The National Institute for Occupational Safety and Health announced the day before Thanksgiving that an error had occurred in the testing of SCBA. For fire departments, this may mean delays in new equipment being available and a window where no certified SCBA can be sold.
The specific NIOSH Respirators User Notice indicated that the U.S. Army Edgewood Chemical Biological Center (ECBC) Test Laboratory learned that all the testing they had performed between July 2012 through October 2013 for evaluating SCBA and other respirator performance against chemical warfare agents was done at concentrations less than what’s required.
The user notice explains that this erroneous testing affects the completed and pending approvals for those manufacturers supplying SCBA to the fire service that are certified to NFPA 1981.
All fire service SCBA as of the NFPA 1981 2007 edition must provide first responders respiratory protection from CBRN terrorism agents (specified chemicals, biological agents, and radiological particulates) that could be released in a terrorism attack.
While this matter may seem small in the overall scope of respiratory protection, it is of great significance and has serious implications.
Foremost is that any testing completed during this 16-month period must be repeated. But this cannot occur until the new testing procedures are validated to the way they were supposed to be performed in the first place.
History of CBRN testing
Some may be aware that CBRN testing has already been the subject of controversy. This past summer, the technical committee responsible for NFPA 1981 petitioned NFPA for special tentative interim amendment to allow manufacturers to continue selling SCBA certified to the 2007 edition because ECBC could not complete the required testing of SCBA meeting the 2013 edition standard by the Aug. 31 deadline.
ECBC cited the federal government sequestration as the cause for its inability to perform the testing in a timely fashion.
The amendment was approved and the grace period extended to the end of February. The extension allows SCBA manufacturers time to get the new product certified to the 2013 edition while permitting them to continue selling 2007-edition product.
NIOSH and ECBC have said that they cannot complete the validation and repeat all the necessary testing by Feb. 28; they’ll need until April 1.
Gap in availability
This leaves a one-month gap for which no certified SCBA can be provided to the fire service. One month may not seem to be a very long time, but that month is in addition to a six-month delay that has denied the fire service access to new SCBA technology that addresses completely different issues.
That technology is the result of an extensive effort to create a more robust SCBA lens to withstand high levels of radiant heat that had been documented to cause SCBA failures on the fireground. By far, this part of the new standard has been the most challenging new requirement for many SCBA manufacturers.
Other changes included a buddy breathing systems, now known as emergency breathing safety systems; an optional electronic supplemental voice communications system with improved methodology for measuring SCBA facepiece communications effectiveness; and a low-air alarm that activates at 33 percent of full cylinder pressure rather than at the previous 25 percent level.
Whether the errant CBRN testing impacts these changes or not, SCBA with these features cannot be available until the testing issues are resolved and all certification testing is completed.
Short-term remedy denied
One solution would be another special amendment to NFPA 1981 to further extend the grace period and prevent this gap. Although not ideal, this would at least permit fire departments to purchase certified SCBA until the testing problems are resolved.
As logical as this may seem, NFPA has indicated its reticence in considering such an amendment stating that the governing body, the NFPA Standards Council, may not be agreeable to such a request.
Personally, we find it curious that NFPA can issue an amendment one time for an apparently valid reason and then not issue a similar amendment with an equally justifiable position. NFPA should allow an open and transparent process to run its course without any pre-emptive discouragement of a possible amendment submission.
As this predicament unfolds, different causes may be identified. One is the complicated certification process, which while robust, is made difficult by the interrelationship between the different organizations involved.
Testing complications
The U. S. Code of Federal Regulations says that all SCBA must be subject to specified requirements and certified by NIOSH. Yet, these regulations are insufficient to establish the type of criteria that are needed to provide adequate levels of protection for firefighting.
The shortcomings have been addressed over the years by the development and evolution of NFPA 1981.
NFPA 1981 requires that fire service SCBA be certified by an organization accredited to certify SCBA and uses laboratories that are likewise accredited for testing personal protective equipment. Even the accreditation bodies that provide these qualifications must themselves operate in accordance to certain procedures.
These accreditations require ongoing audits of the certification process and laboratory testing. Such is the case for the current and only certification organization for fire service SCBA, the Safety Equipment Institute.
Because SCBA must meet federal requirements and industry demands that SCBA be certified to NFPA 1981, a prerequisite is that they are certified by NIOSH before being certified by SEI. SEI accepts the NIOSH certification as part of this process.
The introduction of CBRN criteria in the 2007 edition of NFPA 1981 complicated this relationship. The CBRN criteria are not part of the government’s Code of Federal Regulations, but rather are incorporated within a statement of standard that NIOSH also controls certification. From our review, ECBC is not an accredited laboratory and NIOSH is not an accredited certification organization for SCBA.
Far-term solution
We have long been advocates for fully defining all minimum requirements that pertain to fire service products within the NFPA standards. The NFPA standards process makes the best attempts in principle to be open and transparent, primarily in providing the opportunity for anyone to have input into the process and to understand how requirements are developed.
Our recommendations have included defining the CBRN requirements directly within the NFPA 1981 standard and moving their oversight to the accredited certification organization. In this way, testing could be undertaken by fully accredited laboratories.
Furthermore, the fire service could deliberately define testing requirements specific to its needs and evolve those requirements as both technology changes and threats become clearly defined in a timely fashion that is not possible through a government-based system. The NFPA 1981 technical committee may be considering these options in the future.
Holiday greeting
We want to wish everyone a Merry Christmas and happy holidays. Thank you for your continued questions and inquiries. Many of your comments have become the seeds of future columns. We hope you have a prosperous and happy new year.
