Detailing the changes to PPE-focused NFPA 1851
Highlighting 16 changes to the standard and how they impact firefighters
NFPA 1851 has transformed how the fire service addresses PPE for structural firefighting. With the long title – Standard on Selection, Care, and Maintenance of Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting – the document has evolved over a period of less than 20 years to create changes in how the fire service takes care of the gear intended to provide protection under the worst fireground circumstances.
NFPA 1851 sets requirements for how fire departments select, track, inspect, clean, repair, store and retire PPE. The standard is intended to provide generalized ways for how firefighters can meet these requirements to ensure the continued performance of PPE over its specified service life.
August 2019 marks the 4th edition of the standard, with a heavy emphasis on contamination control. Although the new edition will issue at the end of the month, it is unlikely that either a hard or paper copy will be available until late September, at the earliest.
Like all NFPA PPE standards, NFPA 1851 has a one-year grace period, meaning that the new changes in the standard will not become mandatory until August 2020.
Unlike the PPE standards that applied to manufacturers, full compliance to the standard is uncommon for most fire departments, the principal intended audience for these requirements. Instead, many fire departments attempt to comply as much as possible within their resources. Some areas of the country, like Texas, mandate that career fire departments follow NFPA 1851 requirements. As such, is important to understand the new changes that are coming forward with the new edition.
NFPA 1851 history and current requirements
In the mid-1990s, it became clear that fire departments were often not properly inspecting, cleaning and repairing their protective clothing, with the potential leading to unnecessary exposures to fireground hazards.
When established in 2001, the standard was a follow-up to an effort led by the Fire Industry Education Resource Organization (F.I.E.R.O.), and other fire service safety organizations, to provide appropriate direction for properly taking of PPE.
Since its origin, NFPA 1851 has been increasingly expanded in the breath of requirements and information that it provides. For example, there are now separate requirements for independent service providers (ISPs) to be verified in their inspection, cleaning and repair services of turnout clothing. The standard also has an extensive annex, where non-mandatory guidance information is provided.
NFPA 1851 has not been without controversy as it also specifies a 10-year maximum service life on all forms of structural protective clothing and equipment used by fire departments (proximity outer shells have a five-year retirement). Interestingly, an NFPA survey conducted in 2015 showed that 28% of the U.S. fire departments had at least some gear that was more than 10 years old. Nevertheless, many departments do strive to meet NFPA 1851 criteria within the constraints proposed by their available resources.
What’s new for NFPA 1851
While NFPA 1851 is a maturing standard, the recent focus on fire service contamination control related to cancer and fireground exposure issues created significant modifications to the standard. Below are 16 changes that are considered the most noteworthy in the new edition:
1. A fundamental change has been to define exposure to products of combustion as contamination, which always warrants advanced cleaning. The new edition presents two flow charts that aid fire departments on how to decide upon the appropriate types of cleaning and decontamination.
2. A requirement has been added for fire departments to undertake preliminary exposure reduction, which many in the fire service now call gross decontamination. Fire departments are required to either rinse firefighters off at the scene while still on air or use dry brushing to remove exterior contaminants, followed by bagging and isolation of the gear for later advanced cleaning. It is understood that such procedures may not always be practical, but detailed provisions are provided in the annex with specific recommendations for how the procedures can be applied under different circumstances.
3. Advanced (machine) cleaning is now required every 6 months instead of one year.
4. Advanced cleaning of garments must be performed in a programmable washer extractor with a specified maximum acceleration. These washing machines use a special cycle with controlled temperatures, multiple rinse cycles, water levels, and cycle times to address the proper washing of turnout clothing. The use of top-loading machines is now prohibited.
5. Drying of garments in an air-drying cabinet is now an option. The use of air drying is still an option for drying garments. If machine drying is used, it has to be on a no-heat setting.
6. More complete default cleaning procedures have been established for the other elements, including helmets, gloves and footwear, which involve cleaning in a utility sink with specific outlined procedures. A large amount of detail is provided in the accompanying annex material.
7. There are now requirements for sanitization and disinfection of protective clothing when contaminated with blood, body fluids and other biological contaminants (e.g., flood water). Sanitization applies to removing micro-organisms to a safe level on textile-based elements whereas disinfection applies to a more aggressive removal of microorganisms on hard surfaces, such as helmet shells. Sanitization is supposed to proceed advanced cleaning but can also be part of the advanced cleaning procedures. Sanitizers and disinfectants that are used must comply with EPA registration requirements.
8. A new section has been established for specialized cleaning, which addresses specific types of contaminants, such as asbestos, fentanyl (opioid drugs) and bed bugs. Additional information is provided in the annex for suggested procedures. Organizations are supposed to have some means of verifying whether specialized cleaning is effective using either prior experience, subject-matter expertise, or testing. The annex also explains how to decide if testing is warranted and offers specific recommendations for how the testing can be conducted.
9. The qualifications for organizations that can conduct advanced inspections, cleaning and repairs of protective clothing have been made more rigorous. These include manufacturers, ISPs and trained organizations. There is now a new category of verified cleaners, which are ISPs that provide advanced inspection and advanced cleaning, but not advanced repairs.
10. Relatively detailed and rigorous requirements have been put into place for verifying the effectiveness of advanced cleaning and sanitization for manufacturers, ISPs and verified organizations. The requirements demonstrate that organization procedures reduce the amounts of contaminants in turnout gear. This testing has to be carried out one year after the effective date of the standard, then every 2 years afterward. This is by far one of the more significant changes in the standard that affects manufacturers and ISPs, but is not being applied to fire departments.
11. Fire departments are now supposed to conduct their hazard assessments to take into account the type of fireground operations. This is principally intended to distinguish between structural and proximity firefighting since many departments with airport firefighting stations are now electing to use structural gear in lieu of proximity gear.
12. Complete liner inspections for garments have been folded into the advanced inspection procedures and are now required to be done every year instead of waiting for 3 years into the garment's life. The liner light test and puddle test have been removed from the routine inspection procedures since the specified hydrostatic testing is understood to be a better assessment of moisture barrier quality and is more commonplace in advanced inspections.
13. New inspection provisions have been added to NFPA 1851 to address particulate-blocking hoods. For advanced inspections, there is the choice of a method using light inside a headform or other fixture on which the hood is mounted to identify damage as well as a slightly more sophisticated smoke test that involves a modified hydrostatic tester with a smoke generator.
14. Any training for repair of protective clothing has to be provided by a manufacturer of the same element type or verified ISP that is experienced in providing these types of repairs.
15. Moisture barrier repairs can now include tapes of different widths, making it easier to provide advanced repairs of garment liners.
16. Contaminated ensemble elements are not permitted to be transported inside the apparatus cab unless in a protective bag or case.
No changes were made to the maximum 10-year service life requirement. Instead, the committee reaffirmed the requirement, with provision of further information from relevant studies indicating industry studies supported the requirement and reiterating the lack of non-destructive field methods to assess continued PPE performance.
Forward direction for NFPA 1851
The overhaul in NFPA 1851 is intended to promote better care and maintenance practices to both ensure adequate levels of protection and limit the accumulation of fireground contamination to firefighters. While NFPA 1851 is prescriptive in its requirements, it is also intended to be informative, as evidenced by the vastly increased levels of guidance provided in the accompanying annex material. As such, this standard, along with other new edition standards, such as NFPA 1500, is leading the way for transforming fire service contamination-control practices. Further progress is expected in the future, particularly to address other ensemble elements such as helmets, gloves and footwear for providing the same levels of detail in care and maintenance as not applied to garments.
The views of the author do not necessarily reflect those of the sponsor.