Making the case for firefighter PPE restricted substances lists
The NFPA 1971 technical committee is currently considering an RSL of chemicals and specific levels for those chemicals
By Jeffrey O. and Grace Stull
Chemicals are a constant part of our lives. While many of these chemicals are naturally occurring, there is an increasing abundance of manufactured and synthesized chemicals often not found in the environment. This, of course, is the result of our ever-expanding technology for hopefully making our lives better and more efficient. But as we introduce new substances, consideration must be given to the various impacts to both individuals and the environment.
Lessons learned from experience are helping us understand how to better manage our exposure to many of these chemicals. Through such analysis, we have begun to recognize that many substances need to be restricted in their use – and we must weigh their benefits against possible harm to human health and the environment.
Here we’ll address the concept of restricted substances as applied to manufacturing products, specifically examining how these restrictions can be applied to firefighter PPE.
What makes a substance subject to restriction?
There is a vast number of chemicals that can be classified as hazardous in one way or another. These chemicals can be toxic, both from short-term and long-term exposures; they can be reactive; they can be flammable; and they can have other qualities that harm people or our environment. In most cases, the effects of these hazardous substances are wholly dependent on the dose. The exposure impact is also affected by the form in which these chemicals appear as well as the chemicals’ properties related to their persistency, both within the human body and in the environment.
Many substances have become restricted over time as evidence shows impact on human health or the environment. Generally, this happens because authorities, usually governments, attempt to limit the use of chemicals based on emerging toxicological information, mostly after the chemicals have been in use for some time.
Such restriction of certain hazardous chemicals has been going on a long time. For example, some of us may recall when the insecticide DDT was banned from widespread use due to its impact on human and animal health and the environment. Similarly, we now know that lead in pipes and children’s toys leads to chronic exposure to this toxic heavy metal. We have also seen instances where familiar products have changed because of a restricted substance, such as water bottles no longer containing a chemical known as Bisphenol A that has been associated with impacts on the prostate gland of fetuses, infants and children.
The importance of restricted substance lists (RSLs)
When substances subject to restriction are agglomerated, they are referred to as restricted substance lists (RSLs). RSLs are becoming more common among various areas of product manufacturing, particularly consumer goods, as it becomes a way to regulate the use of and subsequent exposure to various hazardous substances. Thus, an RSL usually provides the names of the identified harmful chemicals and indicates how much of these chemicals can be present, if any, in a particular type of product.
When limits are imposed on the permissible quantities or concentrations of these substances, it is based on detailed scientific work that links specific doses of chemicals through their route of entry into the human body as being less than levels known to cause effects in animals or human beings. In many cases, as more and more studies are conducted, these limits can become more stringent and, in some cases, chemicals can be banned from use altogether.
RSLs are used by industry as a way of establishing product stewardship, which becomes a product-centered approach to environmental protection that, when properly applied, affects all parts of the product life cycle – manufacturers, retailers, users and disposers – to share responsibility for reducing the impacts of products. Manufacturers and suppliers use RSLs to ensure that their products with hazardous substances remain below the appropriate levels to minimize any harm in their exposure to humans and the environment. In essence, it is a responsible way for keeping the most harmful chemicals from becoming exposure hazards to people and resulting in pollution.
Sources of RSLs
There are multiple sources of RSLs. An RSL helps companies meet regulatory requirements. As explained above, a RSL is a list of chemicals restricted in consumer products, usually due to a governmental regulation or law. Consequently, several governmental organizations have promoted RSLs in one form or another. For example, the State of California has Proposition 65, which requires businesses to provide warnings to Californians about significant exposures to chemicals that cause cancer, birth defects or other reproductive harm. These warnings often come in the form of information provided on labels. In 2006, the European Union enacted the REACH regulation, which created responsibilities for registration, evaluation, authorization and restriction of chemicals. All of the regulations pertaining to restricted substances are subject to change and are frequently updated as new information becomes available.
However, some brands have an RSL that may go above and beyond regulatory requirements. These RSLs generally anticipate expected changes for the classification of substances becoming either restricted or more restrictive than current regulations dictate. To this end, several private organizations have established RSLs that are globally broad to be adaptive, and to allow product manufacturers to have an independent way for showing product stewardship.
The following includes a variety of testing labs and websites that explain RSL and how they are put together for a variety of industries:
For most part, these organizations have not only established RSLs that are maintained to keep them up to date, but they also offer the specific test services through which manufacturers and suppliers can state that their products comply with the respective RSL. In some cases, this includes special labeling indicating the compliance as well as frequent monitoring to ensure that the respective products continue to comply with the RSL.
The RSL application to fire service PPE
So, should RSLs be applied to fire service PPE, and if so, how should RSLs be applied?
Currently, there are several suppliers of materials and components used in fire service PPE that meet already existing RSLs created by different organizations. The manufacturers or suppliers have been submitting their materials and components for review by the RSL organization and are listed as complying with applicable requirements. This includes many materials and components but not everything used by the fire service today.
There is nothing to prevent an end-user organization from specifying that RSLs should be met, but it would be helpful if RSLs were consistently applied to the more relevant materials and chemicals specific to different forms of fire service PPE.
One such proposal is currently being entertained by the technical committee responsible for NFPA 1971: Standard on Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting. In this case, consideration is being given to establishing an RSL of relevant chemicals and setting specific levels for those chemicals. This would be followed by establishing the framework by which material and component suppliers can demonstrate compliance without pointing to a specific commercial entity. This approach could be workable; however, it should be implemented in a way that creates a reasonable balance between resource requirements for manufacturers and meeting end-user needs to demonstrate that PPE is reasonably safe and does not create pollution problems.
RSL pros and cons
A potential advantage for incorporating an RSL into NFPA standard is the fact that requirements are made uniformly across the industry. If properly positioned, it may also be possible that those manufacturers and suppliers already applying RSLs for their products would essentially not need to do anything beyond what they are already doing. This would also advance the remainder of the PPE industry that is not applying such product stewardship, bringing them into similar compliance.
This approach is not without its problems. RSLs are relatively complex and take a significant level of expertise to apply judgments for identifying the most restrictive limits on certain hazardous substances and to further ensure that they are properly measured when requirements are set. The list of RSLs is ever-increasing and that in itself creates a burden for maintaining the list to keep up with new information. Lastly, there is always the additional cost of compliance itself, which would represent new expenses for manufacturers that do not currently control substances through RSLs.
As the proposal for including RSL requirements in NFPA 1971 has already been put forward, the issue will be forced to move one direction or another. Hopefully, as with any highly technical subject that spans a range of perspectives as well as the need to find the correct balance for applying RSLs, the committee process will find the most appropriate way of addressing this topic to help with future firefighter health and safety.
About the authors
Jeffrey and Grace Stull are president and vice president, respectively, of International Personnel Protection, Inc. They are members of several NFPA committees on PPE as well as the ASTM International committee on protective clothing. Mr. Stull was formerly the convener for international work groups on heat/thermal protection and hazardous materials PPE as well as the lead U.S. delegate for International Standards Organization Technical Committee 94/Subcommittees on Protective Clothing and Firefighter PPE. They participate in the Interagency Board for Equipment Standardization and Interoperability and have authored the book, "PPE Made Easy.” Send questions or feedback to the Stulls via email.