NFPA 1851: Clean Thinking By Dan Haden and Greg Nicoll

Author - fireservice@admin

Unfortunately, it’s a problem. While we are now protecting firefighters with the latest and most technologically advanced Personal Protective Equipment (PPE), we probably haven’t done a very good job…

of also conveying ‘it must be clean to be protective’. The message now is broader in scope: The ‘shield of armour’ that is comprised of all the elements in our PPE must be selected and maintained properly to be effective in continuing to save our lives. It’s really that simple.

Since our first articles on this topic almost four years ago, the National Fire Protection Association (NFPA) has developed and recently passed the NFPA 1851 Standard on Selection, Care, and Maintenance of Structural Fire Fighting Protective Ensembles, 2001 Edition., commonly being called the ‘SCAM’ document, in reference to “selection, care and maintenance.” However you refer to it, thanks to NFPA, the experts who made up the committee(s) and those who voted in favour of the standard, our fire services now have a clearer safety mandate.

An Overall Program

To comply with NFPA 1851, fire departments must develop a program for “…selection, care and maintenance of structural fire fighting ensembles and … elements,” which includes coats, trousers, coveralls, helmets, gloves, boots, etc. (accessories, such as belts, harnesses, radios, lights, etc., are not permitted unless they are certified in accordance with NFPA 1971 Standard on Protective Ensemble for Structural Fire Fighting, or the fire department has the particular equipment manufacturer’s approval). ‘Turnout gear’ or ‘bunker gear’ is referred to in the standard as an “ensemble.” The ensemble consists of “elements” including coats, trousers, coveralls, helmets, gloves, footwear, and interface (with other protective equipment) components. We have used the terms interchangeably.

If the department has an overall program for turnouts and protective equipment, the SCAM portion must be guided by standard operating procedures (SOPs) that at least provide for turnout ensemble selection; inspection; cleaning and decontamination; repair; storage; and retirement, disposition, and special incident procedure.

Records

Quality record-keeping can track job practices and help respond to various issues and questions, especially those respecting liability. According to the explanatory material, “Records can be used to provide information about  … life cycle … repair and decontamination efforts and … effectiveness of elements … of different materials or … different manufacturers.” Consequently, complying fire departments must now keep program records of at least the following:

  • Person to whom element is issued
  • Date and condition when issued
  • Manufacturer and model name or design
  • Manufacturer’s identification number, lot number, or serial number
  • Month and year of manufacture
  • Date(s) of and findings of advanced inspection(s)
  • Date(s) of advanced cleaning or decontamination
  • Reason for advanced cleaning or decontamination and who performed cleaning or decontamination
  • Date(s) of repair(s), who performed repair(s), and brief description of any repair(s)
  • Date of retirement
  • Date and method of disposal.

Selection of PPE

Although NFPA 1851 avoids narrowly constricting independent selection of structural fire fighting turnout ensembles, it does require that selection criteria include, among others; consideration of the hazards that may be faced by fire fighters and which are identified by a properly completed risk assessment; how ensembles and elements interface with other protective equipment that is or may be used by fire fighters; third-party compliance with NFPA 1971 Standard on Protective Ensemble for Structural Fire Fighting and; the effects of NFPA 1500 Standard on Fire Department Occupational Safety and Health Program, NFPA 600 Standard on Industrial Fire Brigades and applicable occupational safety and health legislation – although the applicability of federal and provincial Canadian legislation is implied from reference to similar US policy.

It’s recommended that decisions respecting the selection of turnout clothing be made by a committee formed for that purpose and that the best choice for performing the risk assessment analysis is the health and safety officer.

Inspections

The bulk of NFPA 1851 deals with the care and maintenance of ensembles and elements after they are put into service. Specifically, Chapters 4, 5 and 6 provide for Inspection, Cleaning and Decontamination and Repair processes.

There are two types of inspections in NFPA 1851 – routine and advanced. The routine inspection is simpler and performed by the firefighter after each time they use their ensemble in an environment where it may become damaged or contaminated. During a routine inspection, firefighters examine their coats, trousers, hoods, helmets, gloves and footwear. In each case, the firefighter will check for soiling (non-hazardous contamination) and contamination from hazardous materials or biological agents. If a hazardous material or biological agent is discovered, the element(s) must be decontaminated before any further inspection is completed.

A routine inspection will then check for physical damage that, of course, will vary with the ensemble element. For example, when inspecting coats and trousers for physical damage pursuant to NFPA 1851, 4.2.2.1, firefighters will be check for the following:

1)      Soiling
2)      Contamination from hazardous materials or biological agents
3)      Physical damage such as the following:
         a. Rips, tears, and cuts
         b. Damaged/missing hardware and closure systems
         c. Thermal damage such as charring [brittle residue], burn holes, and melting [flowing or dripping].
4)      Damaged or missing reflective trim.

Other physical damage inspection criteria are set out for each individual element in the ensemble.

Beyond soiling, contamination and physical damage, each item may also have to be routinely inspected for damage that is likely particular to that item. Thus, firefighters will have to inspect the reflective trim on ensembles and hoods; the opening adjustment for hoods; the suspension and retention systems of helmets; elasticity/flexibility of gloves; and water resistance of footwear; to name a few.

Advanced inspections are more complex than routine inspections and intended to be carried out only by those who have been adequately trained. Advanced inspections must be performed whenever a routine inspection reveals a problem, or at least every 12 months. Advanced inspections are individually performed for all layers of garment elements; hoods; helmets; gloves; and footwear and the results are documented. As an example of how more detailed an advanced inspection is compared to a routine inspection, the following are the advanced inspection criteria for all layers of the garment elements;

1)      Soiling

2)      Contamination from hazardous materials or biological agents

3)      Physical damage to all layers, such as the following:

a.      Rips, tears, cuts and abrasions

b.     Damaged/missing hardware

c.      Thermal damage such as charring [brittle residue], burn holes, melting [flowing or dripping], or discoloration of any layer.

4)      Loss of moisture barrier integrity as indicated by:

a.      Rips, tears, cuts, and abrasions

b.     Discoloration

c.      Thermal damage

5)      Evaluation of system fit and coat/trouser overlap

6)      Loss of seam integrity; broken or missing stitches

7)      Material integrity: UV or chemical degradation, loss of liner material, shifting of liner material

8)      Wristlets: loss of elasticity, stretching, runs, cuts, burn holes

9)      Reflective trim integrity, attachment to garment, reflectivity, damage

10)  Label integrity, legibility

11)  Hook and loop functionality

12)  Liner attachment systems

13)  Closure system functionality

14)  Accessories for compliance with 2.2.3

Cleaning and Decontaminating

NFPA 1851 complying fire departments will now require a process for cleaning and decontaminating firefighter ensembles. Home, public laundering, or commercial dry cleaning (unless dry cleaning is specifically approved by the manufacturer) are not acceptable for compliance with the standard.

Different elements have different cleaning protocols. We have used coats and trousers as examples thus far. In all cases of decontamination and cleaning, the standard first requires reference to the manufacturer’s label and user instructions and although it prohibits certain practices such as the use of bleach; heavy scrubbing or spraying and extreme pH levels, to name several.

There are three types of cleaning in the standard: Routine, Advanced and Specialized. A routine cleaning is simplest and performed after each use that results in soiling. Essentially, a firefighter will perform a routine cleaning at the scene by; brushing off debris; rinsing the area with water; if necessary, scrubbing the area gently and rinsing again; if necessary, spot cleaning in a sink in accordance with the detailed procedure in 5.5.6; re-inspecting; and repeating if necessary.

If, after inspection, it’s apparent that routine cleaning was insufficient, or if six months have passed and an ensemble has been used and is soiled, the standard requires that it receive advanced cleaning. After brushing off debris, a properly trained person can advance clean by either, following the utility sink procedures outlined in section 5.5.6 of the standard, following the machine washing procedures in 5.5.7 of the standard or using a contract cleaner.

Specialized cleaning is for ensembles (and elements) that are contaminated. Using universal precautions, once again a properly trained person will likely begin by removing the item from service and ‘isolating, bagging and tagging’ it. They will try to identify the contaminant and, if they are able to identify it, consult the contaminant manufacturer for decontamination advice. If they cannot get detailed manufacturer’s advice for decontamination, the items must be sent to a qualified contract cleaner for decontamination and cleaning. Presumably, where there are detailed manufacturer instructions, then those must be followed.

Where elements have been soiled with bodily fluids, decontamination and cleaning is completed using a disinfectant recommended by the ensemble/element manufacturer and either a sink as in 5.5.6., or a machine as in 5.5.7.

Drying

Traditionally, it’s been felt that the best drying procedure for fabric items is mildly forced air at slightly elevated temperatures. This was discussed in more detail in two previous articles appearing in earlier issues of FSJ. The new standard provides for various drying procedures, including ventilation and machine drying, for different ensemble elements and where there are no specific manufacturer instructions or approvals.

Repair

The repair of ensembles and elements requires proper skill and knowledge to maintain the integrity and purpose of the original product. In some cases, manufacturers may insist on independent certification. For all elements, NFPA 1851 requires repairs be made only by a properly trained person.

Generally, all repairs must “be done in a manner and using materials that are approved by the manufacturer” and the standard generally either encourages and/or requires manufacturer consultation on repairs, including seaming. ‘Major repairs’ to the outer shell and repairs to the moisture barrier may only be performed by the manufacturer or a manufacturer recognized repair facility. Although ‘major repairs’ is not specifically defined in the standard, it is implied by 6.1.16, which states that; “Repairs of minor tears, char marks, ember burns, and abraded areas shall be limited to those where the damaged area can be covered by a maximum of a 32cm2 (50 in.2) patch.

Compliance will require careful consideration of instances where a repair must be completed by a manufacturer or recognized facility, e.g. repairs to moisture barriers and major B seams, versus a requirement to at least consult, e.g., major A seams over one inch, versus a requirement only to use approved manner and material, e.g. minor repairs to thermal liners with no stitching through the moisture barrier.

The standard provides separate procedures for repair of other ensemble elements.

Storage

Chapter 7 of NFPA contains what by now should be common sense storage habits for turnout ensembles, e.g. no direct sunlight; between –40C and 82C; no sharp objects; and no solvents, hydrocarbons or other contaminants. Each of the requirements in this chapter seeks to recognize that turnout ensembles are highly specialized and technical and must be treated with care.

Retirement

There has been considerable work by a number of organizations attempting to determine criteria for retirement of turnout ensembles. Although recommendations have been made, a comprehensive list of specific criteria does not appear to be generally available.

The standard refers to four determinants: worn or damaged beyond cost effective repair; contaminated beyond cost effective cleaning and decontamination; no longer of use to the organization; and non-compliance with the NFPA standard at date of manufacture. If ensembles/elements are no longer of use, they can be utilized as the organization requires, including for non live-fire training if they are accordingly marked. In all other retirement scenarios, the ensembles/elements must either be destroyed or never used for fire fighting or emergency activities.

For ‘special incidents’ of serious fire fighter injury or fatality, departments must have procedures that at least include those in 8.3, including immediate removal from service; non-destructive tagging and storage; secure containment; and regular review.

Conclusion

Quality turnout ensembles are highly technical. That’s why they are also highly effective at ensuring health and safety.

They can, at first, represent a significant cost. However, direct and associated costs may be reduced by practices that respect the ensembles and elements as investments by the organizations. The requirements of NFPA 1851 should be seen as practices that respect turnout ensembles and elements as the investments they truly are.

The combination of proper selection methods together with regular; routine and advanced inspections, effective cleaning and decontamination procedures, professionally performed repairs and good storage habits, may increase cost effectiveness and cost/benefit ratios with respect to overall ongoing PPE expenditures. In other words, it may be more budget-wise to engage in preventative maintenance and make minor repairs more often than to let them become major repairs.

Dan Haden is Publisher of FSJ and may be contacted at 905-428-8465 or email haden@interlog.com.

Greg Nicoll is General Manager of FireService Management and may be contacted at 888 731 7377 or email greg@fireservicemanagement.com

This article is not intended to provide complete or accurate advice on the requirements of NFPA 1851.

Those requiring accurate details of the standard should refer to the standard directly. Copies are available through The Fire Services Resource Centre at 800-668-2955 or fax 905-683-9572 or www.thefirestore.ca

 Further information, including previous FSJ articles on this subject, may be viewed at www.fireservicemangement.com “The Bunker Gear Care and Maintenance Information Centre”