We have written several times in the past stating the importance of specific standards for the fire service. The majority of these standards originate from the National Fire Protection Association.
Standards on personal protective equipment establish minimum levels of performance that are intended to reflect firefighter needs.
The process for creating and revising standards is fully dependent on the technical committees which are established with fixed size committees. These include a balanced membership from various interested categories including end users, labor unions, manufacturers, research and testing laboratories, and special experts.
However, these standards only become better when individual firefighters and other experienced end users outside the process provide their input to the committee to reflect the practical realities of personal protection.
This month we are writing to encourage you to consider providing proposals and comments on several standards that are in the process of being developed or being revised.
Before we address the current standards in revision, it is important to understand how anyone can provide input to the NFPA process. Unlike many standards development organizations, the NFPA provides two different phases for public recommendations.
Formerly known as public proposals, the first stage is public input. This phase permits individuals to put in suggested changes to an existing standard that are considered by the committee writing the standard in preparing their first draft of the revision.
Any topic is open for consideration, but the NFPA requests that the proposals be put forward in a format where a specific change is suggested and a statement for substantiation should be provided with the change.
The committee reviews each suggested change and either agrees to make the revision or disagrees by rejecting the proposal. However, the committee can also agree in principle by making a related change or accept part of the proposal.
While each suggestion is separately reviewed, the committee may react to a large number of proposals on a single topic and respond with a change that addresses each of the related proposals.
The NFPA is in the process of implementing new procedures where public proposals are viewed more as suggestions as the committee creates a first revised draft of the standard.
The second phase of public involvement is public comment. NFPA is also adapting the rules for how this part of the process is carried out, but for the current year the existing procedures will be in place.
Public comments are submitted after the NFPA publishes its report on proposals, which shows how each of the public comments are handled and an initial draft of the revised or new document.
Like proposals, comments provide recommendations for specific parts of the proposed standard or revision. These recommendations can take the form of adding or changing text, adding new language, or removing parts of the standard.
The committee again reviews each comment and decides whether to accept or reject comments. As with proposals, comments can also be accepted in principle or in part, but another option open to the committee is to hold the proposed change to the next revision.
The actual procedures for submitting a public proposal (now public input) or a comment can be found on the NFPA’s website, under the tab for “Codes and Standards.”
The forms appear to the right side of this page and include explanatory notes for submitting the respective change. In addition, draft documents can be reviewed by selecting the specific standard of interest from the list that appears to the left side of the same page under the heading, “Document information pages.”
By choosing the respective standard, information on that standard will appear, including a full draft of the standard, notices and minutes of any meeting, and a list of members for the respective committee.
The pages for each individual standard also provide a list of specific deadlines for submitting input or comments for the particular standard.
The most important document to look at is the “Report for Proposals” on new documents. This document provides information on what proposals were submitted and how each proposal was addressed by the committee.
In the next part of this article, we’ll outline several standards under development or revision – and what they could mean for you.
