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PPE Update
by Jeffrey O. and Grace G. Stull
Sponsored by Globe

The debate: mandatory gear retirement at 10 years

There's one chance left to weigh in on the issue next summer in Chicago

By Jeffrey O. and Grace G. Stull

As members of the NFPA technical committee on protective clothing for structural fire fighting, we were recently notified that an individual petitioned NFPA to reconsider requiring firefighter helmets be mandatorily retired 10 years following their date of manufacture.

The 2008 edition and the proposed 2013 edition of NFPA 1851 requires that fire departments remove any gear from service that has a manufacture date more than 10 years old. Gear subject to this requirement includes garments, hoods, gloves, boots and helmets.

This petition did not surprise us as the issue had been hotly debated during the standards development process. And while there was a general consensus for both its original implementation and its continued use, it has not been a popular requirement within the fire service for many reasons.

Background on the 10-year rule
Work on NFPA 1851 actually started back in the mid-1990s when fire service safety groups, including the Southern Area Fire Equipment Research, Northern Area Fire Equipment Research, Central Area Fire Equipment Research and Fire Industry Equipment Research Organization worked on creating a publication called "PPE Care & Use Guidelines."

The publication was intended to fill a void in information for the proper selection, care, use and maintenance of turnout clothing, which was somewhat haphazardly addressed by the industry many years ago. The fire service work also became the foundation for the development of NFPA 1851.

One chapter addressed retirement and listed a number of factors for the department to consider including obvious damage and deterioration and when the cost for repairing the gear exceeded 50 percent of the replacement cost.

Nevertheless, the bulk of information in that chapter was advisory. And it emphasized that the actual service life of PPE varies with the amount of use and care, and that decisions to retire gear should be made by trained, qualified individuals.

Mandate vs advice
When the development work for NFPA 1851 started, the standard was positioned to set mandatory requirements for fire departments the same way that NFPA 1971 and other product standards set mandatory requirements for gear manufacturers.

In the case of retirement, the committee struggled with what could be mandated and what should be advisory. One solution was to require that individual departments develop their own specific criteria for when to retire PPE; while this was put into the standard, it was considered to be a relatively weak requirement.

The committee then opted to set a maximum service life for turnout gear that would be unambiguous — remove any gear from service that had a manufacture date of more than 10-years, regardless of its use, care, or actual condition. This was applied for all types of gear except aluminized outer shells found in proximity firefighter clothing that were given an expiration date of 5 years.

Certainly, the 10-year retirement life was not a conspiracy on the part of manufacturers to sell more gear, but rather an attempt to create definitive requirement for ensuring that old gear was retired. The true basis for establishing 10 years as the benchmark for retirement comes from the consideration that the NFPA 1971 standard setting requirements for turnout gear is typically revised every 5 years so that a span of 10 years would represent two revisions of the standard.

The thinking was that after 10 years, new changes in materials and testing technology, plus the implementation of new requirements, would make the PPE obsolete. This reasoning was combined with the observation that most garments last on the average 4 to 6 years before they have to be replaced for wear and tear.

Inconclusive data
While several organizations have conducted research to determine the performance of gear that has been used in the field and of various ages and conditions, no definitive conclusions are possible. We, ourselves, performed work for the U.S. Fire Administration nearly 15 years ago showing various effects of use and care on clothing material performance properties.

In some cases, we observed degradation of certain characteristics such as tear strength and water absorption resistance for shell materials. In other cases, the effects were minor. In a few rare instances we found that some properties — such as thermal protective performance — actually improved with use.

Practically all of the study work that has conducted to date has focused on garments. Very little work has been done for the other elements of the ensemble including helmets, hoods, gloves, and footwear.

We had one instance where we examined used gloves for changes in their insulative performance after use, but the findings were mixed. We also are aware of one major metropolitan fire department that evaluated a large number of helmets that were more than 10 years old for their continued impact and penetration resistance. The test results still showed all of the helmets to be compliant with the pertinent criteria for NFPA 1971.

With a few exceptions, the majority of these tests are destructive so it becomes impractical to perform many different tests that can let the department know if the protective features of the gear have become compromised.

A matter of interpretation
Then there is the matter of being able to interpret results. If the tear strength for an outer shell sample taken from a used coat comes back just a little under the minimum requirement set for that material, does it mean that coat needs to be retired?

The committee responsible for these standards attempts to make the best decisions it can with the available information, but validation information is not available in all cases. For most performance properties, there is insufficient industry research to provide clear-cut findings for determining when the safety of products is diminished to the point that they are no longer protective.

Unfortunately, no one has any solid, fail-safe advice on how to make that interpretation and the whole aspect of retirement becomes this murky, judgment-based call for whoever is responsible within the department. Some argue that the 10-year mandatory retirement obviates these judgment calls or the fact that no judgments are made at all.

The growing demise
We are aware that many fire departments are facing hard times and funds for replacement gear are not always readily available, particularly when it may seem that the gear is still serviceable and apparently safe.

Every several years, the National Fire Protection Association conducts a needs assessment for the fire service and publishes the results in a comprehensive report. The most recent report from 2011 showed the following findings with respect to PPE age and back up equipment:

  • 63 percent of departments have some personal protective clothing that is at least 10 years old, but this is down from 74 percent in 2001 and up from 59 percent in 2005.
  • 53 percent of departments do not have enough reserve personal protective clothing to equip 10 percent of emergency responders, but this is down from 62 percent in 2001 and 57 percent in 2005.

These statistics show that there is a substantial number of departments that either cannot or choose not to comply with mandatorily retiring their gear after 10 years.

Moving forward
The NFPA standards development process affords several opportunities for individuals to make proposals and recommendations to challenge existing requirements. In this case, the individual put in a public proposal to remove the 10-year mandatory retirement rule as applied to helmets from NFPA 1851 during the early stages of the revision process, which was backed up with a thorough substantiation.

After the committee rejected this proposal, the same individual responded with a comment on why the committee should reverse its direction, again with further justification. Others also provided similar proposals and comments.

After the committee has completed its revision efforts, the final chance to pursue this matter is to bring the issue before NFPA at its 2013 association technical meeting.

At that meeting, the individual will be afforded a chance to make a motion and debate will ensue from those present before a vote is taken to find if the NFPA membership agrees or not with the submitter. If they do, then the committee will be asked to vote on the same issue and the results will be brought before NFPA's standard council for the final decision.

At this point in the process, the only way to formally weigh in on this issue is to attend the technical meeting, which will be held in Chicago from June 10 to 13. Please contact us or NFPA if you have questions about this topic.

About the author

Sponsored by Globe

Jeffrey O. and Grace G. Stull are president and vice president respectively of International Personnel Protection, Inc., which provides expertise on the design, evaluation, selection and use of personnel protective clothing, equipment and related products to end users and manufacturers. They are considered amongst the leading experts in the field of personal protective equipment. Send questions or feedback to Jeff or Grace at The views of the author do not necessarily reflect those of the sponsor.

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Steven R Trotter Steven R Trotter Sunday, November 25, 2012 5:01:33 PM No a requirement. Just a recomendation. NFPA is a guide for Departments to follow, in part or hole.
Johnny Murdock Johnny Murdock Monday, November 26, 2012 12:20:06 AM NFPA. Increasingly political. Increasingly out of touch. You are trying to regulate far too much. In FF1 we must be operations qualified, but do not need to know about or use foam. I no longer have confidence in the NFPA!
Frank Svitak Frank Svitak Monday, November 26, 2012 8:59:30 AM While NFPA is NOT a requirement, it IS the accepted national standard. And with that being said, let OSHA come in during an inspection and find gear over 10 years old in service & they will fine you, WHY, because they follow the national standard, NFPA. So you wind up with it as law anyway. Just wish that they would require funding to be provided to do this. Like a lot of other small fire companies, my total operating budget fot the year is under $150,000, and that has to pay for all insurance, fuel, training, building & truck repairs, equipment, and new gear. Trying to make ends meet for an entire fire company on less than a lot of these law makers make is frustrating to say the least.
Ron Maddux Ron Maddux Monday, November 26, 2012 7:14:54 PM Working as a quarter master I have followed this very closely. I agree most of gear would last more than 10 years. However, you have to implement some type of standard if not our firefighters will not always have the best PPE. I'm very lucky we only have 40 career firefighters who are issued new gear every 4-6 year with their current gear being rolled back. Yes, I truly believe gear could last longer than 10 years but where would you set the standard?
Danny Ruckriegel Danny Ruckriegel Monday, November 26, 2012 8:29:42 PM Ron, my friend, give any real fireman his choice and we would be wearin' 3/4 boots and Fireball gloves again. Just the nature of the job. But everytime we kill a brother, its always the job's fault. We gotta protect our own. Ain't nobody hated a Scott-pak worse than myself. But in my infinate wisdom, I know my family loved it more than anyone!
Bill Snowden Bill Snowden Tuesday, November 27, 2012 1:54:08 PM While I have seen gear that didn't last a full 10 years due to use, I have also had to pull brand new gear still in the bag out of service simply because it was 10 years of age. They were never worn. I would think that when gear reaches 10 years of age, it should be given an advanced cleaning and inspection as indicated by NFPA 1851 and if it passes, it should be allowed to remain in service with re-testing being done annually thereafter. It seems truly wasteful to dispose of a $1500 set of gear that never saw a fire one!
Troy Engel Troy Engel Tuesday, November 27, 2012 2:04:49 PM Gear should be replaced when it needs replacing. We seem to go between 4 & 6 years for new turn outs. Engineers & the Chiefs seem to last alot longer.
Myron Pierce Myron Pierce Tuesday, November 27, 2012 6:00:26 PM The 10 year renew would be OK if they were given to poor VFDs.
Mark Palmer Mark Palmer Wednesday, November 28, 2012 7:08:09 AM Vendors should not sit on our NFPA committee or atleast be the minority. I would like to see admistrative officers of the fire service decide what is best for the fire service. Sounds like there is a fox in the chicken house? As chief, my number one priority is the safety of my firefighters.
Justin Hill Justin Hill Wednesday, November 28, 2012 8:06:29 AM Amazing you can regulate firefighter for profits huh?
Justin Hill Justin Hill Wednesday, November 28, 2012 8:14:25 AM No surprise firefighter safety is not the priority for the NFPA profit is! As long as the manufactures continue to write there own rules the NFPA will be joke to ff's across the nation
Johnny Cassidy Johnny Cassidy Thursday, November 29, 2012 4:30:19 AM Your right Steve, it is just a requirement, but as soon as a firefighter is killed guess what the first thing the courts are going to look at, the age of the gear and if all NFPA standards were being followed at the time of the death. I don't agree with all of NFPA because realistically there isn't many if any departments that can afford to be 100% NFPA compliant.
Rob Mullin Rob Mullin Thursday, November 29, 2012 6:13:00 AM I agree with Mr. Snowden. We also have gear that has sat on a shelf in a climate controlled stock room. If a brand new coat still in the bag is nearing the expiration date or has expired, a advanced inspection by a trained individual or send it back to the factory for a detailed inspection could suffice. I think this would eliminate firefighters working in unsafe gear. With small departments that do not have the monies to replace a new set of gear for every member, they would have another option instead of making them wear the old gear instead of replacing it.
Chris Holmes Chris Holmes Thursday, November 29, 2012 7:00:52 AM This Kills Volunteer Depts in small towns.. Its another, unfunded mandate or rule that does not follow common sense. My interior guys, who see action, their gear should be replaced sooner than support crew, engineers, exterior command crew. but to dictate 10 yrs across the board, is crazy and eats up smaller Depts budget unnessesarily..(sp )... Be real and practical.. not reactionary..
Bobby Conary Bobby Conary Thursday, November 29, 2012 8:36:53 AM yep...this will cost me more than my annual budget.
Bill Fennelly Bill Fennelly Thursday, November 29, 2012 9:20:40 AM In the old days we didnt use gear...
Steve Schumacher Steve Schumacher Thursday, November 29, 2012 11:21:47 AM chris holmes is right Im from a small vol. department and turnout gear for firefighter outside of a structre dont have to worriy about termal protection. replacement of everything there looking at would be close to $2000.00 a person this would be 2 years budgets for equiment replacement in our department. sounds like so manufactors of turnout equiment is influanceing NFPA.
Brian Clement Brian Clement Thursday, November 29, 2012 11:35:19 AM Regardless of the rule, for my crew, if your aaren't going to be inside or around the building, your gear will be replaced onan as nedded basis. There are plenty of fireground jobs where gear is needed but thermal protection isn't an issue.
Myron Pierce Myron Pierce Thursday, November 29, 2012 5:49:36 PM We are running out of two stations on less than$35,000. just fuel and training eats up all the money we have, if our gear isn't ragged we keep on going.
John Barnes John Barnes Thursday, November 29, 2012 6:27:04 PM For a busy company I can see it but maybe it should be based on number of washings etc. For small less active departments gear may last them 20 years.
Chris Holmes Chris Holmes Thursday, November 29, 2012 6:35:36 PM you hit it Jonathan, ,, you can't have your cake and eat it to... its a Catch -22...
Vince Davis Vince Davis Thursday, November 29, 2012 6:54:43 PM I agree with Mark Palmer & Frank Svitak below in that both are correct...allowing vendors (who are profit-minded) on the committee creates not only a conflict of interest, but a internal conflict for which there is no defense: as you can't deny "new" gear is better. Frank too is right that OSHA cites on the standard of the industry practices; thus they would go to NFPA standards. In the instance of a fatality, NIOSH would issue a critical report that opens the fire department to civil and/or criminal fines and/or prosecution. The better solution is a method & standard for testing turnout gear (flame, acid, I/R, other) that a firefighter could use to test their own gear if they believe it to be damaged and/or to use for an annual test. Not all firefighters are exposed to the same fire conditions or hazmats to across the board say that ALL bunker need to be replaced after 10 years. What's next, the vehicle committee to say that all fire vehicles need to be replaced every 5 years? Is that the same for FDNY's busiest company as the smallest community near where you live? Common sense needs to prevail as not only is it detrimental to many fire departments, it is wasteful. So, manufacturers of bunker gear... here's the challenge to create a method to test the integrity of bunkers. Who knows, in the end you may find that there is much more damaged gear that will need to be replaced BEFORE the 10 years. In the interim, I'll hold my breath for this one too...just like I'm waiting for a cure from the common cold as many, many over-the-counter drug companies will immediately go out of business.
Vincent Rusch Vincent Rusch Friday, November 30, 2012 6:01:24 AM Like many of their "standards" this does not take in to consideration how much wear and tear the gear gets. A budget buster for small depts. Is there an organization out there that can write standards that make sense?
John Sposato John Sposato Saturday, December 01, 2012 12:51:14 PM Another problem I see is when departments force their members to use Structural Firefighting gear for evolutions it was not designed for such as extrications and wildland fires. Using the proper gear for those evolutions should help prolong the useful life of the more expensive structural gear.
Bryan W. Waagner Bryan W. Waagner Saturday, December 01, 2012 4:45:39 PM Bill Fennelly You also didn't wear SCBAs and steamed fires with booster lines and did alot of other antiquated things that we've moved forward from. I'm not saying I agree with this 10 year replacement plan but progress must be allowed to happen or else the fire service will die.
Vincent Rusch Vincent Rusch Wednesday, December 05, 2012 12:02:37 PM Condition is more important than age.
Paul Schaecher Paul Schaecher Thursday, December 06, 2012 5:15:44 AM Bill Fennelly...In "the old days", you didn't live as long either
Dan Hinshaw Dan Hinshaw Thursday, December 06, 2012 2:32:43 PM About time. Just because the helmets are not subjected to interior fires does not mean that exposure to the sun, carbon monoxide or diesel exhaust in stations, etc. the helmet and other protective clothing are going to break down. Your personnel and their gear is first and foremost the biggest safety issue you have. Use some common sense and replace it.
Andrew Economedes Andrew Economedes Thursday, December 13, 2012 6:58:53 PM Here is my two cents-first if the gear is tested and passes why does it need to be replaced? Or for that matter why have testing. If the gear passes the testing no matter its age then it is good gear! Second, this is my thought on our future FF. The NFPA and PPE manufactures will be contributing significantly to more FF deaths. Reason is they keep making gear to hold up to higher heat which in turn translate into FF's going in deeper and not feeling the heat. If you recall articles about FF being caught in high heat situations the common statement by all is "all of sudden it got really hot". Of course it did because they couldn't feel it. We can argue about training but because of a few idiots who burned FF during training we can barely build a fire of significance due to NFPA rules. Good grief this gets me on my soap box. SO much wrong with the NFPA and our manufacturers, It is getting to be that there is no more weak link. My opinion is that the NFPA is the biggest hazard to the FF.
Derek Pollard Derek Pollard Thursday, December 13, 2012 7:02:38 PM The problem with NFPA is anybody willing to pay membership fees is a voting member! you don't even have to be related to the fire service! It has turned into a huge lobby, and not necessarily for the firefighters!
Arnold Cadena Sr. Arnold Cadena Sr. Thursday, December 13, 2012 7:44:45 PM Very true !!
Donald F. Hayde Donald F. Hayde Tuesday, April 30, 2013 7:27:02 PM I couldn't agree more with these posts. I've sat on NFPA Committees and it is was a stacked deck.The what if's are beyond the pale and the producers and salespeople are rarely the end user. The Fire Service, like the military, needs to spec out the gear, set THEIR OWN standards and have the producers make what we desire. Just like buying a B-1 bomber or an F-18.
Donald F. Hayde Donald F. Hayde Tuesday, April 30, 2013 7:29:09 PM Lab tests rarely produce the effects and kinethesis of firefighting, that we as firefighters experience and can lend first hand knowledge to.
John Smith John Smith Tuesday, April 30, 2013 7:35:20 PM You think money is tight now... Lets replace gear cause a label says its 10 yrs old. I have seen tags on BRAND NEW HELMETS AND OTHER PPE that was a year old from sitting in warehouses and shelves... Also at $1500 to $2000 up for a set... Who's getting a kick back???
Mike Bloom Mike Bloom Tuesday, April 30, 2013 7:52:26 PM NFPA again. I think a lot of what NFPA does is for our safety but most of the people sitting on committees ,like this one, are manufacturers and if they write the rules they make the money. BTW, I have a set of training gear that is 20 years old and is in better condition then my regular stuff that is 8. Just like anything else if you buy cheap stuff it won't last.
Jonathan Bastian Jonathan Bastian Tuesday, April 30, 2013 10:34:04 PM Sometimes these committees write solutions in search of problems.
Ross Tyler Blitz Ross Tyler Blitz Wednesday, July 17, 2013 2:27:50 PM Hey Donald, I sent you a message on Facebook, Please check your "Other" Messages folder... As Facebook want's me to pay to message you. Thanks so much! -Ross Blitz
Larry Perry Larry Perry Wednesday, July 24, 2013 7:34:07 AM Has the NFPA lost touch with reality? Are the experts working in a dream world, where budgets are without limits? In my view the recommendations and standards published by NFPA, that are then blindly adopted by governments, are very destructive to he fire services. Of course we want the safest possible situation for our firefighters, but how does that play out when we are forced to choose between hiring firefighters and replacing PPE that is still perfectly serviceable. And this is just the tip of that iceberg. Its a new and restricted world out there and some of us don't get it. If things don't change and soon, the NFPA will be viewed as the enemy, in fact it may already be the enemy.
Donald F. Hayde Donald F. Hayde Saturday, September 28, 2013 2:18:20 PM Sorry I never got back to you. Contact me again.

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