NFPA 1851, the standard that covers the selection, care and maintenance of firefighting protective clothing, was transformed in late 2019. Requirements for cleaning turnout gear were significantly revamped, with comprehensive changes affecting all aspects of gear cleaning and decontamination and the introduction of verification procedures for independent service providers, organizations and manufacturers that regularly clean gear.
It has now been nearly two years since those requirements were put into place. An assessment of how the fire service has responded to the new standard is helpful in determining whether the industry is embracing the new practices and emphasizing clothing cleanliness.
What changed in NFPA 1851?
The most important change to the 2020 Edition of NFPA 1851 was the establishment of a systematic approach to cleaning and decontamination (see “PPE advanced cleaning requirements in the new NFPA 1851,” Nov 11, 2019). This change involves incorporating several new practices, including:
- Regarding entering structures (where SCBA is required) as exposure to products of combustion.
- Considering products of combustion to be contamination, warranting advanced cleaning of gear.
- Separately defining sanitization and disinfection. Sanitization applies to soft goods with porous materials like garments, hoods, gloves and some footwear, while disinfection applies to hard surfaces. Each process involves different expectations for killing or neutralizing biological contamination.
- Differentiating between advanced cleaning and disinfection/sanitization, which kills or neutralizes pathogenic micro-organisms associated with blood, body fluids or other biological exposures (such as contact with contaminated flood water) but not the removal of soils associated with these exposures. Disinfection and sanitization must be followed up with advanced cleaning or be included as part of advanced cleaning.
- Better defining specialized cleaning by addressing unique contamination hazards and identifying recommended procedures for some unique contaminants that the fire service often encounters (e.g., asbestos, opioid drug residues, bed bugs).
Some of the information most useful to the fire service comes in the vastly expanded guidance that is included in the annex. This includes recommendations on specific cleaning procedures for helmets, gloves and footwear, which can be particularly difficult to clean. There are also details on how to select an appropriate washing machine, set the correct load size, and apply a default set of advanced cleaning and sanitization procedures for garments. This guidance further provides advice on how to determine if advanced or specialized cleaning of gear is possible for difficult contamination. Overall, the comprehensive annex advises the fire service on better approaches for cleaning and decontamination.
Feedback from the fire service on how these new requirements and practices are being put into place is generally positive, although some departments still struggle with finding the necessary resources to frequently clean their gear, especially the more problematic items such as helmets, gloves and footwear.
Preliminary exposure reduction
Another significant addition to NFPA 1851 is the establishment of “preliminary exposure reduction” as a mandatory on-scene practice to start the cleaning process. It should be performed before advanced cleaning and nearly every type of decontamination. It’s helpful that some of these practices evolved from the analogous “gross decon,” which has been a mainstay of hazmat operations. In fact, preliminary exposure reduction has been gaining acceptance among many fire departments in recent years. A 2020 Fire Protection Research Foundation survey found that 80% of the 350-plus respondents indicated that their department had implemented some form of preliminary exposure reduction. NFPA 1851 helps standardize some of these practices by setting minimum requirements for dry or wet mitigation techniques. But more importantly, it points out the different options, values and limitations of these procedures.
As with advanced cleaning and decontamination, guidance in the annex of NFPA 1851 frames these procedures and describes the needed resources and considerations for their implementation as part of the department’s standard operating procedures for emergency scene operations (similar changes were made in NFPA 1584). These procedures are valuable because they remove surface contamination, which in turn lowers the chance of cross-contamination and makes for safer gear. However, that can mean garments have to come out of service more often, which increases the need for spare gear. The annex also includes considerations for applying these techniques in cold temperatures and other situations.
Overall, with supporting research, studies have shown high removal rates for wet-based techniques when fully implemented. Preliminary exposure reduction is becoming a key part of the PPE care philosophy for the fire service. Its fuller use is expected to yield reduced secondary contamination exposures for firefighters and, ideally, eventually lead to reduced rates of long-term health problems in the fire service.
A new bar for qualified cleaning
One of the last major changes in NFPA 1851 is the addition of cleaning verification. Before the 2020 edition of NFPA 1851, independent service providers (ISPs), which clean, inspect and repair gear, were required to be verified. Verification was akin to gear being certified – an outside certification organization assures that the service provider (or manufacturer) meets all the applicable requirements of the standard. While the efficacy of service provider gear repairs were evaluated and audited, there were no analogous criteria for cleaning. This meant that there was no way to ascertain that cleaning was indeed effective.
In the new edition of NFPA 1851, specific criteria and procedures developed by the Fire Protection Research Foundation, under a FEMA Assistance to Firefighters Grants Program for research, were incorporated into the standard. These procedures include “doping” garment outer shell material samples with chemical and biological contaminants, placing these samples into surrogate clothing, subjecting the clothing and samples to the cleaning or sanitization process at the respective service provider facility, and then evaluating the contaminated swatches for levels of remaining contamination. By comparing levels before and after cleaning, the percentage of removal is determined for each applied chemical or biological substance as shown in the figure below.
These procedures were specifically targeted to ISPs, gear manufacturers that offer cleaning, and departments that wanted to be qualified. The category of “verified cleaner” was also established for organizations verified in advanced cleaning and sanitization only. Since the standard came out in late 2019, there are now a total of 60 organizations that have been verified in NFPA 1851’s new cleaning and sanitization requirements. These service providers are located throughout the United States and Canada, as shown in the diagram below.
Specific ISPs can be identified through the listing of the two certification organizations that carry out the verifications: Intertek Testing Services (ITS) and Underwriters Laboratories (UL). For the latter, you’ll be directed to the Prospector site. If you haven’t already signed up, follow the instructions set up an account. After logging in, search for “NFPA 1851.” A dashboard will list the individual companies that are verified ISPs and cleaning organizations. By clicking on the name of the ISP or organization, more information on the verification, including the address, will appear.
This reaction to the NFPA 1851 requirements is significant in several respects:
- Before the 2020 edition, there were 85 verified independent service providers (evaluated for repair procedures only). Nearly 75% of the ISPs have stepped up to the new requirements.
- Even though the requirements were set at moderate levels of contaminant removal (50% on the average for the different target chemicals contaminants), some ISPs ended up having to modify or improve their procedures to attain these levels.
- Verified cleaning and sanitization procedures established at several different ISPs have been shared with fire departments through training programs offered by ISPs to promote effective cleaning at the department or station level. This helps to extend viable cleaning expertise to the fire service without placing an undue burden on fire departments for the costs of cleaning verification.
While significant progress has been made, these efforts are not complete. Further work by the Fire Protection Research Foundation is underway, and it is expected to yield additional understanding and improvements in both cleaning and decontamination approaches that will be made available to the fire service through future changes to NFPA 1851. The hope is that eventually these practices will be the norm in the fire service, and the threat of secondary exposure from contaminated gear will greatly diminish.
Note: The views of the author do not necessarily reflect those of the sponsor.