Many firefighters have been engaged in debates and discussions around the situation currently unfolding with NFPA 1970, the new standard that is intended to blend four existing separate standards into a single standard that encompasses structural/proximity firefighter protective clothing, station/work uniforms, SBCA and PASS devices.
In 2019, the NFPA embarked on a consolidation process to take approximately 100 standards and reduce that number by two-thirds. So far, this approach has had mixed results. There are a couple cases where it has worked out quite well, such is the combination of all hazmat and CBRN PPE standards into a new NFPA 1990 two years ago. Similarly, the hazmat/CBRN training standards were also blended into a new NFPA 470 standard at about the same time. But other experiences have shown some problems with the consolidation approach, which, for certain divisive topics, has made it difficult for the NFPA consensus process to work.
The NFPA process
The process of standard revision starts with soliciting public input for the initial review of an existing standard. The responsible committee then reviews these public inputs and decides which ones to incorporate, modify or reject, creating a first draft. This proposed version of the standard then goes out for public comment and essentially, the process repeats itself. The result is a second draft. For individuals or organizations that may not be satisfied with the work completed by the committee, there is still an opportunity to submit what NFPA calls a “notice of intent to make a motion” (commonly referred to as a NITMAM) at its annual technical meeting.
The technical meeting is where the entire association, consisting of official (generally paying) NFPA members, meets to vote on issues brought up in NITMAMs for proposed new or revised standards. When certified by NFPA as being implementable, NITMAMs become “certified amending motions.” The submitter makes the motion, and there is an ensuing debate where individuals attending the meeting can speak for or against the motion. At the conclusion of the debate, a vote is taken, and the majority prevails.
Voting is permitted by anyone with NFPA membership that is present at the annual technical meeting whether knowledgeable in the topic or not. If these motions are approved, then the requested change can reverse decisions made by the respective technical committee. It is a unique process, but one that the NFPA believes provides a full opportunity for anyone to challenge the advancement of a new or revised standard.
NFPA 1970 NITMAMs
In the case of NFPA 1970, 14 NITMAMs were brought forward as certified amending motions on a wide range of topics primarily related to turnout gear but also SCBA. This was considered a large number, and certainly in the area of PPE, has been the largest number submitted since the NITMAM process was instituted. While 12 of those 14 motions addressed very specific topics, the other two were highly consequential. These two motions, if successful, would have returned the entire NFPA1970 standard to the committees to be reworked. Unfortunately, while this is considered a viable motion, the submitter does not have to disclose their reasoning for the motion. The effect would be an 18-month delay of the standard. Without knowing the relevant topic(s) in advance, defending against this motion is difficult, especially when one may not learn the reasons for the proposed action until the submitter steps up to the microphone to make their motion.
The June 20, 2024, technical meeting, was expected to take a couple hours, as there were 14 motions to address; however, it only took 15 to 20 minutes. This was because individuals on both sides of the various issues got together before the motions were formally made to identify compromises or examine ways where any of the submitters could be satisfied without having to make their motions. Thus, 13 of the 14 motions were withdrawn in this fashion. For the single remaining motion, an agreement was reached before the session where a new amendment to the standard would be put forward at a later time to address the specific issue of concern brought up by the submitter. Thus, even though the submitter made their motion and a committee member spoke in opposition to the motion, the committee member also suggested the pre-agreed amendment, which then allowed the submitter to effectively withdraw the motion by asking NFPA members to vote against that very same motion. This meant that no changes were made as a result of this later portion of the NFPA standards development process.
[Watch an on-demand webinar detailing some of the specific proposed changes to PPE standards.]
This outcome seemingly dispensed with the concern that the new standard would be delayed. This potential delay has been causing consternation in the fire service and broader PPE industry because of the uncertainty around when the standard would issue (in August 2024 or perhaps 18 to 24 months later). This uncertainty affects PPE manufacturers that are trying to prepare products for being certified to the new standard, which in turn requires that they discontinue existing products that would no longer comply. This is in addition to fire departments being affected by potentially putting off purchases, waiting to have equipment meet the new standard when available. Consequently, this situation could have created an unnatural hiatus in getting up-to-date PPE out to the fire service.
Other changes to NFPA 1970 afoot
What is not known to most in the industry is that several new amendments have been proposed to NFPA 1970 before it’s published. The NFPA refers to these as tentative interim amendments (TIAs). TIAs generally apply specific “fixes” to a standard after it has been issued. However, in this case, several TIAs have been preemptively proposed to address several areas in the new NFPA 1970 standard that needed further work or had problems to make the standard implementable. If accepted, the new standard would be printed with these amendments already incorporated.
The proposed amendments are considered critical because they are designed to create further consensus for some of the highly debated areas involving new criteria or test methods that have been introduced for turnout gear. These amendments include:
- Clarified optional requirements that allow a PPE manufacturer to make a claim that their specific product contains acceptable limit of PFAS is based on a standardized test method (TIA 1792).
- Updated requirements and test methods that address the major turnout gear components being measured for specific PFAS chemicals, as well as hundreds of other substances that are restricted for use in textile products such as certain flame retardants, heavy metals and various other substances that are controlled in manufacturing (TIA 1793).
- Correcting several new hood design and performance requirements as well as the associated test methods that were later found to be unworkable as manufacturers investigated the application of these new criteria to their products (TIA 1788).
- Instituting an alternative test for measuring blood-borne pathogen protection provided by protective garments (TIA 1789).
- Clarifying a new “report only” test method for measuring outer shell flame resistance following exposure to diesel fuel and being cleaned (TIA 1787).
- Reinstating the UV light degradation test but in a manner that more appropriately represents the way that clothing would be exposed in use instead of the previous method that was considered questionable by several organizations (TIA 1791).
- Reverting to having hoods provide optional protective blocking performance rather than mandating that all hoods have such capabilities (TIA 1785).
- Shortening the grace period for manufacturers to become compliant with the new edition of the standard from 18 months to 12 months, which would make newer technology available to the fire service earlier than originally specified (TIA 1786).
- Fixing the number of other errors, omissions or other problems within the standard that would have created challenges for its implementation (TIA 1790).
The submission of these amendments during May 2024 helped set the stage for many of the technical meeting-certified amending motions to be withdrawn since additional attention was brought to these areas within the proposed revised standard. Some amendments were also required to address issues caused by consolidation.
Further input needed
The above amendments are also subject to their own approval process, which involves voting at the committee and correlating committee levels, as well as being open for public comment. The latter process is one that firefighters and other interested parties can weigh in on. The NFPA facilitates this process by allowing individuals to provide comments either in support of or against specific amendments. The amendments, which include both the proposed additional changes to the standard as well as substantiation statements, are available at the following links on the NFPA website:
- NFPA 1970 – Proposed TIA Nos. 1786, 1787, 1788, 1789, 1791, 1795, 1796, and 1797 (proposed 2025 edition); comment closing date: July 24, 2024
- NFPA 1970 – Proposed TIA Nos. 1785, 1792 and 1793 (proposed 2025 edition); comment closing date: July 26, 2024
- NFPA 1970 – Proposed TIA No. 1790 (proposed 2025 edition); comment closing date: July 31, 2024
Click on the specific TIA to launch a comment button where you can email the NFPA your feedback or attach a letter. The public comments plus the voting outcome of the individual ballots for each TIA are reviewed by the NFPA Standards Council, which ultimately makes the decision to issue or not issue each amendment.
In addition to the public comments and the committee voting records, individuals can request hearings or ask for appeals on TIAs before the Standards Council make a decision.
Outcome
The standards development process can be complicated but has an enormous impact on the PPE used to protect firefighters from a range of different exposure threats. Getting the standard “correct” can significantly change the provided protection. Hopefully, with the committees’ work combined with feedback from various individuals both inside and outside the process, the quality of the standard can be appreciated and ultimately lead to improved firefighter health and safety – but this outcome can only be achieved if the standard is approved and issued.
Watch: Stull discusses the PPE standards change process
Note: The views of the author do not necessarily reflect those of the sponsor.
