limitations of hundreds of other chemicals used in textile-based products for apparel. This application is nothing new in the textile industry and, in fact, some companies for years have voluntarily complied with requirements set by specific restricted substance list. These lists arise from a variety of sources globally, focused on the health and safety of products, and address the entire service life of materials, not only in the use, but also in their origin and ultimate recycling or disposal. Table 1 provides the major categories of restricted substances. There are hundreds of chemicals that warrant this level of scrutiny, with the understanding that turnout clothing, unlike much of the consumer apparel, is subject to many rigors of environmental exposure, including repeatedly high heat, UV light, liquid exposure, wear and tear, and laundering.
The application of other restricted substance requirements works similarly to PFAS chemicals, using the following approach:
- Specific categories and individual chemicals are identified as part of an overall restricted substance list (RSL);
- Material and component suppliers submit their materials to an independent testing laboratory that evaluates supplier products for levels of restricted substances against the limitation requirements in NFPA 1970 using specific or equivalent test methods;
- The independent testing laboratory (what NFPA 1970 refers to as an “attestation” organization) reports the test results for the relevant restricted substances and provide a certificate that states that the restricted substance limitations established in NFPA 1970 have been met;
- For the material and components that are subject to this requirement, end-product manufacturers can only use materials and components that have attestation certificates; and
- If a supplier does not choose to comply with these requirements, the end-product manufacturer can undertake the testing through the attestation organization on their own to permit use of the material.
RSL requirements are complicated because they comprise a variety of chemical oversight practices established by various groups including regulatory authorities in North America, Europe and globally. Fortunately, these requirements have been made easier with the creation of standard RSLs by a couple of organizations. One of those organizations is the Hohenstein Institute, which sets its own RSL standards – OEKO-TEX Standard 100 and OEKO-TEX PPE Supplement. The NFPA task group that put together the RSL requirements pertaining to turnout clothing relied on the 2024 editions of both standards, along with information from a separate RSL known as AFFIRM that is very similar, but not identical, from the American Apparel and Footwear Association. Both organizations are active in keeping their RSLs up to date.
Naturally, given the newness of these requirements, many questions have arisen about restricted substances, particularly how they are identified, how limits are set, and how testing is carried out to ascertain compliance with RSL. In essence, both organizations offer details on how their respective RSLs were developed and are updated. Hohenstein Institute is one attestation organization for which two principal turnout clothing certifications organizations (Safety Equipment Institute and UL Solutions) are accepting material or component attestation certificates for NFPA 1970 restricted substance requirements. Yet, because NFPA 1970 does not indicate the use of a specific attestation organization or laboratory, these requirements can also be demonstrated by other organizations.
Overall industry impact
The new NFPA 1970 standard is expected to have significant impact on available turnout clothing products beginning in 2025. It is likely that PFAS and other restricted substance requirements could filter out some current materials that, in turn, affect prior existing clothing products. On the other hand, the fire service will now have a level of awareness for what goes into their gear. With the ever-increasing number of chemicals coming under scrutiny, many firefighters will appreciate how the new requirements attempt to proactively address this topic as it pertains to the manufacture of gear.
Multiple other changes have been made to protective elements, for example, the mandate for particulate-blocking hoods for structural firefighting as well as a series of new requirements that further affect the different parts of the protective ensemble. Regardless of the perception of what these changes mean to the fire service, the turnout clothing is entering a new age where a new series of tradeoffs are now becoming part of the selection process.
ABOUT THE AUTHORS
Jeffrey and Grace Stull are president and vice president, respectively, of International Personnel Protection, Inc. They are members of several NFPA committees on PPE as well as the ASTM International committee on protective clothing. Mr. Stull was formerly the convener for international work groups on heat/thermal protection and hazardous materials PPE as well as the lead U.S. delegate for International Standards Organization Technical Committee 94/Subcommittees on Protective Clothing and Firefighter PPE. They participate in the Interagency Board for Equipment Standardization and Interoperability and have authored the book, “PPE Made Easy.” Send questions or feedback to the Stulls via email.