Report of the Committee on

I%e and Emergency Services Protective

Clothing and Equipment

Correlating Committee

Richard M. Duff)', Chair Int'l Assn. of Fire Fighters, DC [L]

Rep. Int'l Assn. of Fire Fighters

Wayde B. Miller, Secretary Mine Safety Appliances Co., PA [M]

Rep. Compressed Gas Assoc.

Thomas Augherton, Safety Equipment Inst., VA [RT] Dennis W. Browner, Scott Aviation, NC [M]

Rep. Industrial Safety Equipment Assn. Robert H. Chiostergi, Southern Mills Inc., GA [M] Loul Clem, Alpine Center for Rescue Studies, CO [U]

Rep. Nat'l Assn. for Search and Rescue Robert A. Freese, Globe Mfg. Co., NH [M] William L. Grilliot, Morning Pride Mfg. Co., OH [M]

Rep. Fire and Emergency Mfrs. and Services Assn. Inc. Virgil Hathaway, San Diego Fire Dept., CA [U]

Rep. Southern Area Fire Equipment Research James s. Johnson, Lawrence Livermore Nat'l Labs, CA [RT] Cy Long, Texas Commission on Fire Protection, TX [E] DavidG. Matthews, United Kingdon Fire Brigades Assn., England [SE]

Rep. Int'l Standards Organization Jim Minx, Oklahoma State Firefighters Assn., OK [G] Bob Montgomery, Hoechst Celanese Corp, NC [M] Ted Putnam, USDA Forest Service, MT [E] effrey O. Stull, Int'l Personnel Protection, Inc., TX [SE] rank P. Taylor, Lion Apparel Inc., OH [M]

Robert D. Tutterow, J r . , Charlotte Fire Dept., NC [M] Rep. Fire Industry Equipment Research Organization

Bruce H. Varner, City of Garrollton Fire Dept., TX [U] Rep. Int'l Fire Service Training Assn.

Harry Winer, U.S. Navy, MA [RT] Thomas L Woilan, Underwriters Laboratories, Inc., NC [RT]

Alternates

Janice c. Bradley, Industrial Safety Equipment Assn. (AlL to D. W. Browner)

Mark B. Chambers, Texas Commission on Fire Protection, TX [E] (Alt. to G. Long)

Nicholas J, Curus, Lion Apparel, Inc., OH [M] (Air. to F. P. Taylor)

Robert Dahl, The DuPont Co., DE [M] (Alt. to B. Montgomery)

Patricia A. Freeman, Globe Mfg. Co., NH [M] (Alt. to P,. A. Freese)

Patrlcia A. Gleason, Safety Equipment Inst., VA [RT] (Alt. to T. Augherton)

William M. Lambert, Mine Safety Appliances Co., (Alt. to W. B. Miller)

Daniel P. Ryan, Underwriters Laboratories Inc., NC (Alt. to T. L. Wollaal)

Nonvoting

Don 1L Forrest, United Firefighters of Los Angeles City, CA Bryan C. Heirston, Oklahoma State Dept. of Labor, OK

Rep. Int'l Assn. of Fire Fighters Richard Mangan, USDA Forest Service, MT Kirk H. Owen, Piano Fire Dept., TX

Rep. NFPA Fire Service Secuon Christopher B. Preu, Louisville Division of Fire, KY Alexander W. Santora, NewYork City Fire Dept., NY Jerry L. Swinford, Texas Commission on Fire Protection, TX

NFPA Staff Liaison: Bruce W. Teele

Committee Scope: This Committee shall have primary responsibility for documents on the design, performance, testing, and certification of protective clothing and protective equipment

manufactured for fire and emergency services organizations and personnel, to protect against exposures encountered during emergency incident operations. This Committee shall also have the primary responsibility for documents on the selection, care, and maintenance of such protective dothing and protective equipment by fire and emergency services organizations and personnel.

Additionally, this committee shall have primary responsibility for documents on the selection, care, and maintenance of emergency medical protective clothing and protective equipment by fire and emergency services organizations and personnel.

Technical Committee on

Emergency Medical Services Protective Clothing and Equipment

Christopher B. Preu, Chair Louisville Division of Fire, KY [U]

jan Dunbar, Secretary Sacramento Fire Dept., CA [U] Rep. Int'l Assn. of Fire Chiefs

Sherri-Lynne Almelda, Houston Fire Dept., TX [U] James M. Baker, Nat'l Safety Clean, Inc., PA [IM] Logan Boss, Best Mfg. Co., GA [M] Douglas Dafter, Lion Apparel, Inc., OH [M] James L. Daneker, Los Angeles City Fire Dept., CA [C] Catherine 1L Dodgen, Inchcape Testing Services/ETL Laboratories, Inc., NY [RT] Daniel Gohlke, W L Gore & Assoc., MD [M] Ahon J. Lovingood, Hall County Fire Services, GA [U] Glen H. Morgan, Oceanside Fire Dept., CA [U] Daniel P. Ryan, Underwriters Laboratories Inc., NC [RT] Michael Spiewak, I. Spiewak & Sons, Inc., NY [M]

J effrey O. Stull, int'l Personnel Protection, Inc., TX [SE] ames P. Zeigler, The Dupont Co. Inc., VA [M]

Alternates

Michael Garrobo, Best Mfg. Co., GA [M] (Alt. to L. Boss)

Kimberly Henry, Underwriters Laboratories Inc., NC [RT] (Alt. to D. P. Ryan)

Grace G. Stull, Int'l Personnel Protection, Inc., TX [SE] (Alt. toJ. o . Stull)

Frank P. Taylor, Lion Apparel Inc., OH [M] (Air. to D. Dafter)

Nonvoting

RobertJ. Mullan, NIOSH/Centers for Disease Control & Prevention, GA

Staff Liaison: Bruce W. Teele

Committee Scope: This Committee shall have primary responsibility for documents on protective clothing and protective equipment, except respiratory protective equipment, that provides hand, torso, limb, and face protection for fire fighters or other emergency services responders during incidents that involve emergency medical operations. These operations include first aid, cardiopulmonary resuscitation, basis life support, advanced life support, and other medical procedures provided to patients prior to arrival at a hospital or other health care facility.

Additionally, this committee shall have primary responsibility for documents on the selection, care, and maintenance of emergency medical protective clothing and protective equipment by fire and emergency services organizations and personnel.

187

Technical Committee on

Respiratory Protection and Personal Alarm Equipment

Alexander W. Santora, Chair New York City Fire Dept., NY [U]

Paul D. Hiltman, Secretary Int'l Safety Instruments, GA [M]

Thomas Augherton, Safety Equipment Inst., VA [RT] Eric Beck, Mine Safety Appliances, PA[M] Mark Crandall, Detex Corp., TX [M] Kenneth R. Ethrldge, Texas Commission on Fire Protection, TX [E] Don R. Forrest, United Firefighters of Los Angeles City, CA [L]

Rep. Int'l Assn. of Fire Fighters Eugene Giorgini, Scott Aviation, NY [M] A. Ira Harkness, U.S. Navy Coastal Systems Station, FL[RT] James S. Johnson, Lawrence Livermore Nat'l Labs, CA [RT] Robert A. Kolenda, City of Pittsburgh, Bureau of Fire, PA [U] Roy Kenneth Lane, Raleigh Fire Dept., NC [U] Patrick J. McLaughlin, Litton Instruments & Life Support , IA [M] Robert W O'Gorman, Inchcape Testing Services NA Inc., NY [RT] Ray F. Reed, Dallas Fire Dept., TX [U] Brian J. Sharkey, USDA Forest Service, MT [RT] Leo W. Stohz, Nat'l Draeger Inc., PA[M]

Alternates

Donald G. Beason, Lawrence Livermore Nat'l Lab, CA [RT] (Alt. to j . s. Johnson)

Carroi E. Burtner, Safety Equipment Inst., VA [RT] (Alt. to T. Augherton)

Vasilios M. Christodoulou, New York City Fire Dept., NY [U] (Alt. to A. W. Santora)

Richard A. Erth, Mine Safety Appliances Co., PA[M] (Alt. to E. Beck)

Darius L. Goodin, U.S. Dept of the Navy - Coastal Systems Station, FL [RT]

(Alt. to A. I. Harkness) Robert E. Gray, Int'l Safety Instruments, Inc., GA [M]

(Alt. to P. D. Hiltman) Richard H. Weaver, Nat'l Draeger Inc., PA [M]

(Alt. to L. W. Stoltz)

Nonvoting

Glen E. Gardner, U.S. Occupational Safety & Health Adm., DC

Staff Liaison: Bruce W. Teele

These lists represent the membership at the time the Committee was balloted on the text of this edition. Since that time, changes in the membership may have occurred. A key to classifications is found at the front of the book.

Committee Scope: This Committee shall have primary responsibility for documents on protective equipment that provides respiratory protection for fire fighters or other emergency services responders during incidents involving operations conducted in hazardous or oxygen deficient atmospheres. These operations include the activities of rescue, fire suppression, hazardous materials mitigation, and property conservation where exposures to an oxygen deficient atmosphere or an atmosphere contaminated with harmful particulate, fog, fume, mist, gas, smoke, spray, or vapor will or could occur.

This committee shall also have primary responsibility for documents on personal monitor/alarm/distress devices for responders operating in hazardous atmospheres or in hazard areas at incidents where entrapment, disorientation, or other responder personal emergency could occur.

Additionally, dais committee shall have primary responsibility for documents on the selection, care, and maintenance of respiratory and personal alarm equipment by fire and emergency services organizations and personnel

This portion of the Report of the Committee on Fire and Emergency Services Protective Clothing and Equipment is presented for adoption in 2 parts.

Part I of this Report on Comments was prepared by the Technical Committee on Respiratory Protection and Personal Alarm Equipment, and documents its action on the comments received

188

on its Report on Proposals on NFPA 1981, Standard on Open- Circuit Self-Contalned Breathing Apparatus for Fire Fighters, 1992 edition as published in the Report on Proposals for the 1997 Annual Meeting.

Part I of this Report on Comments has been submitted to letter ballot of the Technical Committee on Respiratory Protection and Personal Alarm Equipment, which consists of 17 voting members; of whom all 17 voted affirmatively.

Part I of this Report on Comments has also been submitted to letter ballot of the Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment, which consists of 21 voting members; of whom 20 voted affirmatively~ 1 negatively after circulation of negative ballots (Mr. Wollan).

Mr. Wollan vote negatively stating: "The proposed 'ANSI' requirement is unacceptable because:

- It is in clear violation of NFPA Policy and will create a potentially significant anti-competitive situation. See 'NFPA Guide for officers of Technical Committees and Technical Correlating Committees.' Under 'Document Content (2-3.6), NFPA states that a standard should not require proprietary materials to the exclusion of others, neither should a standard prescribe a specific agency for quality control or testing. The comment is seeking to invoke ANSI as a specific agency governing the 'quality control' of certification organizations. The comment provides no option for an alternative accreditation source."

- The substantiation provided by the TCC doesn't address the recommendation. The TCC's substantiation discusses 'recertification' and 'retesting,' and provides no discussion or justification for the proposed ANSI accreditation.

- Neither the TC nor the TCC have documented that a problem exists with the present requirements for Certification or Certification Organizations as stated in Section 2. They have provided no evidence of certified products having been found to be non-compliant.

- The proposed requirement limits the ability of Authorities Having Jurisdiction to accept certification organizations which have alreadybeen found to be acceptable to the AHJ. That the proposal deviates from the established NFPA/AHJ responsibilities is evidenced by the fact that NFPA's definition of 'Approved' does not support AHJ use of NFPA standards to determine the acceptability of testing laboratories. The proposal is inconsistent with NFPA's definition of 'Approved'."

Part II of this Report on Comments was prepared by the Technical Committee on Emergency Medical Services Protective Clothing and Equipment, anddocuments its action on the commen t s r e c e i v e d o n its Report on Proposals on NFPA 1999, Standard on Protective Clothingfor Emergency Medical Operations, 1992 edition, as published in the Report on Proposals for the 1997 Annual Meeting.

Part II of this Report on Comments has been submitted to letter ballot of the Technical Committee on Emergency Medical Services Protective Clothing and Equipment, which consists of 15 voting members; of whom 14 voted affirmatively, 1 negatively after circulation of negative ballots (Mr. Ryan).

Mr. Ryan voted negatively stating: "The proposed 'ANSI' requirement is unacceptable because:

- It is in dear violation of NFPA Policy and will create a potentially significant anti-competitive situation. See 'NFPA Guide for officers of Technical Committees and Technical Correlating Committees.' Under 'Document Content (2-3.6), NFPA states that a standard should ~ require proprietary materials to the exclusion of others, neither should a standard prescribe a specific agency for quality control or testing. The comment is seeking to invoke ANSI as a specific agency governing the 'quality control' of certification organizations. The comment proviaes no option for an alternative accreditation source."

- The substantiation provided by the TGC doesn't address the recommendation. The TCC's substantiation discusses 'recertification' and 'retesting,' and provides no discussion or justification for the proposedANSI accreditation.

- Neither the TC nor the TCC have documented that a problem exists with the present requirements for Certification or Certification Organizations as stated in Section 2. They have provided no evidence of cerdfied products having been found to be non-compliant.

- The proposed requirement limits the ability of Authorities Having Jurisdiction to accept certification organizaions which have alreadybeen found to be acceptable to the AHJ. That the proposal deviates from the established NFPA/AHJ responsibilities is evidenced by the fact that NFPA's definition of 'Approved' does not support AHJ use of NFPA standards to determine the acceptability of testing laboratories. The proposal is inconsistent with NFPA's definition of 'Approved'."

Part II of this Report on Comments has also been submitted to letter ballot of the Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment, which consists of 21 voting members; of whom 20 voted affirmatively, 1 negatively after circulation of negative ballots (Mr. Wollan).

Mr Wollan voted negatively stating: "The proposed 'ANSI' requirement is unacceptable because:

- It is in clear violation of NFPA Policy and will create a potentially significant anti-competitive situation° See 'NFPA Guide for officers of Technical Committees and Technical Correlating

Committees.' Under 'Document Content (2-3.6), NFPA states that a standard should not require proprietary materials to the exclnsion of others, neither should a standard prescribe a specific agency for quality control or testing. The comment is seeking to invoke ANSI as a specific agency governing the 'quality control' of certification orgamzations. The comment provides no option for an alternative accreditation source."

- The substantiation provided by the TCC doesn't address the recommendation. The TCC's substantiation discusses 'recertification' and 'retesting,' and provides no discussion or justification for the proposedANSI accreditation.

- Neither the TC nor the TCC have documented that a problem exists with the present requirements for Certification or Certification Organizations as stated in Section 2. They have provided no evidence of certified products having been found to be non-compliant.

- The proposed requirement limits the ability of Authorities Having Jurisdiction to accept certification organizations which have alreadybeen found to be acceptable to the AHJ. That the proposal deviates from the established NFPA/AHJ responsibilities is evidenced by the fact that NFPA's definition of 'Approved' does not support AHJ use of NFPA standards to determine the acceptability of testing laboratories. The proposal is inconsistent with NFPA's definition of 'Approved'."

189

NFPA 1981 - - A 9 7 ROC

PART I

(Log #CC3) 1981- 1 - (Title): Accept SUBMITTER: Technica l Commi t t ee on Respiratory Protect ion a n d Personal A la rm E q u i p m e n t COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION:

Revise tide o f the d o c u m e n t to read: "NFPA 1981, S tandard on Open-Circui t Self-Contained Brea th ing

Appara tus for the Fire Service." SUBSTANTIATION: T he Technical Corre la t ing Commi t t ee feels that the te rm "fire service" better represents the i n t ended marke t for which these SCBA are manufac tu red . COMMrVrEE ACTION: Accept.

(Log #CCA) 1981- 2 - (1-3 (New)): Accept SUBMITTER: Technica l Commi t t ee on Respiratory Protec t ion a n d Personal Alarm E q u i p m e n t COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION:

Add new Section 1-3 to read: ( R e n u m b e r the existing Sections 1-3 a n d 1-4 (ROP n u m b e r i n g ) as 1-4 and 1-5.

"1-3 Effective Dates. 1-3.1 T h e effective date for this s tandard shall be __ Augus t 1997;

however, the specific Sections he re in shall have i n d e p e n d e n t effective dates.

1-3.2 The effective date for ISO registrat ion specified in Section 2- 4 shall be 1 Sep tember 1999.

1-3.3 The effective date for r e d u n d a n t end-of-service-time indicators specified in Section 4-2 shall be 1 Sep tember 1999." SUBSTANTIATION: T h e Technical Correla t ing Commi t t ee feels tha t addi t ional phase- in t ime is n e e d e d to allow manufac tu re r s to comple te the somew ha t l eng thy process of b e c o m i n g ISO registered. In order to allow SCBA manufac tu re r s t ime to desil~gn, produce , test, a n d certify to these new requ i rements , a d d i t i o n a l Pchase-in t ime is also justif ied.

OMMITTEE ACTION: Accept.

(Log #CC2) 1981- 3 - (1-3 a n d 2-4): Accept in Principle in Part SUBMIT'FEll: Technica l Correla t ing Commi t t ee on Fire and Emergency Services Protective Clothing a n d E q u i p m e n t COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION: Add new defini t ion for "Model" to Section 1-3 to read:

1-3 Model. The collective t e rm used to identify identical SCBA of the same basic design and c o m p o n e n t s f rom a single manu fac tu r e r p r o d u c e d by the same m a n u f a c t u r i n g and quality assurance procedures tha t are covered by the same certification.

Add a new Section 2-4 to read: 2-4 Recertification. 2-4.1 All SCBA that are labeled as be ing compl ian t with this

s t andard shall u n d e r g o recertif ication on an annua l basis. This recertif ication shall inc lude inspect ion and evaluat ion to all des ign requ i rements a n d test ing to all pe r fo rmance requ i rements as requi red by 2-3.5 on all m a n u f a c t u r e r mode l s and componen t s .

2-4.1.1 Any change tha t affects the SCBA's pe r fo rmance u n d e r the desig.n or performance, r equ i rements of this s t andard shall const i tute a different model .

2-4.1.2 For the pu rpose of this s tandard , models shall inc lude each u n i q u e pat tern, style, or design.

2-4.2 Samples of m a n u f a c t u r e r models and c o m p o n e n t s for recert if ication shall be acqui red f rom the manufac t u r e r or c o m p o n e n t suppl ier du r i ng r a n d o m and u n a n n o u n c e d visits as par t of the follow-up inspec t ion p rogram.

2-4.3 T h e m a n u f a c t u r e r shall ma in ta in all des ign a n d pe r fo rmance inspect ion a n d test da ta f r o m the certification organizat ion used in the recertif ication of manu fac t u r e r mode l s a n d componen t s . The m a n u f a c t u r e r shall provide such data, u p o n request, to the purchase r or au thor i ty having ju r i sd ic t ion .

R e n u m b e r existing Section 2-4 as Section 2-5. SUBSTANTIATION: T he Technica l Correla t ing Commi t t ee has d i rected tha t all p roduc t s tandards carry the following text regarding the accredi ta t ion of the third-party certification organizations. Therefore , the TCC directs the TC to incorporate fl~e following changes to its d o c u m e n t at the Repor t on C o m m e n t s stage.

COMMITTEE ACTION: Accept in Principle in Part. As to the par t of the C o m m e n t regard ing 1-$, Model:

Revise 1-3 to read: "Model. T h e collective t e rm used to identify identical SCBA of the same basic des ign f rom a single m a n u f a c t u r e r p r o d u c e d by the same manufac tu r i ng an d quality assurance p rocedures that are covered by the same certification."

As to the par t of the c o m m e n t regard ing new Section 2-4: 2-4.1: Add new 2-4.1 to read: "All SCBA mode l s tha t are labeled

as be ing compl ian t with this s t andard shall u n d e r g o recertification on an annua l basis. This recert if icat ion shall inc lude inspect ion and evaluation to all des ign r equ i r emen t s and test ing to all pe r fo rmance requ i rements as requi red by 2-3.5 and 2-3.8 on all m a n u f a c t u r e r mode l s and componen t s . "

2-4.1.1: Reject 2-4.1.2: Reject 2-4.2: Reject 2-4.3: Accept R e n u m b e r Sections 2-4 and 2-5 (ROP n u m b e r i n g ) as 2-5 and 2-6.

COMMITTEE STATEMENT: As to the par t of the C o m m e n t regard ing Section 1-3: The Technica l Correla t ing Commi t t ee modi f ied the submi t te r ' s

wording to delete "components . " As to the part of the c o m m e n t regard ing new Section 2-4: 2-4.1: The Commi t tee modi f ied the sugges ted wording to be

consis tent with the new defini t ion of "model." 2-4.1.h The Commi t t ee re jected as the issues in the suggested

new 2-4.1.1 are already covered in 2-3.10 (ROP n u m b e r i n g ) . 2-4.1.2: The Commi t t ee rejected as the sugges ted wording

conflicts with the def ini t ion of "model." 2.-4.2: The Commi t t ee rejected as the sugges ted wording was

r e d u n d a n t to 2-2.7 (ROP n u m b e r i n g ) .

190

(Log #15) 1981- 4 - (1-3 Compres sed Brea th ing Gas): Accept in Principle SUBMITTER: K.R. Ethridge, Texas Commiss ion on Fire Protect ion COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION: Revise as follows:

1-3 Definitions. Compressed Brea th ing Gas.* O x ) g c n c.= a A respirable gas

mix ture s tored in a compressed state a n d suppl ied to the user in a u n c o m n r e s s e d gaseous fo rm ~vitabl¢ for b rea th ing (may also be referrecl to as Comnres sed Brea th ing Air). Brea th ing Gas /Brea th ing Air used in oven circuit SCBA shall laave a m i n i m u m air oual i tv of Grade D with a mois ture con ten t o f no m o r e t han 24 Dvm or drver (dew vo in t of -65°F (-54°C~ or lower~

a n d a m a x i m u m Darticulate level of 5 m g / m 2air. A-l-3 Compressed Brea th ing Gas. T h e q u a ! W ef brez*-h!ng ~ r te

k . . . . . , 4 : . . . . . . : . . . . : ~ ~ P D A . . . . . . I 1 - - . ^ # k ^ . C P D A . . . . . ~ ' * ~ ' ~ 1 , . . . . . . . . . . [ . , . . . . . . . . . . . . . . . . . . . . . . . . . . • . . . . . . . . . . . . . . . . . .

c o n ~ n c d in ~WPA 15C~0, Sm~u.a~-d z n ~ r c Dcpa~-'.mcnt r~ . . . . . . . . '^~1 e~¢~,~. ~ . a tzo~l,t, v . . . . . uuali tv of the . . . . v . . . . . . . . . . ~ . . . . . . . . . . . . ~, . . . . . . T h e _ comvressed brea th in~ ~ used in oven-ci rcui t SGBA has a direct effect on the oerforn~ance of this enu ivmen t . It is therefore imnerative tha t a b rea th ing ires be u-secl tha t is consistent with the des ign criteria established in this s t anda rd to ensure tha t the SCBA will con t inue to m e e t the verforrnance criteria conta ined in this s tandard. It has been established t h rough vears of exner ience that Grade D Brea th ing Air with a m a x i m u m mois ture con ten t of 24

nora or drver and a m a x i m u m nart iculate level of 5 m g / m 3 air will mee t the needs o f both the f i re ' f ighter and the SCBA. SUBSTANTIATION: Since this d o c u m e n t sets the m i n i m u m des ign and pe r fo rmance criteria for SCBA and since the quality of the b rea th ing air used in SCBA has a direct effect on the pe r fo rmance of this e q u i p m e n t it is imperative tha t this s tandard specify the quality o f air to be used. It has been d o c u m e n t e d t h r o u g h years o f exper ience tha t Grade D air with a m a x i m u m mois ture con t en t of 24 p p m or dryer and a m a x i m u m particulate level of 5 m g / m 3 air will m e e t the needs of bo th the fire f ighter and the SGBA. COMMITTEE ACTION: Accept in Principle. 1. Revise Section 1-3 Definitions, to read:

Compressed Brea th ing Gas.* A respirable gas mix ture s tored in a compressed state and suppl ied to the user in a gaseous form.

2. Revise 6-1.13.1 to read: 6-1.13.1" The brea th ing air used in the SCBA brea th ing gas

cylinders shall have a m i n i m u m air quali ty of Grade D as specified in ANSI /CGA G-7.1, Commod i ty Specification for Air, a n d s h a l l have a dew po in t of -65°F (-54°C) or lower (24 p p m v /v or dryer) and shall have a m a x i m u m part iculate level of 5 m g / m 3 air.

NFPA 1981 - - A 9 7 ROC

3. Add newA-6-1.13.1 to read: A-6-1.13.1 See A-l-3, Compressed Breathing Gas. 4. Revise A-l-3 Compressed Breathing Gas to read: The quality of the compressed breathing gas used in open-

circuit SCBA has a direct effect on theperformance of this equipment. It is therefore imperative that a breathing gas be used that is consistent with the design criteria established in this standard to ensure that the SCBA will continue to meet the performance criteria contained in this standard. It has been established through years of experience that Grade D breathing air with a maximum moisture content of 24 ppm or dryer [that is a dew point of -65°F (-54°C) or lower], and a maximum particulate level of 5 mg /m 3 air will meet the needs of both the fire fighter and the SCBA~ See also 6-1.13.1. COMMITTEE STATEMENT: The Technical Committee agreed with the submitter's intent and revised the text of 6-1.13.1 to be compatible with NFPA 1500. The Committee moved the breathing air requirement to 6-1.13.1 instead of the definition as the definitions are not the correct place for requirements. A cross reference in the appendix was also included.

(Log #CC1) 1981- 5 - (2-1.2): Accept in Principle in Part SUBMITTE~ Technical Correlaung Committee on Fire and Emergency Services Protective Clothing and Equipment COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION: Replace the existing 2q.2 and 2-2.1 with the following text: 2-1.2 All certification shall be performed by a certification

organization that is accredited for personal protective equipment by the American National Standards Institute (ANSI) in accordance with ANSI Z34.1, American National Standard for Third-Party Certification Programs for Products, Processes, and Services."

2-2.1 "The certification organization shall be accredited for erSonal protective equipment by the American National Standards stitute (ANSI) in accordance with ANSI Z34.1, American

National Standard for Third-Party Certification Programs for Products, Processes, and Services." SUBSTANTIATION: Within the Fire and Emergency Services Protective Clothing and Equipment Project, recertification is already required in some documents and, for consistency, the Technical Correlating Committee will see that it is added to each document that does not currently have it during the normal revision process.

The periodic recertification of compliant product is a necessary measure to assure tl~at the future production of compliant product continues to be compliant. Without specific criteria for retesting and recertification, different certification organizations could have widely divergent programs and the possibility of noncompliant product being produced and reaching the field is significantly increased. COMMITTEE ACTION: Accept in Principle in Part. As to the part of the Comment regarding2-1.2:

Revise 2-1.3 to read: "All certification shall be performed by a certification organization that is accredited for personal protective equipment in accordance with" ANSI Z34.1, American National Standard for Third-Party Certification Programs for Products, Processes, and Services."

As to the part of the Comment regarding 2-2.1: Reject. COMMITTEE STATEMF-aNT: AS to the part of the comment rewarding 2-1.2:

"i~he Technical Correlating Committee made the text change to 2- 1.3 instead of the suggested 2-1.2 which was the incorrect pa~.{~raph. While the Committee supports accreditation of certification organizations, the Committee does not agree that accreditation can only be performed "by ANSI to ANSI." The Committee modified the submitter's text to only require accreditation to ANSI Z34.1.

AS to the part of the Comment regarding 2-2.1: The Committee rejects the suggested text for 2-2.1 as being

redundant to the new 2-1.3. The text contained in the existing 2-2.1 (ROP) addresses different issues arid needs to be retained.

(Log #27) 1981- 6 - (2-1.2 and 2-2.1): Accept in Principle in Part SUBMITTER: Frank Savino, SGS U.S. Testing Co., Inc. COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION: Combine into one paragraph to read as follows: All certification shall be performed by a certification organization

that is accredited to either of the following: A. ANSI Z34.1, American National Standard for Third-Party

Certification Programs for Products, Processes and Services, where the accrediting agency is American National Standards Institute (ANSl).

o r :

B.1 ISO/IEC Guide 25, General Requirements for the competence of calibration and testing laboratories, where the accrediting agency is The American Association for Laboratory Accreditation (A2LA). In addition, the NFPA Standard(s) would have to be listed by A2LA as being with the scope of the laboratories' accreditation.

and: B.2 The certification organization is approved by the National

Evaluation Service as a quality control agency for listing and labeling programs. SUBSTANTIATION: The idea that the certification agencies have proof of their expertise is a logical one. However, it is unfair and unnecessary to limit such proof to accreditation by American National Standards Institute (ANSI) to ANSI Standard Z34.1. There are other nationally recognized agencies which use different standards to accomplish the same goal.

NFPA should recognize this and include the agencies cited in the preceding section as offering equivalent proof of a certification agency's ability. COMMITTEEACTION: Accept in Principle in Part. COMMITTEE STATEMENT: The Technical Committee agrees with the submitter that it is not necessary to limit accreditation to "by ANSI to ANSI." See Committee Action taken on Comment 1981-5 (Log #CC1).

The Technical Committee does not agree that other accreditation requirements need to be included as the Committee feels that ANSI Z34.1 is the appropriate accreditation document.

(Log #CC5) 1981- 7 - (2-2.5 and 2-5.5): Accept SUBMITTER: Technical Committee on Respiratory Protection and Personal Alarm Equipment COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION:

I Revise 2-2.5 to read: "The certification organization...meets the requirements of

Sections 2-4 and 2-5." Delete 2-5.5.

SUBSTANTIATION: The Technical Correlating Committee wants to preserve Section 2-4 (ROP numbering) even after ISO registration takes effect as Section 2-4 contains specific requirements pertaining to PPE products. ISO alone is more generalized as to be applicable to all industry and the retention of Section 2-4 reinforces a good level of PPE quality assurance under ISO registration. COMMI'FrEE ACTION: Accept.

(Log #7) 1981- 8 - (2-3.1): Accept in Principle SUBMITI'ER: RichardStein, Survivair COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION: Delete whole 2-3.1 - Place in the Appendix.

SUBSTANTIATION: This paragraph is an advisory statement, and has nothing to do with pass/fail criteria of SCBA.

Further, the NFPA Committee recognizes the inherent danger of this test, and thus should change the test to eliminate the danger. COMMITTEE ACTION: Accept in Principle. Delete 2-3.1 and renumber the remaining paragraphs.

Add new A-2-$ to read: (Add * following 2-3: 2-3*) A-2-3. The testing facility should take suitable precautions to

Phrotect testing personnel and to guard against catastrophic failure at could result in a high pressure gas release, fragmentation, and

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flying parts a n d debris. Catastrophic failure can occur because m a n y tests specified in Chapte r 6 involve compressed gas cylinders conta in ing h i g h p r e s s u r e s , a n d the tests are r igorous in nature . COMMITTEE STATEMENT: T h e Commi t t ee agreed with the submit ter bu t revised the text of 2-3.1 for the append ix to be an advisory s t a t emen t per ta in ing to all test ing in Chapter 6.

(NOTE: THE SEQUENCE NO. 1981-9 WAS NOT USED.)

(Log #8) 1981- 10 - (2-3.4): Accept SUBMITTER: Richard Stein, Survivair COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION:

I evise text as follows: 2-3.4 "SCBA fabric, thread, a n d lens c o m n o n e n t s shall be tested

and shall meet.. ." SUBSTANTIATION: Table 2-3.2 calls ou t specific tests in category E. The defini t ion o f " c o m p o n e n t " in the defini t ion section includes ~ material, par t or subassembly. Thus , Section 2-3.4 m u s t be clarified to indicate only thread, fabric and lens are to be tested per category E. COMMITTEE ACTION: Accept.

(Log #28) 1981- 11 - (2-4, 2-5): Reject SUBMITFER: T h o m a s G. A u g h e r t o n , Safety E qu i pmen t Insto COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION: Paragraph 2-4.1 - revise to read: 2-4.1 The manufac t u r e r shall provide and ma in ta in a quality

a s s u c a n c e p r o g r a m that mee t s the requ i rements of this Section or Section 2-5. The p rog ram shall include a d o c u m e n t e d inspect ion and p roduc t recal lsys tem. T he manufac t u r e r shall have an inspect ion system to substant ia te confo rmance to this s tandard.

Head ing 2-5 - revise to read: 2-5 ISO Registration for Manufac turers (Opt iona l Alternative to

Section 2 4 l Paragraph 2-5.4 - delete Paragraph 2-5.5 - delete

SUBSTANTIATION: As the third-party certification organizat ion for open-circui t SCBA mee t ing the r equ i r emen t s of this s tandard, SEI has a r igorous p rog ram for mon i to r ing and eva lua t ing the quality assurance activities of the SCBA manufac turers . SEI's quality assurance audi t ing p rog ram is on-going. It is r equ i red by the ANSI accreditat ion of SEI as a third-party certification organizat ion u n d e r ANSI Z34.1-1993, Third-Party Certification Programs For Products, Processes and Services, for con t inu ing qualification f o r p e r t i n e n t ISO Guides. This includes ISO Guides 28, 40, 53 and others which prescribe r equ i r emen t s for mon i to r ing quality assurance programs.

SEI believes its four-plus years exper ience in certifying SCBA to the 1992 edi t ion of the s tandard has demons t r a t ed tha t compl iance with the provisions o f Section 2-4 will result in a quality assurance p rog ram that will provide con t inued produc t compl iance with the s tandard.

SEI, therefore, believes tha t a manda to ry r e q u i r e m e n t tha t all manufac tu re r s achieve ISO 9000 registrat ion shou ld not be inc luded in the s tandard. Such a r e q u i r e m e n t provides no assurance tha t a manufac tu re r ' s quality assurance p rog ram will be more effective than one mee t ing the requ i rements of Section 2-4. It would resul t in extra, unnecessary expense for a manu fac tu r e r who is no t en te r ing the in ternat ional marketplace. It may be cons idered ant icompeti t ive, as it would prohib i t otherwise fully-qualified manufac tu re r s f r om receiving certification of their products .

The changes r e c o m m e n d e d will pe rmi t those manufac tu re r s who choose to seek ISO 9000 registrat ion to be recognized, bu t will no t require it, and will pe rmi t o ther manufac tu re r s with acceptable quality assurance p rograms to qualify and participate in the certification of their p roducts to the s tandard.

It is impor t an t tha t NFPA u n d e r s t a n d tha t j u s t because a company is ISO registered, that is no guaran tee tha t ou tgoing p roduc t quality will be good. Part of the work tha t SEI does is with companies who are registered, a n d whose ou tgo ing p.roduct quality is p.oor - they want help m improving produc t quality. T hey also rout inely pass ISO audits.

The re is a significant cost associated with ISO 9000 registration a n d ongo ing audits. Registration, by itself, does no t accomplish anyth ing above a n d beyond the cu r ren t NFPA Quality Program requ i rements - except a t r e m e n d o u s a m o u n t of documenta t ion . Perhaps a compromise would be for NFPA to require tha t the ISO 9000 s tandard be used by participants in des ign ing their quality programs, a n d for the SEI audi tors to verify tha t the participant 's quality p rog ram is ~ to ISO 9000 w i ~ o u t the participant going t h rough the expense of registration. The re is n o th in g wrong with ISO as a ~uide for the quality systems par t of all audit. However, it does no t get into processes and p roduc t quality controls as m u c h as necessary. Any addit ional SEI r equ i rements (traceability, recall, process control, p roduc t control, etc.) tha t are covered more in dep th than requi red by ISO are a t t ended to by the SEI auditors. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The ISO 9000 series registrat ion provides a more detai led quality assurance p rog ram th an provided only by Section 2 4 (ROP). ISO 9000 is well recognized in the domest ic market for control l ing quality assurance and result ing in better products . ISO is no t only for manufac tu re r s en te r ing or in the internat ional market.

(Log #26) 1981- 12- (24.1.1): Accept SUBMITTER: Eugene Glorgini, Scott Heal th Safety COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION:

Delete paragraph 2-4.1.1 in its entirety. SUBSTANTIATION: Model is adequate ly def ined in Part i , 1-3. Paragraph 2-4.1.1 is confus ing and subject to misinterpretat ion. COMMITTEE ACTION: AccepL

192

(Log #17) 1981- 13 - (24.1.1, 24.1 .2 and 24.3): Accept in Part SUBMITTER: Paul D. Hiltlnan, Int'l Safety Ins t ruments , Inc. COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION: Delete Sections 2-4.1.1, 24.1.2, and 2-4.3.

SUBSTANTIATION: (A) Delete sections 24.1.1 an d 2-4.1.2 - Sections 2-4.1.1 a n d 2-4.1.2 are inconsis tent with the new definit ion for "model ' p roposed by the TCC for Section 1-3. Th a t defini t ion allows some variation in the same basic des ign within a single mode l range. Sections 2-4.1.1 and 24.1 .2 say any change in pe r fo rmance or des ign const i tutes a new model . If these latter sections were inc luded in NFPA 1981, any change in the SCBA per fo rmance du r ing recerdf icat ion would consti tute a different model . With this proposal it is highly likely tha t a new model would be crea ted at each annua l recertification, because no manufac tu re r ' s SCBA will pe r fo rm exactly the same f rom one year to the next. This obviously would be impractical for all conce rned parties and canno t be consis tent with the in ten t of the Technical Correlat ing Commit tee .

However, even if the wording was c h a n g e d to say "Any change that significantly affects the SCBA's performance. . ." , the re would s-till be major problems. The first p rob lem would be how to de t e rmine the dividing line between a significant change a n d an insignificant change. The second p rob lem would be the confus ion in the purchaser ' s m i n d when two SCBA with identical appearance an d per formance , except for a significant difference in as few as one of the 1981 tests, are forced to be marke ted as different models.

(B) Delete Section 2-4.3 - Section 2-4.3 would force the manufac tu re r s to release the NFPA certification test data on their SCBA's to the public. This proposal const i tutes a major safety hazard.

The pe r fo rmance data on each manufac tu re r ' s SCBA has always been protec ted by the third party ce~f i e r , the certifier's test lab, and all manufac tu re r s ever since the release of the 1982 edition of S tandard 1981. It was foreseen at the start tha t releasing such data could inf luence the purchaser ' s choice of SCBA in ways tha t were irrelevant or dange rous to themselves. Because this data was genera ted by an i n d e p e n d e n t lab us ing a consensus NFPA standard, there w o u l d b e a natural t endency to be heavily in f luenced by this da ta and base a final choice primarily on what are considered to be the "best" test results. However, there are many o ther factors which are un ique to each user which m u s t be fully evaluated to ensure the SCBA will be suitable for thei r un ique si tuation.

N F P A 1981 m A 9 7 R O C

For example, suppose a purchase r chose an SCBA based on a compar i son of the third-party NFPA certification lab test data, price a n d overall appearance of the unit . Fur ther suppose this purchase r failed to conduc t fit and user trials with tha t SCBA. In this case the SCBA selected migh t be so uncomfor tab le on some individual users ' faces that they removed the facepiece premature ly when egress ing f rom an IDLH env i ronmen t leading to disastrous results.

Or ano the r example: suppose a manu fac t u r e r adds some f lame re ta rdan t material to cover parts of their un i t so that it will get exceptional results on the hea t a n d f lame test. But suppose this material gets very ha rd at low tempera tures a n d prevents the un i t f rom its normal range of movement° This type of restriction would no t be revealed t h r o u g h the NFPA certification testing; it could only be found by evaluating the un i t in the full range of ant icipated usage condit ions.

The purpose of NFPA s tandards is to establish m i n i m u m universal level of pe r fo rmance to ensure safety. These s tandards were never i n t ended to gua ran tee every user that the e q u i p m e n t certified to an NFPA s tandard would be fully appropr ia te or completely safe for tbeir individual situation. It is for this very reason that the Selection, Care and Main tenance documen t s are being developed. These s tandards will address the impor tance of conduc t ing full selection evaluations of SCBA, with a p rogram tailored to the specific needs of each end user.

Purchasers shou ld be conce rned tha t the units they purchase mee t the m i n i m u m safety s tandards of NFPA 1981, and that those units best mee t the un ique needs of their end users. Having a recognized third party certification for the SCBA they select will give purchasers conf idence that the uni t they select meets the r equ i rements of NFPA 1981 Having a t ho rough evaluation p rog ram will ensure those units also mee t the individual r equ i rements of the people who will actually use and mainta in the equ ipment . COMMITTEE ACTION: Accept in Part.

I Delete 2-4.1.1 and 2-4.1.2. COMMITTEE STATEMENT: The Technical Commi t tee rejects de le t ing 2-4.3 as it feels it is essential that dais da ta is available for the autlaorities having jur isdic t ion a n d for purchasers or prospective purchasers a n d should no t be with he ld or otherwise den ied by the manufac turers .

(Log #6) 1981- 16 - (2-5.3): Accept in Principle SUBMITTER: Richard Stein, Survivair CO MMENT O N PROPOSAL NO: 1981-1 R E C O M M E N D A T I O N : Revise text as follows:

2-5.3 "Final assembly of SCBA componen t s into an SCBA shall be accompl i shed in a facility tha t is regis tered to at least ISO 9002." S U B S T A N T I A T I O N : "All e lements" indicate tha t ~ m ach in ed part, plastic componen t , thread, n u t and bolt, dye, etc. m u s t be done in a 9002 facility. Tha t is far beyond the scope of 1981 a n d would br ing produc t ion of SCBA to a halt. COMMITTEE ACTION: Accept in Principleo COMMITTEE STATEMENT: See Commi t tee Action taken on C o m m e n t 1981-17 (Log #18).

(Log #18) 1981- 17- (2-5.3): Accept in Principle SUBMITTER: Eugene Giorgini, Scott Heal th Safety. COMMENT O N PROPOSAL NO: 1981-1 RECOMMENDATION: Revise as follows:

"All sub-assemblies of the Self Conta ined Brea th ing Apparatus def ined on the NIOSH approval label shall be r e q u i r e d t o be assembled in a facility that is registered at least to ISO 9002." S U B S T A N T I A T I O N : Paragraph 2-5.3 has been revised to:

- Change "protective ensemble" to "Self Conta ined Breath ing Apparatus" which is the subject of this document°

- Clearly identify the level of c o m p o n e n t / s u b a s s e m b l y which will require assembly in the ISO 9002 facility. COMMITTEE ACTION: Accept in Principle°

I Revise 2-5.3 to read: All subassembl i e s of SCBA def ined on the NIOSH approval label

and final assembly of SCBA c o m p o n e n t s into an SCBA shall be accompl i shed in a facility tha t is registered at least to ISO 9002. COMMITTEE STATEMENT: The Technical Commi t tee agreed and modif ied the submi t te r ' s text to inc lude two different aspects covered by this c o m m e n t and C o m m e n t 1981-16 (Log #6).

(Log #25) 1981- 14 - (2-4.1.2): Accept in Principle SUBMITTER: Eugene Giorgini, Scott Heal th Safety COMMENT O N PROPOSAL NO: 1981-1 RECOMMENDATION: Revise as follows:

2-4.1.2 For the purpose of this s tandard, Models shall inc lude each un ique ~ or Design as des igna ted bv the Manufac turer . S U B S T A N T I A T I O N : Wording such as STYLE and PATTERN may apply to c lo thing or gloves but are inappropr ia te for SCBA. The Manufac tu re r is best able to differentiate models. COMMITTEE ACTION: Accept in Principle. COMMITTEE STATEMENT: See Commi t t ee Action taken C o m m e n t 1981-3 (Log #CC2).

(Log #19) 1981- 15- (2-5.2): Reject SUBMITTER: Robert W. O 'Gorman , ITS COMMENT O N PROPOSAL NO: 1981-1 R E C O M M E N D A T I O N : A m e n d the cu r ren t text to read:

"The manufac tu r e r shall be registered by an accredi ted registrar ( to ISO 9001 or ISO 9002 as applicable."

S U B S T A N T I A T I O N : ISO 9001 certifies bo th the manufac tu r ing and design capabilities of a manufac tu re r . Not all manufac tu re r s operate u n d e r a system which requires a des ign capability. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The design capability is essential for manufac tu re r s who are p roduc ing life suppor t products , such as the self-contained b rea th ing appara tus covered by this s tandard. Design capability is no t requ i red by ISO to be "in house" design capability and can be contracted, bu t t he capability mus t exist.

(Log #5) 1981- 18 - (3-1.1): Accept SUBMITTER: Richard Stein, Survivalr COMMENT ON PROPOSAL NO: 1981-1 RECO MMENDATION:

Revise text as follows: 3-1.1 "In addi t ion to the NIOSH approval label, "

S U B S T A N T I A T I O N : I believe NIOSH refers to the label on each respirator as an "approval" label. COMMITTEE ACTION: Accept .

(Log #4) 1981- 19- (3-1.7): Accept in Principle SUBMITTER: Richard Stein, Survivalr COMMENT O N PROPOSAL NO: 1981-1 RECO MMENDATION: Revise text as follows: 3-1.7 "The identification of the S_.l~ecifled componen t s of the

SCBA..." S U B S T A N T I A T I O N : Remove the word "major" since this is n o t def ined. Add the word "specified." Now the te rm "specified componen t " should be def ined by the Commit tee . As presently written, ne i ther approval agency nor manufac tu re r can know what to identify. COMMITTEE ACTION: Accept in Principle. Revise 3-1.7 to read:

SCBA componen t s , as listed on the NIOSH approval labels shall be marked directly on the c o m p o n e n t with ei ther the lot n u m b er , or serial n u m b e r , or year a n d m o n t h of manufac ture . COMMITTEE STATEMENT: The Technical Commi t tee revised the entire text of 3-1.7 to reflect the need to have the c o m p o n e n t directly identified. NIOSH requires tha t all parts be identif ied in the manufac tu re r s ' l i terature so tha t the label r e q u i r e m e n t is no t necessary.

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(Log #12) 1981- 20 - (4-1.1, 4-1.1.1, 4-1.1.2, A-4-1.1, and A-I-2.1): Accept SUBMITTER: Leo W. Stoltz, National Draeger, Inc. COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION:

Delete all reference to weight. 4-1.1 - Delete 4-1.1.1 - Delete 4-1.1.2 - Delete A-4-1.1 - Delete A-l-2.1 - Delete first paragraph only.

SUBSTANTIATION: All reference to weight should be dele ted because:

1. NIOSH has legal jurisdiction over maximum weight. See letter provided.

2. Proposed NFPA 1981, 1997 edit ion conflicts with NIOSH policy.

3. NFPA 1981 has no provision to test and record weight. 4. There is no user benefi t obtained from NFPA moni tor ing

weight. Note: Support ing material is available for review at NFPA

Headquar ters . COMMITTEE ACTION: Accept.

(Log #20) 1981- 21 - (4-1.2): Reject SUBMITTF3R: Rober t W. O'Gorman, ITS COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION: Replace "All electric circuits" with "All electronic items."

SUBSTANTIATION: For purpose of certification, clarification is required of the te rm "Electric Circuits." COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: ANSI/UL 913 consistendy uses the term "electric circuit" within that document , therefore the term will be re ta ined in NFPA 1981.

(Log #3) 1981- 22- (4-1.3): Reject SUBMITTER: Richard Stein, Survivair COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION: Delete whole 4-1.3.

SUBSTANTIATION: There is no performance specification to measure rough spots, burrs or sharp edges. What criteria is the approval t agency to use? Check under a microsco.~e? Have 20/20 vision only. Is a burr that is "0.002" unacceptable. What is a rough spot? Suppose a "rough spot" is placed purposefully for a handgrip? Whose finger does one use to test "sharp edges?" COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Section 4-1.3 is no t a performance requi rement but is a design requirement . Evaluation on design requirements to de te rmine compliance is conducted by the certification organization.

(Log #2) 1981- 23- (5-10.1): Accept SUBMITTER: Richard Stein, Survivair COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION:

Revise text as follows: 5-10.1 " ~ specimens of the SCBA's primary..."

SUBSTANTIATION: Clarifies that it is the SCBA that is tested, no t the communicat ion means alone. The test is no t o f a speaking d iaphragm alone, but o f an SCBA using a speaking diaphragm.

The suggested change now brings 5-10.1 into conformance with the language of 6-10.8(a) and (b). COMMITTEE ACTION: Accept.

(Log #16) 1981- 24- (6-1.7(g)): Accept SUBMITTER: Paul D. Hilmaan, Int'l Safety Instruments, Inc. COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION:

"+65°F to 250°F (+54°C to 121°C)" should be changed to:

"-65°F to 250°F (-54°C to 121°C) " SUBSTANTIATION: To agree with manufacturer 's specifications.

(Apparently a typo - - was -65°F in 1981, 1987 edi t ion) Note: Support ing material is available for review at NFPA

Headquar ters . COMMITTEE ACTION: Accept.

(Log #1) 1981- 25 - (6-3.1 and 6-3.5): Accept in Principle SUBMITTEBz Richard Stein, Survivair COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION: Revise text as follows: 6-3.1 "SCBA, utilizing an unpressurized but equivalently weighted

cylinder, shall be tested..." 6-3.5 "After being subjected to the vibration test, the SCBA shall

be tested, using fully pressurized unvibrated cylinder, as specified in Section 6-1, Air Flow Performance Test." SUBSTANTIATION: Section 6.3 specifies that an SCBA shall be vibration tested. It does no t specify that the cylinder needs to be filled with air. However, a filled cylinder is implied because of the air flow test requi rement following vibration. SCBA have been tested by SEI ( lnchcape) with a full cylinder for many years. We believe that this test r equ i rement is especially hazardous. Test results on at least one cylinder has shown that a por t ion of the glass fiber componen t was completely removed f rom a composite cylinder dur ing testing (see at tached photograph) . This could have resulted in a ruptured cylinder. Field results on an abused cylinder has indicated that delayed cylinder rupture ispossible. A composite cylinder which was damaged at the Detro i t tire depa r tmen t subsequendy ruptured hours after the initial damage. Another incident took place near Eureka, CA at he Humbo ld tF i r e District #1. A cylinder ruptured approximately 6 days after exposure to a cleaning chemical (see at tached NIOSH Respirator Users Notice). These incidents indicate clearly that personnel at a test laboratory cannot always de termine if a cylinder has been damaged during the vibration test, and more importandy, cannot de termine if that cylinder will rupture or when. Given the extreme nature of the test and the damage that can result, we believe that a rupture will eventually occur sometime during the vibration test or the subsequent air f lowper fo rmance test, with life threatening results. We do no t t h i n k t h a t the caution provided in Section 2-3.1 is the p roper way to eliminate hazards caused by an inherently dangerous and unnecessary test requirement . We urge the Technical Commit tee to immediately establish a test that replaces a filled cylinder with a cylinder of equivalent weight that is not filled with high pressure air. During subsequent air flow performance, an unvibrated cylinder shall be used for performance evaluation. Since the current test can lead to a serious safety hazard, a TIA could be issued in parallel with the draft o f the 1997 edit ion if changes cannot be made quickly enough to the 1997 draft.

NOTE: Support ing material is available for review at the NFPA Headquar ters . COMMITTEE ACTION: Accept in Principle. COMMITTEE STATEMENT: See Committee Action on Comments 1981-25a (Log #24) and 1981-26 (Log # 21).

(Log #24) 1981- 25a- (6-3.3): Accept SUBMITrER: Robert W. O 'Gorman ITS COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION:

Add new 1-3, Surrogate Cylinder, to read: Surrogate Cylinder. A breathing gas cylinder only for testing in which the mass of the breathing gas is replaced by a substitute mass.

Add new 6-3.3 to read: (Renumber existing 6-3.3 through 6-3.5, ROP number ing. ) 6-3.3* The breathing gas cylinder of the SCBA shall be replaced by a surrogate cylinder.

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Add new 6-3.3.1 to read: 6-3.3.1 The surrogate cylinder and cylinder valve shall be of identical design and construction as the breathing gas cylinder and cylinder valve of the SCBA to be tested.

Add new 6-3.5.2 to read: 6-3.3.2 The mass of the breathing gas of a fully pressurized b rea th inggas cylinder shall be replaced in the surrogate cylinder with a substitute mass. The substitute mass shall consist of a brass rod and surrounding foam constructed as shown in Figure 6-3.3.2.

Add new 6-3.3.3 to read: 6-3.3.3 The surrogate cylinder and cylinder valve with the substitute mass shall have the same total mass, ~:5 percent , as the fully pressurized brea th ing gas cylinder and cylinder valve.

Revise A-l-2.1 (7. Vibration Tests) to delete the second sentence and replace with a new second sentence to read: In this unsecured test, the pressurized breathing gas cylinder is now replaced by a surrogate cylinder to avoid the potential of catastrophic pressurized breathing gas cylinder failure during this rigorous test.

Add new A-6-3.3 to read:

A-6-$.3 Recommended Procedure for Surrogate Cylinder Preparation.

Terms used in this procedure * Free-Air Volume (V): The amount of air in cubic feet at s tandard atmospheric conditions s tored in the cylinder • Water Volume (WV): Internal volume of the test cylinder de te rmined by calculating water displacement. - Rated Storage Pressure (P): The nominal storage pressure rating of the cylinder at room temperature .

Determining mass of air stored in cylinder (M) M = 0.0748V Where M = mass of air in cylinder (LBM), arid V = free air

volume, cu ft.

Determining Nominal Design Weight (W) Weight can be estimated based on the following components :

W=W1 +W2+M Where W1 = Tare weight of empty cylinder less cylinder valve

W2 =: Weight of cylinder valve assembly

Determining Ballast Rod Length The ballast rod length is de te rmined by measuring the overall length f rom the neck of the cylinder to the center of the bot tom of the cylinder (L1). The threaded engagement of the cylinder valve is also measured (L2). The overall length is calculated as follows: (Dimensions are shown in Figure 6-3.3.2.)

L = L1 - L2 + 0.32 inches Note: Ensure that the ballast rod does no t extend beyond the cylinder.

I Determining the Nominal Diameter o f the Ballast Rod (D) The nominal d iameter of the ballast rod is calculated as follows:

D = 2.060"~/((M - 0.00318*V2)/L)

Where M = air mass in cylinder (LBM)

I V2 = air volume in cylinder (cu in.)

V2 = ((14.7*V)/(P+14.7))*1728 feet) Where V = free air volume of cylinder (cubic

L = ballast rod length (in.)

Determining the Necessary Foam Weight (WF) This is found by subtracting the ballast rod weight f rom the total air storage weight as follows:

WF = M - 0.2388*(D2)*L

The foam should have a molded density of 5.5 lbf /cubic foot and mixed in a 50 percen t ratio based on weight. Theoretical amount of each c o m p o n e n t can be de te rmined as follows:

Weight of Componen t A = WF/2 Weight of Componen t B = WF/2

I It is r e c o m m e n d e d to allow for a 15 to 20 percent . The final r e c o m m e n d e d mixture for each component , measured in grams, is as follows:

I ComponentBA 272"WF (grams) Componen t - 272"WF (grams)

Cylinder Preparation Empty the cylinder of air and fully open the cylinder valve. Remove the cylinder valve from the cylinder. A means of threading the ballast rod to the cylinder valve must be incorporated. This is most readily implemented by removing the "dip-robe" f rom the cylinder valve and adding a 3/8-16-UNC female thread on the end of the cylinder valve m o u n d n g thread.

Ballast Rod Machining The ballast rod is mach ined f rom ASTM B16 brass, (1 /2 hard) . The machining details are provided in Figure 6-3.3.2. Care should be taken to ensure that the rod does no t interfere with the cylinder at the valve end. This may require machining a short thread relief at the cylinder valve end of the ballast rod. This is indicated in Figure 6-3.5.2.

Cylinder Foam Filling Once the cylinder valve has been installed and the ballast rod installed and torqued, the cylinder should be posi t ioned vertically with the f iU/vent holes point ing upwards. Commercially available plastic disposable laboratory funnels should be placed in the two f i l l /vent holes. Upon measuring the componen t A and c o m p o n e n t B materials, they should be simultaneously poured into the cylinder via the funnels. Once the material has been poured into the cylinder, the funnels should be removed. The mixture can be agitated by shaking the cylinder. The foam will begin to rise in 4 0 t o 50 seconds. T h e entire volume of the cylinder will fill and excess foam will vent out of the two fill holes. This material should be removed f rom the external surface of the cylinder.

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Comparison o f Total Mass of Surrogate Cylinder to Submitted Cylinder The fully pressurized breathing gas cylinder submit ted for testing and the completed surrogate cylinder both should be weighed separately. The weight o f the surrogate cylinder can not vary from the weight o f the pressurized breathing gas cylinder, that was submit ted for testing, by more than 5 percent .

195

N F P A 1981 n A97 R O C

SUBSTANTIATION: Since the 1992 edit ion of this standard, the topic of stafety has been discussed with regard to the loose cargo vibration test and the possibility of catastrophic failure that exists within the rigorous test environment . As directed through Commit tee process, the surrogate cylinder procedure was developed to remove this issue.

Note: Support ing material is available for review at NFPA Headquar ters . COMMITTEE ACTION: Accept.

(Log #21) 1981- 26- (6-3.5): Accept SUBMITTER: Robert W. O'Gorman, ITS COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION:

I Revise 6-3.5 to read: "After being subjected to the vibration test, the SCBA shall be

reat tached to the breathing gas cylinder originally provided with the SCBA and shall then be tested as specified in Section 6-1, Air Flow Performance Test." SUBSTANTIATION: By adding the surrogate cylinder to the vibration test it is necessary to add this wording to provide direction to test labs pr ior to conduct ing the final air flow

erformance test. OMMITTEE ACTION: Accept.

(Log #9) 1981- 27 - (6-4.1): Accept in Principle SUBMITTER" Cheryl Sparks, c . J . Offray & Son, Inc. COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION: Revise text as follows: 64.1 Five test specimens (hefor¢ condit ioning and five test

Specimens after condit ioninv) of each different fabric componen t of the SCBA shall be tested in accordance with me thod 5903.1, Flame Resistance of Cloth, Vertical, of Federal Test Method Standard 191A, Textile Test Methods. (The condit ioning of the five test specimens is def ined in Section 6-4.3). SUBSTANTIATION: Unwashed textiles can be flammable if not properly treated. The t rea tment is washing; therefore, a f lammable fabric componen t c a n g o undetec ted if no t tested prior to washing. COMMITTEE ACTION: Accept in Principle.

I Revise 6-4.1 to read: "Ten specimen of each different fabric..." ] Revise 6-4.3 to read: "Five test specimens shall be tested without ] any conditioning. The remaining five test specimens shall first..."

COMMITTEE STATEMENT: The Technical Commit tee agreed with the submitter but modif ied the submit ter 's p roposed text to place the condit ioning requirements in the appropria te paragraph.

(Log #10) 1981- 28- (6-5.1); Accept in Principle SUBMITTEI~ Cheryl Sparks, C.J. offray & Son, Inc. COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION: Revise text as follows: 6-5.1 Five test specimens before condit ionin~ and five test

soecimens after condi t ioning/ of each different fabric componen t of the SCBA shall be tested in a forced circulating air oven capable of achieving and maintaining an air stream tempera ture of 500°F + 10°/-0°F (260°C + 5°/-0°C). (The condit ioning of the five test snecimens is def ined in Section 6-5.3L SUBSTANTIATION: Unwashed textiles can be f lammable if not properly treated. The t rea tment is washing; therefore, a f lammable fabric componen t c a n g o unde tec ted if no t tested prior to washing. COMMITTEE ACTION: Accept in Principle. Revise 6-5.1 to read: "Ten specimen of each different fabric..."

Revise 6-5.3 to read: 'Wive test specimens shall be tested without any conditioning. The remaining five test specimens shall first..." COMMITTEE STATEMENT: The Technical Commit tee agreed with the submitter but modif ied the submit ter 's p roposed text to place the condi t ioning requirements in the appropriate paragraph.

(Log #29) 1981- 29 - (6-8): Accept in Principle in Part SUBMITTER: ThomasJ . Comerford, Phi ladelphia Fire Dept. COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION: Due to problems with hear ing a Low Air Pressure Warning Whistle I request that they have a safety redundancy. A redundancy which would impact on the two senses, not merely the sense of hearing, i.e., an audible alarm and a light; an audible and a vibratory alarm. In order to have true safety redundancy the alarms should no t be activated by the same source, e.g., a light at tached to a whistle activated by the same source.

6-8 Particulate Test. Any whistle that use ambien t air for either activation, or operat ion of the End-of-Service-Time indicator be tested for particulate activation, and cleaned, separately. SUBSTANTIATION: Current NIOSH/NFPA Standards allows whistles of 80 decibels, activated a n d / o r powered by ambient air, to be the sole warning for firefighters wearing SCBAs and operating in Hazardous Environments. The term Low Air Pressure Warning Whistle (LAPWW) is used synonymously with the term: End-Of- Service-Time indicator.

The use of a whistle as the sole means of alerting a firefighter wearing an SCBA in a hazardous environment is unacceptable for the following reasons:

1. Ambient air can interfere with the effective operation of the whistle.

2. The pitch and tone of the whistle used by Philadelphia is not comDellin~.

3. -The whistle tone is highly directional. 4. Bunker clothing is highly absorptive. 5. The 80 decibel requi rement is inadequate because:

Routine f i reground operational sounds are frequently higher than the NIOSH/NFPA Standard of 80 decibels, the original Philadelphia requi rement of 92 decibels, and the modif ied requ i rement of 102 decibels.

The BOCA building code allows audible alarm-indicating appliances to sound as high as 130 decibels.

6. The hearing loss of firefighters, and the general population, corresponds with the tone and pi tch of the whisde.

NOTE: Support ing material is available for review at NFPA Headquar ters . COMMITI'EE ACTION: Accept in Principle in Part. As to the issues of particulate testing and sound pressure levels of the warning signal: Hold.

As to the issue of r edundan t low air pressure warning alarms: Add new Section 4-2 to read: "4-2 End-of-Service Time Indicators. 4-2.1 The requirements of this section shall have an effective date

as specified in Section 1-3, Effective Dates. 4-2.2 All SCBA shall be equipped with at least two active end-of-

service-time indicators, one of which shall no t be solely an auditory warning.

4-2.3 Each end-of-service-time indicator shall meet the activation requirements of NIOSH certification as specified in 99 CUR 84.

4-2.4 The design of the end-of-service-time indicators shall be that the failure of ei ther end-of-service-time indicators shall not affect the activation and operat ion of the o ther end-of-service-time indicator(s) ." COMMITTEE STATEMENT: The Technical Committee agrees with the submitter that the issues of particulate testing and sound pressure levels of the warning signal need to be addressed, but did no t have sufficient time dur ing the ROC process to adequately address them and as held them for fur ther study.

The Commit tee was very concerned with the seriousness of the Pthotential failure of the end-of-service-time indicators and decided

at the safety offered by redundancy should be appl ied to all end- of-service-time indicators and has added new design requirements as no ted above.

While the Commit tee realizes that this issue and the new text will no t have full public review, the Commit tee 's concern is he ightened because when fire fighters are per forming structural fire fightin~ operations they are exposed to the products of combustion anct oxygen deficiency and are always considered to be operat ing in IDLH atmospheres (Immediately Dangerous to Life and Health). Failure of the end-of-service-time indicator would cause the fire fighter to exhaust the breathing gas supply without any warning that this was about to occur and then expose the fire fighter to the IDLH atmosphere , resulting in injury, and most likely serious injury or death to the SCBA wearer. This was an unacceptable outcome for the Committee.

196

NFPA 1981 - - A 9 7 ROC

In order to allow SCBA manufac tu re r s t ime to design, produce , test, and certify to these new requi rements , the T e c h n i c a l Commit tee has provided an ex tended effective date for Section 4-2 of 1 Sep tember 1999, two years following the expected NFPA effective date for the 1997 edition. (See C o m m e n t 1981-2 (Log #CCA) for the addi t ion of effective date.)

(Log #22) 1981- 30- (6-10.3): Hold SUBMITrER: Robert W. O 'Gorman , ITS COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION: Replace "audiometrical ly normal" hea r ing as def ined in Section 5-

3 of ANSI $3.2, m e t h o d for measuring, the intelligibility of speech over communica t ions systems." With hea r ing th reshold levels tha t are no h ighe r t han +20 db and no lower than -10db at any andiometr ic test f requency 125 Hz t h rough 4000 Hz as the th resho ld is measu red by us ing an aud iomete r which meets the Amer ican National St :mdard specification for audiometers , ANSI $3.6-1989. SUBSTANTIATION: ANSI 5-3.2 requires hear ing levels of up to 8000 Hz, todays firefighters are evaluated against NFPA 1582 which allows for significantly lower hea t i ng levels by a firefighter. No data has been collected regard ing cu r r en t communica t ions systems v.s. 1582 levels, so the n u m b e r being p resen ted is based upon lab records for test subjects no t accepted to partake in conduc t ing evaluations. COMMITTEE ACTION: Hold. COMMITTEE STATEMENT: The Commi t tee has he ld action on this c o m m e n t because it did no t have sufficient t ime in this ROC process to adequate ly address this issue.

(Log #13) 1981- 31 - (6-11.20 and 6-11.21): Reject SUBMITTER: Leo W. Stoltz, National Draeger, Inc. COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION: Revise as follows: Provision shou ld be made to use the lens vision mask to evaluate

after f lame clarity in a consis tent manne r . The mask could be made f r o m a similar lens with the same shape . SUBSTANTIATION: 6-11.20 Place the lens vision mask over the test lens. The test subject shall t hen read the s tandard eye chart...

6-11.21 The lens vision mask shall be fo rmed f~om a similar lens with the same shape. The nomina l center.. . COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The Commi t tee feels that the existing text is sufficient. How the nomina l center of the lens is d e t e r m i n e d for consistency in testing is d e t e r m i n e d by laboratory protocol to the requ i rements of 6-11.20.

(Log #11) 1981- 33 - (A-6-1.7): Reject SUBMITTER: David Has ton , Survivair Inc. COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION: Ghange Append ix A, pa rag raph A-6-1.7 as follows: "One (1) mode l P24 differential pressure t ransducer. . .

Northr idge, CA 91324. Connec t the single t ransducer to the recorder ( r e c o m m e n d e d in A-6-1.8) as shown in Detail X."

• He~dfo~ pressure hose

T- ~ Ma.n~utn pressure hose Recorder S , ~ t c h Transducor

Detail X

SUBSTANTIATION: Section 6-11, Heat and Flame Test: Append ix A, pa ragraphs A-6-1.7 and A-6-1.8 r e c o m m e n d a

differential t r ansducer a n d recorder , respectively, bu t do no t specify the pressure sens ing set-up or the a r r a n g e m e n t between the test head fo rm and the test m a n n e q u i n . Specifically, the n u m b e r of pressure t ransducers used to measure mask pressure du r in g the Section 6-11 test ing is no t specified.

Two pressure t ransducers are used in conjunct ion with a single recorder in the cu r ren t test se tup at ETL. O n e t ransducer is used to measure facepiece pressure on the test headform, and the o ther is used to measure facepiece pressure on the test m a n n e q u i n . W h e n these t ransducers are electrically switched, the single recorder m u s t be recalibrated for tha t part icular t ransducer . Even t h o u g h bo th t ransducers have identical specifications, large differences have been observed on the recorder prior to the calibration procedure . This se tup has occasionally resul ted in quest ionable test data.

In order to improve test data reliability, we r e c o m m e n d that Append ix A, pa ragraph A-6-1.7 specify a single pressure t ransducer , used in conjunct ion with a single recorder . This would minimize the variables in recalibrat ing the two pressure t ransducers , a n d lessen in ter ference signals p icked up f rom nearby AC power sources or lines which could possibly affect the test results.

The switching of pressure connec t ions ( that is, the connec t ion between the t ransducer and the h e a d f o r m or m a n n e q u i n ) can be accompl i shed by us ing a small manua l ly opera ted 4-way valve. This

~ roposed se tup would no t affect the calibration relat ionship etween the t ransducer and the recorder , or induce any e r roneous

electronic signals into the t ransducer du r ing calibration or actual operat ion. The Detail X shown above describes this system sch emati cally. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The submi t te r was unclear of what benefi t would be realized by the p roposed change as the substant ia t ion does no t correctly summar ize how the calibration is conducted .

(Log #14) 1981- 32 - (A-I-I.1): Accept SUBMITTERa K. R. Ethridge, Texas Commiss ion on Fire Protect ion COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION:

I evise as follows: A d d . 1 The use of self-contained b rea th ing appara tus (SCBA) by

fire fighters is always a s sumed to be in a tmospheres immedia te ly dange rous to life or hea l th (IDLH). The re is no way to p r ede t e rmine hazardous condit ions, concent ra t ions of toxic materials, or percentages of oxygen in air in a fire env i ronmen t du r ing overhaul (salvage) operat ions, or u n d e r o ther emergency condi t ions involving spills or releases of hazardous materials. Thus SCBA are requi red at ,'all t imes d u r i n g any fire f ighting, hazardous materials or overhaul operations. General use criteria is contairled in NFPA 1500. S tandard on Fire Depa r t men t Ofcupa t iona l Safety and Heal th Program. SUBSTANTIATION: Since A-I-I.1 deals with use of SCBA it would seem appropr ia te at this po in t to refer to the NFPA s tandard tha t addresses use o fpro tec t ive equ ipmen t . COMMITTEE ACTION: Accept.

(Log #23) 1981- 34 - (A-6-1.14): Reject SUBMITrER: Robert W. O 'Gorman , ITS COMMENT ON PROPOSAL NO: 1981-1 RECOMMENDATION: Move Append ix Section A-6-1.14 to a newly created Section 5-1.1.2.

SUBSTANTIATION: Cur ren t p rocedure for airflow brea th ing m a c h i n e calibration is located in the append ix of the document . This proposa l places the p rocedure into the d o c u m e n t body. COMMITrEE ACTION: Reject. COMMITTEE STATEMENT: The submi t te r did no t provide suggested manda to ry text for the Commit tee to study and evaluate. The Commi t tee feels tha t there are m a n y impor tan t issues that need to be inc luded in manda to ry text that are no t clearly identifiable as "should be mandatory" in the cu r ren t r e c o m m e n d e d p rocedure or in the commen t .

197

N F P A 1 9 9 9 m A 9 7 R O C

P A R T 11

(Log #11) 199% 1 - (Entire Document) : Reject SUBMITTER: Robert A. Swor, Nat'l Assn. of EMS Physicians COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: The Board of Directors of the National Association of EMS

Physicians appreciates this opportuni ty to provide additional comments on the p roposed NFPA 1999 standard. We had previously shared comments and concerns with you about this draft (March 1995). Additionally, Ms. Kathryn West testified before your committee in May 1995, providing information to put this issue in an appropriate medical perspective. We are aware of the information which Ms. West provided at that t ime and suppor t the information which she shared with your committee.

We must express our extreme concern about this s tandard as it has been drafted. There is no medical or scientific information to support the need for the extent o f the protective equipment which is being suggested by this standard. The potential risk of exposure which exists to all heal th care providers (either prehospital or hospital) does no t warrant ei ther the time or the equipment / suppl ies expense that would be required to implement these recommendat ions . The universalprecaut ions which have been r e c o m m e n d e d by the Centers for Disease Control are adequate to address the potential exposure issues. Additionally, appropriate educat ion of heal th care providers and the use of appropriate immunizat ions is a much more realistic approach to limit potential infectious exposures. Implementa t ion o f the guidelines suggested in NFPA 1999 would place an unnecessary financial bu rden on most EMS agencies in the country. Again, this is a bu rden which cannot be suppor ted by scientific data. SUBSTANTIATION: We hope that you will seriously reconsider a reevaluation of this s tandard based on appropriate education, immunizat ion and protective barriers uul'qzation. We would be happy to provide fur ther support ing information on this topic. Thank you. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: "Guidelines for Prevention of Transmission of Human Immunodef ic iency Virus and Hepatitus B Virus to Health Care and Public Safety Workers" [USHHS, CDC, MMWR 1989:38 (No S-6 ppl-37)] r e c o m m e n d that personal protective clothing that prevents direct body contact with blood and body fluids be worn in some but no t all EMS situations. The NFPA Technical Commit tee on Emergency Medical Services Protective Clothing and Equipment , who are responsible for NFPA 1999, and NFPA Technical Committee on Fire Service Occupational Safety and Health, who are responsible for NFPA 1500, Standard on Fire Depar tment Occupational Safety and Health Program, both require viral barrier protect ion for EMS

~ roviders. Vaccination is no t adequate p ro tec t ion against all Ioodborne pathogens. There is no evidence that has been

presented to the Commit tee that the cost of compliance has limited patient care or worker protect ion. This s tandard was developed to provide min imum performance requ i rement where none exist to assist organizations that deliver EMS operations in their selection of appropriate emergency medical protective clothing in accordance with 29 CFR1910.1030.

(Log #15) 1999- 2 - (Entire Document) : Reject SUBMITTER: Patricia W. Whitaker, Indian River County EMS COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: It is my unders tanding that you are about to pass the NFPA 1999

Standard on Protective Clothing for Emergency Medical Operations. STOPI As written this s tandard will no t pass risk assessment studies nor cost analysis studies.

I am concerned that you have chosen to ignore opposit ion of this s tandard f rom major groups as the AMEP, CDC, NIOSH and the NAEMSP, and that NIH sent you a memo in May 1995 voicing their concerns as well.

Those of us that are in the pre-hospital setting are quite aware of the risks associated with b loodborne pathogens. We utilize appropriate levels o f PPE and know that there is no such thing as a 100 percen t risk free environment. Allow us to evaluate these uniforms for efficacy and delay the passage of this s tandard at this time.

NOTE: PROPER COMMENT FORM SENT 10 /9 /96

SUBSTANTIATION: None given. COMMIIWEE ACTION: Reject. COMMITI'EE STATEMENT: See Commit tee Action taken on C ommen t 1999-1 (Log # 11).

(Log #16) 1999- 3 - (Entire Document) : Reject SUBMITTER: Miki Mayon Savoie, LaFourche Ambulance District #1 COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: U p o n review of the p roposed standards, it becomes obvious that

in the vast majority of EMS calls, the benefits derived f rom these standards are doubtful at best. It's also obvious that the cost in money and t ime would be prohibitive.

Please accept this as an objection to NFPA 1999. SUBSTANTIATION: None given. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The Commit tee disagrees with the substantiation for this comment . In a large majority of EMS calls, the only equ ipment required are gloves. T h e s e standards provide detai led requirements for gloves. In cases where more extensive protect ion is required, this s tandard defines requirements that are most likely to provide protection. Finally, the issue of cost affective delivery of service has no t been demonstrated.

(Log #68) 1999- 4 - (Entire Document) : Hold SUBMITTER: Jeffrey o . Stull, Int'l Personnel Protection, Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Additional requirements should be added for cleaning gloves

which are based on higher levels o f tensile strength, puncture resistance, cut resistance, and permeat ion resistance to disinfectants.

Proposed requirements for cleaning Gloves: Chapter 3 Same requi rements for emergency medical gloves (3-2) except

cleaning glove used in label and technical data package. Chapter 4 Same requirements for emergency medical gloves except 4-2.4 and

change 4-2.2 to "152 m m (6 in.) beyond the wrist crease." Chapter 5 Change per formance levels as follows" 5-2.1 Same 5-2.2 Same 5-2.3 Same 5-2.4 Same 5-2.5 Change to "98.9 N (2.0 lb)." 5-2.6 Change to "40 g." 5-2.7 Change to "120 percent" 5-2.8 Same 5-2.9 New requirement: Glove material samples shall no t exhibit

a normalized breakthrough detect ion time of one hour or less for 50 .0pe rcen t w /w gluteraldehye when tested as specified in Section 6-X [Adopt permeat ion test f rom NFPA 1991, 1994 edition (Section 9-60]. SUBSTANTIATION: It is impor tant to differentiate between medical examgloves and cleaning gloves. Cleaning gloves have not been addressed in t h e p r o p o s e d standard. COMMITTF~ ACTION: Hold. COMMITTEE. STATI~IENT: The Technical Committee is not clear where the requirements for such a cleaning glove should reside or what they should be. The issues raised cannot be addressed in the limited t ime available to the Technical Committee dur ing the ROC process to answer comments .

198

(Log #88) 1999- 5 - (Entire Document) : Reject SUBMITTER: Toni Brophy, Emergency Medical Services COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: This letter is being written on behalf o f the Arizona Emergency

Medical Services Council concern ing NFPA's new nat ional standards for EMS protective clothing and equipment .

N F P A 1 9 9 9 m A 9 7 R O C

The Emergency Medical Services Council r ecommends standards on the establishment of statewide standardized training, certification, and medical s tandards for all classifications of EMTs; establishment of s tandardized testing procedures and cont inuing educat ion criteria; and establishment of medical standards for non- physician prehospital t rea tment and triage of patients requiring emergency medical services.

The EMS Council voted at its September 27th meet ing to write you a letter as public comment . The Council unanimously voted to suppor t the National Association of State Emergency Medical Services Directors' position that the standards as currently written would entail significant expense and hassle for EMS providers across the country and therefore does no t support the new national standards.

Thank you for the the opportunity for the EMS Council to express their viewpoint. Please don ' t hesitate to contact me should you have any questions. SUBSTANTIATION: None given. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The issue of cost raise in this comment has no t been demonstra ted. In addit ion, this is a voluntary standard. There is no requi rement that any agency or governmental entity adopt this standard.

See also Committee Actions taken on Comments 1999-1 (Log #11) and 1999-3 (Log #16L

(Log #2) 1999- 6 - (1-1.1): Accept in Principle SUBMITTER: Bill Grilliot, Morning Pride Mfg Co. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Change "Designed to Pro tec t Emergency Medical ..." to "Designed

to Provide a Minimum Level o f Protection to Emergency Medical . . . "on Def in i t ions /Scope /Throughou t Standard. SUBSTANTIATION: - No protective clothing can provide complete protect ion.

- Top rov ide a min imum level of protect ion is consistent with o ther NFPA standards. COMMITTEE ACTION: Accept in Principle. Make the change in I d A and in 1-3 Emergency Medical Face Protect ion Device. COMMITTEE STATEMENT: Submit ter was no t clear where such specific existed. The Technical Commit tee identified these 2 parts of the text and made the change.

(Log #56) 1999- 7- (1-1.1): Reject SUBMITTER: Kimberly Henry, Underwriters Laboratories Inc. COMMENT ON PROPOSALNO: 1999-7 RECOMMENDATION: Revise text to read:

"This s tandard specifies the min imum documentation, . . . ." SUBSTANTIATION: Current wording implies that the standard is still in the process of be ingwri t ten . COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Standard must use the term "shall."

(Log #57) 1999- 8 - (1-1.1): Reject SUBMITrER: Kimberly Henry, Underwriters Laboratories Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Revise text to read: "...including garments, gloves, boots and face protect ion

devices...." SUBSTANTIATION: Boots or bootie material should be covered in the standard. It is suggested that boots or bootie material should be subjected to at least the Bacteriophage Penetrat ion, Puncture Resistance and Liquidtight Integrity Tests. COMMII~EE ACTION: Reject. Delete all references to "boot," "bootie," and "foot protection." COMMITTEE STATEMENT: Standard has no t provided requirements for foot protect ion and it is no t appropriate to include a new "footwear" or "boot" e lement without public review.

(Log #CC1) 1999- 9 - (1-1.2 (New)): Accept SUBMITTER: Technical Commit tee on Emergency Medical Services Protective Clothing and Equipment COMMENT ON PROPOSAL NO: RECOMMENDATION:

Add new 1-1.2 to read: This s tandard shall no t apply to the use of emergency medical

protective clothing; such use requirements are specified in NFPA 1500, Fire Depar tment Occupational Safety and Heal th Program and NFPA 1581, Fire Depar tment Infection Control Program. SUBSTANTIATION: The Committee wishes to be clear that NFPA 1999 is a product s tandard and does not address user requirements . COMMITTEE ACTION: Accept.

(Log #3) 1999- 10- (1-3): Reject SUBMITTER: Bill Grilliot, Morning Pride Mfg Co. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Change ~ to "Footwear" in definitions and throughout the

standard. Definition should read: Footwear "An Emergency Medical Garment i tem designed to

g rotect the wearers foot." UBSTANTIATION: The term "Footwear" is consistent with

other NFPA standards for foot protective items. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Commit tee Action taken on Comment 1999-8 (Log #57).

(Log #69) 1999- I I - (I-3): Hold SUBMITTER: Jeffrey o . Stull, Int'l Personnel Protection, Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Include definition for trim: "Trim. Retroreflectlve and f luorescent material at tached to the

outermost surface of the protective garment for visibility enhancement . Retroreflective materials enhance nightt ime visibility, and f luorescent materials enhance daytime visibility." SUBSTANTIATION: It is possible for trim to be used on emergency medical garments. While tr im should no t be required for emergency medical garments, when used, it should meet certain mi n i mum requirements . COMMITTEE ACTION: Hold. COMMITTEE STATEMENT: See Commit tee Actions taken on Comments 1999-36 (Log #75) and 1999-48 (Log #82).

199

(Log #89a) 1999- 12 - (1-3 and 2-4 (New)): Accept SUBMFITER: Technical Correlating Commit tee on Fire and Emergency Services Protective Clothing and Equipment COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

Add new definit ion for "Model" to Section 1-3 to read: 1-3 Model. The collective term used to identify a group of

individual elements of the same basic design and components from a single manufacturer p roduced by the same manufacturing and quality assurance procedures that are covered by the same

i certification. Add a new Section 2-4 to read: 2-4 Recertification. 24.1 All individual elements of emergency medical protective

clothing that are labeled as being compliant with this standard shall undergo recertification on an annual basis. This recertification shall include inspection and evaluation to all design requirements and testing to all performance requirements as required by this s tandard on all manufacturer models and components .

2-4.1.1 Any change that affects the elements performance under the design or performance requirements of thls s tandard shall constitute a different model.

2-4.1.9 For the purpose of this standard, models shall include each unique pattern, style, or design, of the individual element.

N F P A 1 9 9 9 m A 9 7 R O C

2-4.2 Samples of manufacturer models and components for recertification shall be acquired from the manufacturer or component supplier during random and unannounced visits as part of the follow-up inspection program.

2-4.3 The manufacturer shall maintain all design and performance inspection and test data from the certification organization used in the recertification of manufacturer models and components. The manufacturer shall provide such data, upon request, to the purchaser or authority having jurisdiction.

Renumber existing Section 2-4 as Section 2-5. S U B S T A N T I A T I O N : The Technical Correlating Committee has directed that all product standards carry the following text regarding the accreditation of the third-party certification organizations. Therefore, the TCC directs the TC to incorporate the following changes to its document at the Report on Comments stage.

Within the Fire and Emergency Services Protective Clothing and Equipment Project, recertification is already required in some documents and, for consistency, the Technical Correlating Committee will see that it is added to each document that does not currently have it during the normal revision process.

The periodic recertification of compliant product is a necessary measure to assure that the future production of compliant product continues to be compliant. Without specific criteria for retesting and recertification, different certification organizations could have widely divergent programs and the possibility of noncompliant product being produced and reaching the field is significantly increased. COMMITTEE ACTION: Accept.

(Log #54) 1999- 13 - (1-3 Barrier Layer): Reject SUBMITTER: Daniel Silvestri, Aldan Rubber Co. CO MMENT O N PROPOSAL NO: 1999-7 R E C O M M E N D A T I O N : Delete and substitute: Barrier Layer. The garment material, garment materials, glove

material, glove materials, or face protection device material providing biopenetration resistance. S U B S T A N T I A T I O N : New technologies allow woven fiber to be treated with a Biocide finish. This new technology gives additional protection to the end user by reducing the amount of contaminate penetrating the outer layer of the garment. In the case of multi layer garments, the barrier layer could be composed of more than one layer of material. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See definitions for Garment Material and Glove Material for further clarification.

Sections 4-1.4 and A-4-1.4 further elaborate on the Technical Committee's position°

Currently there is no evaluation of biocide in ASTM F1671 and in the ASTM F1671 test biocide would probably cause the material to fail the test.

(Log #29) 1999- 15 - (1-3 Emergency Medical Garment): Reject SUBMITTER: Dan Gohlke, W.L. Gore & Assoc. COMMENT O N PROPOSAL NO: 1999-7 R E C O M M E N D A T I O N : Revise text as follows: Emergency Medical Garment "...aprons, sleeve protectors, boots and shoe covers.

S U B S T A N T I A T I O N : This makes it clear, that for those parties interested in footwear, it is covered in this standard under emergency medical garments. COMMITTEE ACTION: Reject. Also delete "shoe covers" from Emergency Medical Garment definition. COMMITTEE STATEMENT: See Committee Action taken on Comment 1999-15 (Log #29).

(Log #89) 1999- 16 - (2-1.2 and 2-2.1): Accept SUBMITTER: Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment CO MMENT ON PROPOSAL NO: 1999-7 R E C O M M E N D A T I O N :

Replace the existing 2-1.2 and 2-2.1 with the following text: 2-1.2 All certification shall be performed by a certification

organization that is accredited forpersonal protective equipment by the American National Standards Institute (ANSI) in accordance with ANSI Z34.1, American National Standard for Third-Party Certifcation Programs for Products, Processes, and Services.

2-2.1 The certification organization shall be accredited for personal protective equipment by the American National Standards Institute (ANSI) in accordance with ANSI Z34.1, American National Standard for Third-Party Certification Programs for Products, Processes, and Services. S U B S T A N T I A T I O N : The Technical Correlating Committee has directed that all product standards carry the following text regarding the accreditation of the third-party certification organizations. Therefore, the TCC directs the TC to incorporate the following changes to its document at the Report on Comments stage.

Within the Fire and Emergency Services Protective Clothing and Equipment Project, recertification is already required in some documents and, for consistency, the Technical Correlating Committee will see that it is added to each document that does not currently have it during the normal revision process.

The periodic recertification of compliant product is a necessary measure to assure that the future production of compliant product continues to be compliant. Without specific criteria for retesting and recertification, different certification organizations could 'have widely divergent programs and the possibility of noncompliant product being produced and reaching the field is significantly increased. COMMITTEE ACTION: Accept.

(Log #32) 1999- 14 - (1-3 Emergency Medical Face Protection Device): Accept in Principle SUBMITrER: Dan Gohlke, W.L. Gore & Assoc. COMMENT O N PROPOSAL NO: 1999-7 R E C O M M E N D A T I O N : Add the following under Emergency Medical Face Protection Device:

"...intended to be (but could be) primary eye protection. S U B S T A N T I A T I O N : Original text makes the impression that face protection devices shouldn't be primary eye protection. This change makes it clear that they could be. COMMITTEE ACTION: Accept in Principle. Delete last sentence (before parenthesis) of 1-3 Emergency Medical Face Protection Device.

Add new 4-3.3 to read: "Face protection devices that are compliant with this standard are not intended to be primary eye protection but shall be permitted to be primary eye protection."

Renumber 4-3.3* through 4-3.5 as numbered in ROP. COMMITTEE STATEMENT: The Technical Committee agrees with the submitter but relocated the new text to the design requirements as the definitions are not the appropriate place for requirements.

(Log #24) 1999- 17- (2-5.2): Accept in Principle SUBMITTER: Catherine R_ Dodgen, Inchcape Testing Services /ETL Testing Lab, Inc. COMMENT O N PROPOSAL NO: 1999-7 R E C O M M E N D A T I O N : Revise text as follows: 2-5.2 The manufacturer shall be registered to the relevant ISO

9000 series document for the facility. S U B S T A N T I A T I O N : ISO 9001 mandates a manufacturer to have design services capability, not all manufacturers have this (some merely assemble recognized components.). COMMITTEE ACTION: Accept in Principle.

I Add to 1-3 to read: "Manufacturer. The entity that assumes the liability and provides the warranty for the compliant product." COMMITTEE STATEMENT: The definition of "manufacturer" which is "boilerplate" in the project, clarifies the issue and ISO 9001 is the correct reference.

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(Log #25) 1999- 18- (2-5.3): Reject SUBMITTER: Catherine R. Dodgen, Inchcape Testing Services /ETL Testing Lab, Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Delete 2-5.3 in its entirety.

SUBSTANTIATION: 2-5.3 should be either deleted or reworded to delineate how far down the chain ISO 9002 is required, i.e., are thread suppliers intended to be required to be registered? Fiber producers? COMMITTEE ACTION: Reject. COMMITTEE STATKMENT: The term "elements" is defined and does not include component manufacturers "up stream°" See also definition of "components."

(Log #4) 1999- 19- (3-1.2.1(e)): Accept SUBMITTERa Bill Grilliot, Morning Pride Mfg Co. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

I Add to end of 3-1.2.1(e) the following: "...and OSHA 29 CFR 1910.132." SUBSTANTIATION: OSHA regulations should be included and it is consistent with other NFPA standards. COMMITTEE ACTION: Accept.

(Log #34) 1999- 23 - (3-2.3.1): Accept SUBMITTER: Dan Gohlke, W.L. Gore & Assoc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

[ Revise 3-2.3.1 as follows: "...of - N o t t ~ ~ SUBSTANTIATION: 3-2 is the labeling and information section for gloves. COMMITTEE ACTION: Accept.

(Log #31) 1999- 24- (3-3.1): Accept SUBMITTER: Dan Gofilke, W.L. Gore & Assoc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

Revise 3-3.1 text as follows: "3-3.1" Product and Package Product label requirements." SUBSTANTIATION: This section deals with package product labels too. COMMITTEE ACTION: Accept.

(Log #35) 1999- 25- (3-3.1.4): Accept SUBMITTER: Dan Gohlke, W.L. Gore & Assoc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

] Revise 3-3.1.4 as follows: "...statement shall be printed on the..." SUBSTANTIATION: Editorial correction. COMMITTEE ACTION: Accept.

(Log #5) 1999- 20 - (3-1.2.1(1)): Reject SUBMITTER: Bill Grilliot, Morning Pride Mfg Co. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Revise text as follows: Maintenance and (;leaning: - Provide separate user information for single and multiple use

garments and face protection. - Remove "cleaning" and "decontamination" from single use user

information. SUBSTANTIATION: "Cleaning" and "decontamination" are not

ate for single use user information. EE ACTION: Reject.

COMMITTEE STATFaMENT: The text of 3-1.2.1 states "as applicable." These probably would not be applicable for "single use" items.

(Log #33) 1999- 21 - (3-1.3.1): Accept SUBMITTER: Dan Gohlke, W.L. Gore & Assoc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

Revise 3-1.3.1 as follows: "... o f - - c - l ~ g ~ a g l l L 2 SUBSTANTIATION: 3-1 is the labeling and information section for garments. COMMITTEE ACTION: Accept.

(Log #36) 1999- 26 - (3-3.3.1): Accept SUBMITTER: Dan Gohlke, W.L. Gore & Assoc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

[ Revise 3-3.3.1 as follows: " of - e l o t l ~ f a c e protection device." SUBSTANTIATION: 3-3 is the labeling and information section for face protection devices. COMMITTEE ACTION: Accept.

(Log #70) 1999- 27- (4-1.x): Hold SUBMITTER: Jeffrey o. Stull, Int'l Personnel Protection, Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Add new requirement: "4-1.X Garment items configured as boots shall meet the

requirements of ANSI Z41-1991, Protective Footwear." SUBSTANTIATION: OSHA Title 29 CFR 1910.136 requires that footwear comply with the ANSI footwear standard. No provisions are currently provided in NFPA 1999 which address footwear pchysical performance.

OMMITTEE ACTION: Hold. COMMITTEE STATEMENT: The Committee did not have time in the ROC process to address footwear issues and the new requirements would not have had appropriate public review.

(Log #6) 1999- 22 - (3-2.2.1(t)): Reject SUBMITTER: Bill Grilliot, Morning Pride Mfg Co. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Delete "cleaning" and "decontamination."

SUBSTANTIATION: "Cleaning" and "decontamination" are not appropriate for single use gloves. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The text of 3-1.2.1 states "as applicable." These probably would not be applicable for "single use" items.

(Log #7) 1999- 28- (4-1.2): Reject SUBMITTER: Bill Grilliot, Morning Pride Mfg Co. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Remove "feet" from excluded list. Add "footwear" to the non-full body clothing list.

SUBSTANTIATION: "Boots" or "footwear" are considered a~rnents and so do provide protection to the feet.

MMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Action taken on Comment 1999-8 (Log #57).

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NFPA 1999 - - A 9 7 ROC

(Log #28) 1999- 29- (4-1.2): Reject SUBMITTER: Dan Gohlke, W.L. Gore & Assoc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Revise as follows: ..."excluding hand and face ~ ...such as aprons, sleeve

protectors, boots and shoe covers." SUBSTANTIATION: This makes it clear, that for those parties interested in footwear, it is covered in dais standard under emergency medical garments. COMMITTEE ACTION: Reject. Only delete "shoe covers" from 4-1.2. COMMITTEE STATEMENT: See Committee Action taken on Comment 1999-8 (Log #57).

(Log #72) 1999- 33- (4-3.x): Hold SUBMITTER: Jeffrey O. Stull, Int'l Personnel Protection, Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Add new design requirement: "4-3.X Face protection devices which are faceshields shall meet

requirements in Section 9 of ANSI Z87.1-1995, Practice for Occupational and Educational Eye and Face Protection." SUBSTANTIATION: The current design and performance requirements for face protection devices are insufficient for faceshield-type faceprotection devices. COMMITTEE ACTION: Hold. COMMITTEE STATEMENT: The Committee did not have sufficient time during the ROC process to address face protection devices and the new requirements would not have had appropriate public review.

(Log #58) 1999- 30- (4-2.1): Accept SUBMITTER: Kimberly Henry, Underwriters Laboratories Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

Revise 4-2.1 text to read: "Gloves shall be designated as single-use only." SUBSTANTIATION: Current wording implies that multiple-use gloves are permitted and shall meet single use requirements. I think it is the Committee's intention that gloves shall be single-use only. COMMITTEE ACTION: Accept.

(Log #18) 1999- 31 - (4-2.5): Reject SUBMITTER: Michael Garrobo, Best Manufacturing Co. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Revise text as follows: 4-2.5 In order to label or otherwise represent a glove as being

compliant with the requirements of this standard, the manufacturer shall provide gloves in not less than -five-four separate and distinct sizes. SUBSTANTIATION: Four sizes can fit 95 percent of the population with an elastomeric glove. These gloves are not as rigid and stiff as a structural fire fighter's glove. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: All emergency medical gloves are not of elastomeric properties and the five sizes are felt to be necessary to properly fit the 95 percent of population including both male and female users.

Table 4-2.5 is consistent with international sizing tables.

(Log #73) 1999- 34- (4-3.x): Hold SUBMITTER: Jeffrey o . Stull, Int'l Personnel Protection, Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Add new design requirement: "4-5.X Face protection devices which are goggles shall meet

requirements in Section 10 of ANSI Z87.1-1995, Practice for Occupational and Educational Eye and Face Protection." SUBSTANTIATION: The current design and performance requirements for face protection devices are insufficient for

~g les-type face protection devices. MMITTEE ACTION: Hold.

COMMITTEE STATEMENT: The Committee did not have sufficient time during the ROC process to address face protection devices and the new requirements would not have had appropriate public review.

(Log #74) 1999- 35 - (4-3.x): Reject SUBMITTER: Jeffrey o. Stull, Int'l Personnel Protection, Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Add new design requirement: "4-3.X Face protection devices which are respirators shall be

NIOSH/MSHA certified." SUBSTANTIATION: The current design and performance requirements for face protection devices are insufficient for respirator-type faceprotection devices. COMMITTEE ACTION: Reject~ COMMITTEE STATEMENT: Respiratory protection is outside the scope of this Technical Committee.

(Log #71) 1999- 32- (4-3.x): Hold SUBMITTER: Jeffrey o . Stull, Int'l Personnel Protection, Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Add new design requirement:

"4-3.X Face protection devices which are spectacles shall meet requirements in Section 8 of ANSI Z87.1-1995, Practice for Occupational and Educational Eye and Face Protection." SUBSTANTIATION: The current design and performance requirements for face protection devices are insufficient for spectacle-type face protection devices. COMMITTEE ACTION: Hold. COMMITTEE STATEMENT: The Committee did not have sufficient time during the ROC process to address face protection devices and the new requirements would not have had appropriate public review.

(Log #75) 1999. 36- (5-1.x): Hold SUBMITTER: Jeffrey O. Stull, Int'l Personnel Protection, Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Include new performance requirement for garments: "5-1.X Specimens of garment trim shall be tested for refiectivity

and flourescence as specified in Section 6-X, 'Retroreflectivity and Flourescence Test," and shall a coefficient of Retroreflection (R a)

of not less than 100 cd / lux /m 2 (cd/ fc / f t 2) and shall be designated as flourescent." SUBSTANTIATION: It is possible for trim to be used on emergency medical garments. While trim should not be required for emergency medical garments, when used, it should meet certain minimum requirements. COMMITTEE ACTION: Hold. COMMITTEE STATEMENT: See Committee Actions taken on Comments 1999-11 (Log #69) and 1999-48 (Log #82).

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NTPA 1999 - - A 9 7 ROC

(Log #8) 199% 37- (5-1.2): Reject SUBMITTER: Bill Grilliot, Morning Pride Mfg Co. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Change "garment material" to "barrier layer."

SUBSTANTIATION: Only test barrier layer - not garment material. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Garment material is the appropriate term as the "assembled" garment may undergo the preconditioning. (See 6-3.7.2) Barrier layer is correctly specified in the test method (6-3.7.1).

(Log #76) 1999- 38- (5-1.3, 6-4): Reject SUBMITTER: Jeffrey o . Stull, Int'l Personnel Protection, Inc. COMMENT ON PROPOSAL NO: 199%7 RECOMMENDATION: Delete performance requirement in 5-1.3 and test method in 6-4.

SUBSTANTIATION: Tensile testing of materials can only be applied to one layer of a multilayer system and therefore biases results to one layer systems. Burst strength and puncture propagation tear resistance tests adequately define garment material strength and hazard resistance properties and can be applied to multilayer garment systems. This change is consistent with the change made to NFPA 1993 from the 1990 to 1994 edition on which these test requirements are based. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The Technical Committee feels it is necessary that each separable layer must meet the minimum physical performance requirements as composite testing would only show the performance of the strongest layer of the composite.

(Log #78) 1999- 41 - (5-2.5): Reject SUBMITTER: Jeffrey o . Stull, Int'l Personnel Protection, Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Change requirement for puncture resistance in paragraph 5-2.5 to "not less than 3.6N (0.8 lbs)". SUBSTANTIATION: Interlaboratory variation in the way that this test is conducted suggests a wide range of test results for the same product. Since the requirement was originally introduced for defining acceptable glove performance on one laboratory's test results, the criteria bear reexamination to ensure that a consistent performance level is established. COMMI'VrEE ACTION: Reject. COMMITrEE STATEMENT: Testing Laboratories do not agree with that interlaboratory variation is a problem.

There does not appear to be an industry problem in meeting the proposed requiremenL

(Log #79) 1999- 42- (5-2.6): Reject SUBMITTER: Jeffrey O. Stull, Int'l Personnel Protection, Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Change requirement in paragraph 5-2.6 from "not less than 25 g"

to "not less than 20g". SUBSTANTIATION: When the requirement was first proposed as a new requirement for glove cut resistance, limited data was available for setting a minimum performance level. Subsequently, new data has been generated and a cut resistance of 20.g appears to discriminate between acceptable and nonacceptable cut resistance. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Action taken on Comment 1999-43 (Log #60).

(Log #59) 199% 39- (5-1.5): Reject SUBMITTER: Kimberly Henry, Underwriters Laboratories Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Revise text to read: "Specimens of the barrier layer of the garment shall be tested for

bursting strength..." SUBSTANTIATION: The ASTM Method for burst strength is applicable to coated fabrics only. This test is not suitable for separable layers, such as, outer shell fabrics, winter liners, etc. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The Technical Committee feels it is necessary that each separable layer must meet the minimum physical performance requirements as composite testing would only show the performance of the strongest layer of the composite.

(Log #77) 1999- 40 - (5-1.6, 6-7): Reject SUBMITTER: Jeffrey O. Stull, Int'l Personnel Protection, Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Delete performance requirement in 5-1.6 and test method in 6-7.

SUBSTANTIATION: Tear resistance testing of materials can only be applied to one layer of a multilayer system and therefore biases results to one layer systems. Burst strength and puncture propagation tear resistance tests adequately define garment material strength and hazard resistance properties and can be applied to multilayer garment systems. This change is consistent with the change made to NFPA 1993 from the 1990 to 1994 edition on which these test requirements are based. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The Technical Committee feels it is necessary that each separable layer must meet the minimum physical performance requirements as composite testing would only show the performance of the strongest layer of the composite.

(Log #60) 1999- 43 - (5-2.6 and 6-14): Accept SUBMI'I'rER: Kimberly Henry, Underwriters Laboratories Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

I Delete 5-2.6 and 6-14, the Cut Resistance Test and references to this test. SUBSTANTIATION: This test method has not been completed or published by ASTM. Insufficient background and data to support the test method at this time. COMMITTEE ACTION: Accept.

(Log #80) 1999- 44- (5-2.8): Accept SUBMITTER: Jeffrey O. Stull, Int'l Personnel Protection, Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

Change the requirement in paragraph 5-2.8 from "no greater than 1000 p.g/g" to "no greater than 100 }xg/g". SUBSTANTIATION: While no source has been able to substantiate a lower limit of glove proteins which constitutes a concentration less likely to result in an allergic reaction, the industry agrees that lower levels of glove proteins are "better" and are achievable in the manufacturing of natural rubber based medical gloves. COMMITTEE ACTION: Accept.

(Log #61) 1999- 45 - (5-2.8 and 6-16): Reject SUBMITTER: Kimberly Henry, Underwriters Laboratories Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Delete the Protein Content Test and all references to this test.

SUBSTANTIATION- Insufficient background and data to support the requiredprotein levels. COMMITTEE ACTION: Reject.

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NFPA 1999 - - A 9 7 ROC

COMMITTEE STATEMENT: The Technical Committee feels the issue of human protein sensitivity is a relevant hazard for users and needs to be addressed by the performance requ i rement and test method. Available data supports the position that sensitization reactions are

correlated with the protein content of natural rubber latex. Use of emergency medical gloves is required in all EMS

operations by NFPA 1500, Fire Depar tment Occupational Safety and Health Program and NFPA 1581, Fire Depar tment Infect ion Control Program, and natural rubber latex gloves are the most prevalent emergency medical glove in use.

(Log #81) 199% 46 - (5-3.x, 6-x): Hold SUBMITTER: Jeffrey 0 . Stull, Int'l Personnel Protection, Inco COMMENT ON PROPOSAL NO: 199%7 RECOMMENDATION: Add new performance requirement: "5-3.X Specimens of face protection devices designated for

multiple use shall be tested for scratch resistance as specified in 6- X, 'Face Protection Device Scratch Resistance Test,' and shall not exhibit a delta haze of greater than 25.0 percent." Also add Section 6-23 Ks modif ied for face protect ion devices from NFPA 1971 (1996 ROC). SUBSTANTIATION: Face protect ion devices should provide adequate resistance to scratch as is required for helmet visors and SCBA facepieces. COMMITTEE ACTION: Hold. COMMITTEE STATEMENT" See Committee Actions taken on Comments 1999-32 (Log #71), 1999-33 (Log #72), 1999-34 (Log #73), and 1999-35 (Log #74L

(Log #27) 199% 47- (5-3.2): Accept SUBMrVrER: Dan Gohlke, W.L. Gore & Assoc. COMMENT ON PROPOSAL NO: 199%7 RECOMMENDATION:

Revise 5-3.2 text as follows: " and shall allow no ~ - v c a t - e r - penetrat ion. SUBSTANTIATION: This language is consistent with the language in the test method. COMMITTEE ACTION: Accept. COMMITTEE STATEMENT:

(Log #82) 199% 48 - (6-x (New)): Hold SUBMITTER: Jeffrey o . Stull, Int'l Personnel Protection, Inc. COMMENT ON PROPOSAL NO: 199%7 RECOMMENDATION: Include new test method, 6-X, "Retroreflectivity and Fluorescence

Test." 6-X Retroreflecfivity and Fluorescence Test. 6-)(.1 Application. 6-X.I.1 This test me thod shall apply to trim materials used on

garments. 6-X.1.2 Trim material specimens shall be tested for each

procedure specified in 6-X.4 6-X.1.3 Trim materials wiaich are used on garments that are

des igned for single use or multiple use in accordance with 4-1.1 sha l l be subjected to different sample preparat ion procedures specified in 6-X.3.

6-X.2 Specimens. 6-X .2.1 A min imum of three trim test specimens shall be tested. 6-X.2.2 Except as specified in the test procedures referenced in 6-

X.4.3, each trim test specimen shall consist of a 30.5 cm X 30.5 cm (12 in. X 12 in.) composite made up of multiple strips of the f inished trim product . Where retroreflective and non- retroreflective surface areas are combined to form a trim, the complete f inished product consisting of the retroreflective and non-retroreflective portions shall be used to form the composite test specimen.

6-}(.2.3 Specimens for testing in 6-X.4.3 shall be as specified in the test methods referenced in those paragraphs.

6-X.3 Sample Preparation.

6-X.3.1 Samples of trim for single-use garments shall be condi t ioned as specified in Section 6-1.2. Samples for condit ioning shall include 30.5 cm (12 in.) long sections of trim.

6-X.3.2 Samples of trim for multiple-use garments shall be condi t ioned as specified in Section 6-1.3. Samples for conditioning shall include material sewn onto a 1-m (1-yd) square of ballast material no closer than 5.08 cm (2 in.) apart in parallel strips. The ballast material shall be as specified in ANSI/AATGC 135, "Dimensional Changes in Automatic Home Launder ing of Woven and Knit Fabrics." Specimens shall be removed from the ballast material prior to testing.

6-X.4 Procedures. 6-X.4.1 Measurement of Coefficient of Retroreflectivity. 6-X.4.1.1 The Coefficient of Retroreflection (Ra) shall be

measured in accordance with ASTM E 809, "Standard Test Method for Measuring Photometr ic Characteristics of Retroreflectors," using the following modifications:

(a) Test distance = 15.2 m (50 ft); (b) Observation angle = 0.2 degree; (c) Entrance angle = -4.0 degree; (d) The receiver shall be provided with an entrance aperture of

26 mm (1.024 in.), -+5 percent, in diameter which is equivalent to 0.1 degree angular aperture;

(e) The exit aperture of the source shall be circular and 26 mm (1.024 in.), -+5 p e r c e n t , in d iameter which corresponds equivalent to 0.,1 degree angular aperture;

(f) Retroreflector reference angle = 90 degrees; and (g) Datum mark shall be placed as specified by the trim

manufacturer . 6-X.4.1.2 The coefficient of Retroreflection (R a) shall be

calculated by the following equation: R a = R I / A r where: R I is the coefficient of luminous intensity measured as

specified in 6-X.4.1.1} and A r represents only the retroreflective surface are of the trim test specimen's surface area. A r shall be calculated by subtracting tile non-retroreflective surface area from the test specimen's total surface area.

6-X.4.2 Evaluation of Fluorescence. 6-X.4.2.1 Trim fluorescence shall be de te rmined by examining

the material under a black light at a distance of 30.5 cm (12 in.) for a per iod of 30 seconds.

6-X.4.2.2 Specimens which exhibit f luorescence shall be designated as fluorescent. Specimens which do no t exhibit f luorescence shall be designated as non-fluorescent.

6-X.4.3 Rainfall Test. 6-X.4.3.1 Specimens of trim shall be tested for retroreflectivity

when wet as specified in Annex A of EN 471, "High Visibility Warning Clothing," at a rate of 4.3 in. per hour (10.4 cm per hour ) .

6-X.4.3.2 The Coefficient of Retroreflectivity shall be measured as specified in 6-X.4.1.2 rain. -+15 sec. after the rainfall exposure has been started.

6-X.4.3.3 The fluorescence shall be evaluated as specified in 6- X.4.2.2 min. +15 sec. after rainfall exposure has been started.

6-X.5 Report. 6-X.5.1 The Coefficient of Retroreflectiou (R a) shall be reported

for each specimen. The average Coefficient of Retroreflection (R a) of all specimens shall be calculated and repor ted separately for each of the test procedures specified in 6-X.4.1 and 6-X.4.5.

6-X.5.2 The number of f luorescent and non-fluorescent specimens shall be repor ted separately for each of the test procedures specified in 6-X.4.2 and 6-X.4.5.

6-X.6 Interpretation. 6-X.6.1 For trim retroreflectivity, pass/fall performance shall be

de te rmined using the average Coefficient of Retroreflection (R a) of all specimens tested for each procedure above.

6-X.6.2 For tr im fluorescence, any non f luorescent specimens in any test procedure shall constitute failing performance.

Also add reference for EN 471 in Chapter 7. 7-1.2.6 EN Publication. EN 471, High Visibility Warning Clothing, 1994.

SUBSTANTIATION: It is possible for trim to be used on emergency medical garments. While trim should not be required for emergency medical garments, when used, it should meet certain mi n i mum requirements . COMMITTEE ACTION: Hold. COMMITTEE STATEMENT: See Committee Actions taken on Comments 1999-11 (Log #69) and 1999-36 (Log #75).

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NFPA 1999 - - A 9 7 ROC

(Log #9) 1999 49 - (6-1.3.1): Reject SUBMITTER: Bill Grilliot, Morning Pride Mfg Co. COMMENT ON PROPOSAL NO: 19997 RECOMMENDATION: Change 25 cycles to 5 cycles°

SUBSTANTIATION: 5 cycles is consistent with o ther NFPA standards for multiple use garments. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Five cycles are not the constant as NFPA 1977 requires 50 cycles and NFPA 1975 requires 100 cycles. See also Commit tee Actions taken on Comments 1999-50 (Log #53) and 1999-51 (Log #CC2).

(Log #53) 1999 50 - (6-1.3.1): Reject SUBMITTER: William Grob, Aldan Industries COMMENT ON PROPOSAL NO: 19997 RECOMMENDATION: Delete and substitute: 6-1.3.1 Samples shall be subjected to 10 cycles of washing and

drying in accordance with the procedure specified in Machine Cycle 1, Wash Tempera ture V, and Drying Procedure Ai, of ANSI/AATTCC 135, Dimensional Changes in Automatic Home L a u n d e r i n g o f Woven and Knit Fabrics. SUBSTANTIATION: The technology does not exist for manufacturers to seal seams that will pass biophase testing, 100 percent of the time, after 25 wash cycles in combination with other

~ recondit ioning. If we retain 25 cycles, all reusable garments may e eliminated from the market.

COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The Technical Committee has been informed that the technology exists for meet ing the 25 cycles. Further, this is a requi rement for screening durability of non-single use garments and the Technical Committee believes the 25 cycles is the necessary min imum requirement . See also Committee Action taken on Comments 1999-49 (Log #9) and 1999-51 (Log #CC2).

(Log #CC2) 1999 51 - (6-1.3.1): Accept SUBMITTER: Technical Commit tee on Emergency Medical Services Protective Clothing and Equipment COMMENT ON PROPOSAL NO: 19997 RECOMMENDATION:

Revise 6-1.3.1 to read: "Samples ...Machine Cycle 3, Wash Tempera ture III, and Drying Procedure Aiii of ANSI/AATCC135,

SUBSTANTIATION: The Technical Commit tee has changed the washing criteria to reflect the types of synthetic fabrics principally used in emergency medical garments. COMMITTEE ACTION: Accept.

COMMITTEE STATEMENT: The Technical Commit tee has been informed that the technology exists for meet ing the 25 cycles. Further this is a requ i rement for screening durability of non-single use garments and the Technical Committee believes the 25 cycles is the necessary requirement . See also Commit tee Action taken on Comments 1999-49 (Log #9) and 1999-51 (Log #CC2).

Submitter was present at the ROC meet ing and wished to withdraw the comment , so he agreed with the rejection.

(Log #83) 1999- 53 - (6-1.4, 6-1.5): Accept SUBMITTER: Jeffrey O. Stull, Int'l Personnel Protection, Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

Delete sections 6-1.4 and 6-1.5 and all references to these sections throughout the s tandard in Chapter 6. SUBSTANTIATION: It has not been demonstra ted that the protocols established in sections 6-1.4 and 5-1.5 provide a realistic demonstra t ion of conditions appropria te for emergency medical garments. COMMITTEE ACTION: Accept.

(Log #62) 1999- 54 - (6-1.4(c)): Reject SUBMITTER: Kimberly Henry, Underwriters Laboratories Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Revise text to read: "An 80 grit abradant trimite C-weight open coat, or equivalent,

shall be used." SUBSTANTIATION: The 80 grit trimite E-weight abradant currently proposed is too abrasive and does no t truly represent the normal wear and abrasions an EMS garment endures. A G-weight abradant is more suited for testing materials used for EMS

arments. OMMITTEE ACTION: Reject.

COMMITTEE STATEMENT: The requi rement was deleted. See Committee Action taken on Comment 199953 (Log #83).

(Log #38) 1999- 55 - (6-1.5,1): Accept SUBMITTER: Dan Gohlke, W.L. Gore & Assoc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

[ Revise 6-1.5.1 as follows: "... cg~d't'cn"~ cond i t ioned " SUBSTANTIATION: Spelling error. COMMITTEE ACTION: Accept.

(Log #12) 1999 52 - (6-1.3.4): Reject SUBMITTER: Todd R. Carroll, Kappler Safety Group COMMENT ON PROPOSAL NO: 19997 RECOMMENDATION: Revise text as follows: 6-1.3.4 A laundry bag shall only be used if specified in the care

and maintenance instructions supplied by the manufacturer. In the absence of such recommendat ion , a laundry bag shall not be used. SUBSTANTIATION: Section 6-1.3.4 can be contradictory to 6- 1.3.3 if the manufacturer specifically recommends the use of a laundry bag. As written, it would appear that the testing laboratory could be required to go against a manufacturer 's recommendat ion. I do not believe that the spirit of the s tandard is compromised by adher ing to manufacturer s recommendat ions for care and maintenance. I also do not believe that it is in the best interest of NFPA to test in a m anne r that specifically contradicts manufacturer 's recommendat ions . Launder ing without a laundry bag may inflict additional stresses to a garment that would not normally occur if laundered with a bag. COMMITTEE ACTION: Reject.

(Log #13) 1999- 56 - (6-2.5.1): Accept SUBMITrER: Todd R. Carroll, Kappler Strew Group COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

I Revise text as follows: "6-2.5.1(f) Inspection of the specimen shall be completed within 1O minutes of the end of the liquid spray exposureper iod ." SUBSTANTIATION: Failure by this me thod is de te rmined by the visual or tactile detect ion of water on the liquid-absorptive under- garment. Method sensitivity is affected by percentage contact between file outer and inner garments, tactile sensitivity of the inspector, and the evaporation rate of the challenge liquid. Obviously, evaporation rate is affected by time a n d temperature. Higher temperatures and ex tended inspection times will result in lower sensitivities. Minimizing the total allowable time between the end of the exposure and the end of inspection is crucial to maximizing the sensitivity of this method. Even a 10 minute period might be too long since small quantities of water can easily evaporate in this amount of time. COMMITTEE ACTION: Accept.

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N F P A 1999 m A97 R O C

(Log #23) 1999- 57 - (6-2.5.1 (f)): Accept SUBMITTER: Catherine 1L Dodgen, Inchcape Testing Services / E T L Testing Lab, Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

Revise text as follows: "(f) The liquid-absorptive garment on the mannequ in shall be inspected within 10 minutes.. ." SUBSTANTIATION: The original wording says to inspect the e~p..Cgtt]0.glt (i.e., the garment) for evidence of liquid penetrat ion. This is inconsistent with 6-2.7.1 which specifies de te rmin ing pass/fai l .based on the liquid-absorptive garment . The other option would be to revise 6-2.6.1 and 6-2.7.1 to be consistent with the original text. COMMITTEE ACTION: Accept.

1999- 58 - (6-2.7.1): Reject (Log #14) SUBMITTER: Todd R. Carroll, Kappler Safety Group COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Revise text as follows: 6-2.7.1 Any evidence of liquid on the liquid-absorptive garment,

or the interior of the specimen, as de te rmined by visual inspection, tactile inspection, or by absorbent toweling shall constitute failure of the specimen. SUBSTANTIATION: The sensitivity of this test is in large part de te rmined by the percentage contact between the specimen and the liquid-absorptive inner-garment, ff intimate contact is not made between ttae two garments, leakage may not be detected. For this reason, the interior o f the specimen should also be inspected using visual, tactile, and absorptive toweling techniques. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The Technical Commit tee feels the sensitivity of inspecting the liquid absorptive garment is sufficient given the severity of the test exposure. T h e Technical Committee also feels this technique improves the reproducibili ty of the the test.

(Log #1) 1999- 59 - (6-3): Reject SUBMITTER: Nathan L. Belkin, Clearwater, FL COblblENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: It has been brought to my attention that your Technical

Committee for this documen t has included the ASTM's recently adopted test methods for Protective Clothing- F1670-95 and F1671- 95 - as an integral part of its contents.

As a former m e m ber of your organization now 'retired' after a 37 year career in the healthcare industry, I would like to take this opportuni ty to submit my comments as to why these test me thods are NOT appropr ia te for this unique application.

1) Although the test methods were primarily adopted to protect the members of the surgical community from the hazards associated with the transmission of b loodborne pathogens, they have no t been ei ther endorsed or suppor ted by any professional clinical society. Quite to the contrary, the American College of Surgeons had gone on record with the ASTIVl as being opposed to their adoption;

2) the clinical l i terature indicates that the levels of pressure exper ienced by those participating in invasive type of procedures exceed the "pass" l eve ladop ted by the ASTM which obviously accounted for the penetra t ion of "pass" products repor ted under in-vivo conditions;

3) the test's pass~fail results do no t distinguish between levels o f challenge, i.e., spray, splash and soak, and prohibi t the employer /user f rom selecting the level of protect ion that they believe is required for the anticipated level of exposure;

4) to provide all EMS personnel with what the mater ia l /garment manufacturers consider to be the maximum ("pass") in protect ion is no t fiscally responsible and could adversely influence the allocation of financial resources available from funding agencies as well as the resources of individuals that serve in a volunteer capacity who may be responsible for their own clothing;

5) using the ASTM test methods for intermit tent testing of the material's effectiveness during the ~arment 's life expectancy necessitates destruct ion of one of Its components , Le., ann, leg, f ront or back panel;

6) with the tests' criteria for a "pass" predicated on a fabric's ability to resist penetra t ion at a level of pressure of 2 pounds per

square inch (psi), a superior product , e.g., one able to withstand 2.5 or 3 psi, would still be identified as a "pass;"

7) the ASTM reportedly is considering other test methods for protective clothing whose results are expressed in terms of the level of pressure a material is able to withstand; and

8) it might be advisable for the NFPA to arrange to conduct some tests designed to ascertain the effect that the protective clothing would have on the wearer under actual conditions of use in terms of mobility, heat stress and comfort.

It is my hope that these comments will be viewed in the vein in which they are being submitted. SUBSTANTIATION: None. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: 1. EMS are delivered in emergency settings without the equipment and order of a health care facility. EMS providers are required by OSHA regulations to have barrier protect ion f rom blood borne pathogens and this test provides the evaluation of barriers. This s tandard support and amplify the efforts to educate and protect EMS personnel from blood-borne pathogens.

The NFPA Technical Commit tee on Emergency Medical Services Protective Clothing and Equipment , who is responsible for NFPA 1999, and NFPA Technical Commit tee on Fire Service Occupational Safety and Health, who is responsible for 1500, Standard Oh Fire Depar tment Occupational Safety and Health Program, require a viral barrier protect ion for EMS providers. ASTM F1671 is the only nationally developed, consensus standard which measure the penetrat ion of a virus through a protective clothing fabric. The surrogate viral challenge was chosen based on scientific studies pe r fo rmed by FDA personnel , that demonstrates its efficacy as a viral surrogate for HW and HBV for penetrat ion studies.

2. There are some clinical studies that have indicated that a garment material may occasionally see shor t durat ion pressures in excess of the ASTM F1671 test pressure dur ing invasive, surgical

~ rocedures. Other studies suggest that the 2 psi requi rement is too igh. There is also some bel ief that the high pressures repor ted in

some clinical studies has a different effect on fabrics than the hydrostatic pressures represented by ASTM F1671. In no case, do we have a study pressures seen on clothing dur ing EMS events. We are no t aware of any reports that garment comprised of materials that pass ASTM 1671, have failed in either invasive surgical procedures or in EMS situations.

3. At this time, there is no generally accepted definition of spray, splash or soak. Without a generally accepted definition of performance, there is no way to define test methods. Nor have guidelines been established when to wear garments that protec t against spray, protec t against splash and pro tec t against soak. NFPA 1500 and 1581 require EMS providers wear gloves at all times while delivering patient care. W h e n face protect ion and garments are required they must provide viral barrier as evaluated by ASTM F1671.

4. Gloves are the only equipment required to be worn in all EMS situations by NFPA 1500, Standard o n F i r e Depar tment Occupational Safety and Health Program and NFPA 1581, Standard on Fire Depar tment Infection Control Program. Other personal protective equipment , i.e., emergency medical garments, and emergency medical face protective devices, are to be used for any situation where the potential for contact with blood or other body fluids is high. Except for gloves, there are no requirements that all equ ipment be worn in all situations.

Personal protective equ ipment used in emergency medical care, including masks, splash-resistant eyewear, gloves and fluid-resistant clothing, shall be present on all fire depa r tmen t vehicles that provide emergency medical operations.

5. There is no intent ion in this s tandard to routinely measure the material 's barrier effectiveness after several uses. Instead, the precondi t ioning requirements for multiple use are more controlled methods to assess per formance after multiple uses.

6. It is not the in ten t o f ASTM F1671 to differentiate performance o ther than pass/fail, nor has it been demons t ra ted that such differentiation is required to de termine if the barrier is adequate.

7. When ASTM adopts o ther methods for measuring viral barr ier Ptherformance and when such methods can improve NFPA 1999,

en it will be relevant to discuss those methods as a supplement to or a rep lacement of ASTM F1671.

8. It is up to the manufacturers to provide the best balance of protection, mobility, heat buildup and comfort. End-users in making their purchase decision has the ability to choose clothing on a number of factors, including comfort and mobility, that are not specifically addressed in the standard.

2 0 6

NFPA 1999 - - A 9 7 ROC

(Log #22) 199% 60- (6-3.3.2): Accept SUBMITTER: Catherine R~ Dodgen, Inchcape Testing Services /ETL Testing Lab, Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

Revise text as follows: "6-3.3.2 Samples of multiple use garments, including seams, shall be conditioned ..." SUBSTANTIATION: In 5-1.2 testing of seams is specified but in 6-3.3.2 it is not clear whether seams would be subjected to 25 cycles of laundering, flexing, and abrasion or whether flexing and abrasion applies only to flat material. If seams are not intended to be flexed and abraded, 6-3.3.2 should be revised to make that clear. COMMITTEE ACTION: Accept.

(Log #37) 199% 61 - (6-3.3.2): Accept SUBMITTERz Dan Gohlke, W.L. Gore & Assoc. COMMENT ON PROPOSAL NO: 199%7 RECOMMENDATION:

I Revise 6-3.3.2 as follows: "6-3.3.2 Samples of multiple use garments shall be conditioned as specified in 6-1.3 add then as specified in 6-1.2."

Delete the rest of 6.3.3.2 mad also 6-1.4, 6-1.5, 6-3.7.2, 6-3.7.3, 6- 3.7.4. SUBSTANTIATION: In conjunction with the increased washing cycles, these conditioning requirements are excessive and no longer necessary. I have examples to submit to the committee in November demonstrating rials point. Deleting these preconditioning requirements has already been done for single use garments. COMMITTEE ACTION: Accept.

(Log #63) 199% 62 - (6-3.3.2): Accept in Principle SUBMITTER: Kimberly Henry, Underwriters Laboratories Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Add new text: "6-3.3.2 Samples of multiple-use garment seams shall be

conditioned as specified in 6-1.2" Current paragraph 6-3.3.2 should be renumbered to 6-3.3.3.

Current paragraph 6-3.3.3 should be renumbered to 6-3.3.4. SUBSTANTIATION: Paragraph 5-1.2 requires that garment seams be tested for Phi-X-174 bacteriophage, but a section regarding

reparation of garments seams was not included in 6-3.3 OMMITTEE ACTION: Accept in Principle.

COMMITTEE STATEMENT: See Committee Action taken on Comment 1999-60 (Log #22).

(Log #55) 199% 65 - (6-3.7.2): Reject SUBMITTER: Daniel Silvestri, Aldan Rubber Co. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Delete and substitute: 6-3.7.2 Specimens for conditioning as specified 6-1.3, 6-1.4, and

6-1.5 shall be permitted to be garment materials configured as in the construction. SUBSTANTIATION: Seams and materials utilized in multi layer garments should be conditioned as configured in the actual construction for washing, flexing, and abrasion preconditioning to remmn consistent. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The requirement was deleted. See Committee Actions taken on Comments 199%53 (Log #83) and 1999-61 (Log #37).

(Log #21) 199% 64- (6-5.1.1): Accept SUBMITTER: Catherine R. Dodgen, Inchcape Testing Services /ETL Testing Lab, Inc. COMMENT ON PROPOSAL NO: 199%7 RECOMMENDATION:

Revise 6-5.1.1 to delete "...then all layers, assembled in the same order in which they appear in the i~arment, shall be tested as a composite." Insert (at that point) '... each separable layer of garment material shall be tested." SUBSTANTIATION: The performance requirement in 5-1.4 already specifies that all separable layers be tested; also, this makes 6-5.1.1 consistent with the practice for the other material strength requirements (such as tensile strength, PPT, trap tear). COMMITTEE ACTION: Accept.

(Log #39) 1999- 65 - (6-5.1.1): Accept in Principle SUBMITTER: Dan Gohlke, W.L. Gore & Assoc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Delete current wording and replace with: 6-5.1.1 This test shall be applied to each layer of materials used

in the construction of garments. SUBSTANTIATION: I understand that all the physical property tests would be applied to each layer as is stated in 6-4.1.1 and 6- 7.1.1. COMMITTEE ACTION: Accept in Principle. COMMITTEE STATEMENT: See Committee Action taken on Comment 1999-64 (Log #21).

(Log #65) 1999- 66- (6-5.1.1): Reject SUBMITTER: Kimberly Henry, Underwriters Laboratories Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Add new text: "This test shall apply only to the barrier layer used in the

construction of the garment. Delete text: "If the garment is constructed..."

SUBSTANTIATION: In lieu of our comment on section 5-1.5. It is not suitable to test a composite or non coated materials using this method. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Actions taken on Comments 1999-38 (Log #76) and 199%64 (Log #21).

(Log #41) 1999- 67 - (6-5.3A, 6-6.3.1, 6-7.3.1, 6-8.3.1): Accept SUBMITTER: Dan Gohlke, W.L. Gore & Assoc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

Revise 6-5.3.1, 6-6.3.1, 6-7.3.1, and 6-8.3.1 as follows: "Samples for conditioning shall be --1-m -2- (1 zq 7~-.) cf matz-al

the entire garmet~t." SUBSTANTIATION: I understood that the conditioning of garments would be on the whole garment as indicated in 6-4.3.1 and 6-3.3.2. COMMITTEE ACTION: Accept.

(Log #42) 1999- 68 - (6-5.3.3, 6-6.3.3, 6-7.3.3): Accept SUBMI'I"TER: Dan Gohlke, W.L. Gore & Assoc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

Revise 6-5.3.3, 6-6.3.3, and 6-7.3.3 to add: "...specified in 6-1.3 and then conditioned as specified ill 6-1.2." SUBSTANTIATION: This makes it clear that the conditioning includes room temperature conditioning as is done in 6-4.3.3. COMMITTEE ACTION: Accept.

(Log #20) 1999- 69- (6-6.1.1): Accept SUBMITTER: Catherine IL Dodgen, Inchcape Testing Services /ETL Testing Lab, Inc- COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

Add to 6-6.1.1: "...If the garment is constructed of several layers, then each separable layer of garment material shall be tested." SUBSTANTIATION: The performance requirement in 5-1.5 already specifies that all separable layers be tested; also, this makes 6-6.1.1 consistent with the practice for the other material strength requirements (such as Mullen burst, trapezoided tear, tensile strength). COMMITTEE ACTION: Accept.

(Log #40) 1999- 70 - (6-6.1.1): Accept in Principle SUBMITTER: Dan Gohlke, W.L. Gore & Assoc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Delete current wording and replace with the following: 6-6.1.1 This test shall be applied to each layer of materials used

in the construction of garments.

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SUBSTANTIATION: I unde r s t ood tha t all the physical property tests would be appl ied to each layer as is stated in 6-4.1.1 and 6- 7.1.1. COMM/TTEE ACTION: Accept in Principle. COMMITTEE STATEMENT: See Commit tee Action taken on C o m m e n t 1999-69 (Log #20).

(Log #66) 1999- 71 - (6-6.1.1): Accept in Principle SUBMITTER: Kimberly Henry , .Underwriters Laborator ies lnc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Revise text to read: "If the g a r m e n t is cons t ruc ted of several layers, t hen each layer

shall be tested separately." SUBSTANTIATION: Paragraph 5-1.5 states tha t each seperable layer shall be tested for punc ture . COMMITTEE ACTION: Accept in Principle. COMMITTEE STATEMENT: See Commi t tee Action taken on C o m m e n t 1999-69 (Log #20).

(Log #67) 1999- 72 - (6-10.2.1): Reject SUBMITTER: Kimberly Henry , Underwri ters Laborator ies Inc. COMMENT ON PROPOSAL NO: 199%7 RECOMMENDATION: Revise text to read:

"A m i n i m u m of three whole-glove." SUBSTANTIATION: Three spec imen are always tested for Bacter iophage. COMMITTEE ACTION: Reject. Revise first sen tence of 6-3.2.1 to read:

"A m i n i m u m of five spec imens shall be tested." COMMITTEE STATEMENT: Tire Technical Commi t t ee feels tha t five spec imens are necessary to demons t r a t e an acceptable level of pe r fo rmance .

In addit ion, the Technical Commi t t ee revised 6-3.2.1 to read "five specimens" for consis tency in the test methods .

(Log #84) 1999- 73 - (6-13.4.1): Hold SUBMITTER: Jeffrey o . Stull, Int'l Personnel Protection, Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Change paragraph 6-13.4.1 to read: "6-13.4.1" Spec imens shall be tested in accordance with ASTM Y

1342, S tandard Test Method for Resistance of Protective Clothing Materials to Puncture , with the following modifications:

(a) A 0.025 m m (0.01 in.) thick u l t rah igh molecular weight h igh density polyethylene shall be used as a s t andard re ference material.

(b) Punc tu re probes shall first be qualif ied before use in test ing by showing an average punc tu re resistance of 10.3 N(2.32 lbs).

(c) The compress ion load cell shall have range capable of d iscern ing 0.4 N (0.1 Ib) in the range suitable for the glove material being tested. The uppe r limit of the load cell shall be no more than 10 t imes the ac tua l punc tu re resistance measu red for the glove specimens .

A-6-13.4.1 A suitable reference material is available f rom Allied Signal, Inc., 1 95 and Walthall Exit 5, P.O. Box 31, Petersburg, VA 23804, 804-520-3146. SUBSTANTIATION: With he specification of a s t andard reference material a n d acceptance criteria for the punc tu r e probe, there can be a wide range in the repor ted results f r om different laboratories. COMMITTEE ACTION: Hold. COMMITTEE STATEMENT: T he Commi t tee did no t have the necessary t ime du r ing the ROP process to address this change in test ing procedure .

(Log #85) 1999- 74 - (6-14): Reject SUBMITTER: Jeffrey o . Stull, Int'l Personnel Protection, Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Make the changes to the "Cut resistance Test" in Section 6-4 as

follows: Revisions to Section 6-14, Cut Resistance Tes t 1. Revise and "on a spec imen ho lder (C)" to "on a mandre l (G)"

a n d "by weights (D)" to "by weights (E)" in pa rag raph 6-14.4.1.

2. Revise "to 1 m m (1 /25 in.)" to "to 0.1 m m (0.004 in.)" in paragraph 6-14.4.2.

3. Add new paragraph 6-14.4.3: "6-14.4.3 Weights (E) shall be m o u n t e d on the lever a rm

assembly. The appara tus shall be capable of hand l ing loads rang ing f rom 10 g (35 oz.) to 15 kg (33 lbs). "

R e n u m b e r existing paragraphs 6-14.4.3, 6-14.4.4, and 6-14.4,5. 4. Revise the second sen tence of pa rag raph 6-14.4.4 to read, "The

surface of the mandre l shall shall be m a d e e i ther o f a e lectroconduct ive material or be covered with an electroconductive material. Double faced tape shall be used to secure the spec imens to the mandre l .

5. Add new paragraph 6-14.4.7: "6-14.4.7" A 1.57 m m (0.062 in.) -+10 pe r cen t thick Neoprene®

having a hardness of 50 +-5 Shore A shall be used as the calibration material .

A-6-14.4.7 Neoprene®, style NS-5550, or equivalent suppl ied by Fairprene 85 Mill Plain Road Fairfield CT 06340 203-259-3351, has proven satisfactory for a calibration material."

6. Add to the end of the second sen tence in pa ragraph 6-14.5.1, "," or when chang ing a blade supply f rom a different manu fac tu r i ng lot number . "

7. Add to the end of pa ragraph 6-14.5.1: ' T h e cut t h rough lengths at the beg inn ing and end of each

sample test should not differ in l eng th by more than 10 m m (0.40 in.). W h e n the length of cut t h r o u g h is outside these distances, the following shall be checked:

(a) Newness of the cut t ing edges; (b) The correc~ n e o p r e n e calibration material is being used; and (c) The calibration p rocedure for the level a rm indicates that the

force at po in t of contact is 400 g (0.88 lbs). 8. Add to the end of the first sen tence in paragraph 6-14.5.3, "at

least once a m o n t h or whenever the appara tus is moved." 9. Revise paragraphs 6-14.5.14.1, 6-14.5.14.2, and 6-14.5.14.3; add

new paragraph 6-14.5.14.4 as follows: 6-14.5.14.1 If no cut occurs with one 50 m m (2.0 in.) traverse of

rite blade, the test appara tus shall be s topped, the weights and blade shall be removed, and the cutt ing a rm shall be rested on the support . The spec imen shall t hen be moved 6 m m (0.25 in.) to a new spot, a new blade shall be installed, rite load shall be increased, the distance mete r shall be zeroed, and the test restarted as descr ibed in 6-14.5.14. Test ing shall con t inue with changes in loads until a cut is observed within one traverse of the blade which causes the test appara tus to stop. The distance mete r shall be read and the distance and load shall be recoded if the cut is with the acceptable range of 5 to 50 m m (0.2 to 2.0 in.). Test ing shall be con t inued as specified in 6-14.5.14.3.

6-14.5.14.2 ff a cut occurs with one 50 m m (2.0 in.) traverse of the blade, the test appara tus shall s top automatically. Th e distance mete r shall be read and the dis tance and load shall be recorded if the cut is within the acceptable range of 5 to 50 m m (0.2 to 2.0 in . ) .

6-14.5.14.3 Ad jus tmen t of loads shall be con t inued as n e e d e d an d retes t ing shall be pe r fo rmed to collect 5 data points in the 5 - 20 m m (0.2 to 0.8 in.) cut length range, 5 da ta points in the 32 to 50 m m (1.3 to 2.0 in.) cut length range, and 5 addit ional points at any loading selection in between those used for the uppe r and lower cut ranges.

6-14.5.14.4 This de te rmina t ion shall require a total of 15 data

~ oints to be collected. UBSTANTIATION: Improvemen t s in the cut resistance test

me thodo logy have been identif ied by the ASTM F-23 commit tee . COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Commi t t ee Action taken on C o m m e n t 1999-43 (Log #60).

(Log #43) 1999- 75 - (6-14.4.1): Reject SUBMITTER: Dan Gohlke, W.L. Gore & Assoc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Revise as follows: "... by weights (---~F,,) . . . . "

SUBSTANTIATION: This change makes the text agree with the legend. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Commi t tee Action taken on C o m m e n t 1999-43 (Log #60).

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(Log #45) 199% 76 - (6-14.5.16): Reject SUBMITTER: Dan Gohlke, W.L. Gore & Assoc. COMMENT ON PROPOSAL NO: 199%7 RECOMMENDATION: Revise text as follows: "...calculated -oeI'or the material . . . . "

SUBSTANTIATION: Editorial correction. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Action taken on Comment 1999-43 (Log #60).

(Log #47) 1999- 82 - (6-18.2.1): Accept SUBM]TTER: Dan Gohlke, W.L. Gore & Assoc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

I Delete 6-18.2.1 and replace with the following: "6-18.2.1 A minimum of three specimens shall be tested. Specimens shall be complete face protection devices." SUBSTANTIATION: This change makes the standard more consistent with 6-17. COMMITTEE ACTION: Accept.

(Log #19) 199% 77- (6-15.4.2): Accept SUBMITTER: Catherine R. Dodgen, Inchcape Testing Services /ETL Testing Lab, Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

I Revise text as follows: "6-15.4.2 Test subjects shall be selected such that their hand dimensions are consistent with those specified in accordance with Table 4-2.5." SUBSTANTIATION: "As close as possible" in the existing wording is too vague and opens the test to large variability based on test subjects' hand sizes andavailability. COMMITTEE ACTION: Accept.

(Log #44) 1999- 78- (6-16.5.1): Accept SUBMITTER: Dan Gohlke, W.L. Gore & Assoc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

I Revise 6-16.5.1 as follows: "... shall be reported to the nearest 10 /agper gram." SUBSTANTIATION: Editorial correction. COMMITTEE ACTION: Accept.

(Log #10) 1999- 79- (6-17.1.1): Accept SUBMITTER: Bill Grilliot, Morning Pride Mfg Co. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

Revise 6-17.1.1 to change "This test method shall apply to those face ...." to: "This test method shall apply to that portion of the face..." SUBSTANTIATION: Visual acuity test is only appropriate for eye a r e a .

COMMITTEE ACTION: Accept.

(Log #26) 1999- 80- (6-17.3.2): Accept SUBMITTER: Dan Gohlke, W.L. Gore & Assoc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

Revise as follows: "6-17.3.2 Samples of sin~le- and multiple-use face protection devices shall be conditioned as specified in 6-1.2." SUBSTANTIATION: This brings the conditioning requirements of these to methods into conformity with 6-3.3.3. COMMITTEE ACTION: Accept.

(Log #46) 1999- 81 - (6-18.1.1): Accept SUBMITTER: Dan Gohlke, W.L. Gore & Assoc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

I Revise 6-18.1.1 as follows: "This test shall apply to a complete face protection device - in - i s emire~'." SUBSTANTIATION: This change makes the standard more consistent with 6-17. COMMITTEE ACTION: Accept.

(Log #48) 1999- 83- (6-18.3.1): Accept SUBMITTER: Dan Gohlke, W.L. Gore & Assoc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

Delete 6-18.3.1 and replace with the following: "6-18.3.1 Samples for conditioning shall be complete face protection devices." SUBSTANTIATION: This change makes the standard more consistent with 6-17. COMMITTEE ACTION: Accept.

(Log #86) 1999- 84 - (A-I-I.1): Accept in Principle SUBMITTERz Jeffrey o. Stull, Int'l Personnel Protection, Inc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Recommend the addition of the proposed text as follows: Addition to Paragraph A-I.I.1 The U.S. Department of Health and Human Services has issued,

Guidelines for Prevention of Transmission of Human Immunodeficiency Virus and Hepatitis B Virus to Health Care and Public Safety Workers [Center for Disease Control, MMWR 1989; 38 (no. S-6); pp. 1-37]. Two useful tables from this publication which describe the conditions under which emergency protective clothing are worn follow:.

Table Aol-l.l(a) Summary of task categorization and implications for personal protective equipmem

Joint advisory notice category*

Personal protective equipment should

be:

I

II

III

Nature of Available? Worn? task/activity

Direct contact with Yes Yes blood or other body fluids to which universal precautions apply Activity performed Yes No without blood exposure but exposure may occur in emergency Task/activity does No No not entail predictable or unpredictable exposure to blood

*U.S. Department of Labor, U.S. Department of Health and Human Services, Joint advisory notice: protection against occupational exposure to hepatitis B virus (HBV) and human immunodeficiency virus (HIV). Washington, DC: U.S. Department of Labor, U.S. Department of Health and Human Services, 1987.

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Table A-I-I.1 ('0) Examples o f r e c o m m e n d e d personal protective equipment for worker protect ion against HIV and H B V transmission" in prehospital ° settings

Disposable Protective Task or activity, igloves Gown Mask c e~'ewear

Bleeding control with Yes Yes Yes Yes spur t ing blood

Bleeding control with Yes No No No minimal b leed ing

Emergency childbirth Yes Yes Yes, if splashing is Yes, if splashing is likely likely

Blood drawing At certain t imes No No No

Starting an in t ravenous (IV) Yes No No No line

Endot rachae l in tubat ion, Yes No No, unless No, unless sp lash ing esophageal obtura tor use splashing is likely is likely

Ora l /na sa l suct ioning, Yes d No No, unless No, unless sp lash ing manual ly c leaning airway splashing is likely is likely

Handl ing and c leaning Yes No, unless No No ins t rmnen t s with microbial soiling is likely con tamina t ion

Measur ing blood pressure No No No No

Measur ing t empera tu re No No No No

Giving an injection No No No No

Tile examples provided in dais table are based on appl icat ion of Universal Precautions. Universal Precaut ions are i n t ended to s u p p l e m e n t ra ther t han replace r e c o m m e n d a t i o n s for rout ine infection control, such as h a n d washing and us ing gloves to p reven t gross microbial con tamina t ion of hands (e.g., contact with u r ine or feces).

b Defined as set t ing where delivery of emergency heal th care takes place away f rom a hospital or o ther hea l th care facility.

c Refers to protective masks to prevent exposure of mucous m e m b r a n e s to b lood or o ther potentially con tamina ted body fluids. Some resuscitative devices are referred to as "masks."

d While not clearly necessary to prevent HIV or HBV t ransmiss ion unless b lood is present , gloves are r e c o m m e n d e d to prevent t ransmiss ion of o the r agents (e.g., Herpes s implex) .

SUBSTANTIATION : Addit ional l anguage is necessary to clarify when the use of emergency medical protective clothing is warranted. COMMITTEE ACTION: Accept in Principle. Revise A-I-I.1 to read: "This d o c u m e n t only addresses emergency medical products and the design, per formance , testing, and certification of specific product . Use criteria for Emergency Medical protective c lothing is covered in NFPA 1500, S tandard on Fire D e p a r t m e n t Occupat ional Safety and Heal th Program, and NFPA 1581, S tandard on Fire D e p a r t m e n t Infect ion Control Program." COMMITTEE STATEMENT: T he Technica l Commi t tee has

rovided revised text for Add.m to assist in clarifying, these issues. is n o t within the scope of this d o c u m e n t to cover 'use" cn t ena .

(Log #17) 1999- 85 - (A-1-2.1 (New)): Accept in Principle SUBMITTER: Richard M. Duffy, Int'! Assn. of Fire Fighters COMMENT O N PROPOSAL NO: 1999-7 RECOMMENDATION: Add new append ix i tem as follows: A-1-2.1 Various condi t ions tha t exist at the scene of a fire service

emergency are uniquely different to those of a hospital based emergency. It is for these condit ions that the m i n i m u m requ i r emen t s of this s t andard are established. Such condi t ions are character ized by the uncont ro l led e n v i r o n m e n t of on scene response to fatal and nea r fatal vehicle crashes where the victim may be difficult to access a r o u n d twisted wreckage, b roken glass, a n d potential ly explosive a tmospheres ; violent weapon attacks against pe r sons in poor ly l ighted or awkward locadons; emergency chi ldbir th pr ior to hospital arrival; necessary use of sharps in field

envi ronments ; ex t ended t ime spen t in blood con tamina ted envi ronments ; a n d various o ther exposures to t r auma victims and

~ ersons in jured or ill with u n k n o w n i m m u n e status. U B S T A N T I A T I O N : The IAFF fully suppor t s the purpose of

NFPA 1999. As worker representat ives 225,000 professional fire f ighters and emergency medical responders , we are s t rong aavocates for appropriate , accessible a n d effective protective c lothing for emergency medical operat ions. The field work env i ronmen t of the fire service is no t the sterile env i ronmen t of the hospital with mos t patients p resen ted on a gurney. Unlike for mos t hea l th care providers, h a n d washing a n d shower ing facilities are no t immedia te ly accessible following exposures . The federal OSHA standard, 29 CFR 1910.1030 (c)(3)( i ) , only (and inadequately) def ines personal protective e q u i p m e n t as appropr ia te "only if it does no t permi t blood or o ther potent ial ly infectious materials to pass t h r o u g h or reach the employee 's work clothes, s treet clothes, unde rga rmen t s , skin, eyes, m o u th , or o ther m u c o u s m e m b r a n e s u n d e r no rma l condi t ions of use an d for the dura t ion o f t ime which the protec t ive e q u i p m e n t will be used." NFPA 1999 has establ ished the pe r fo rmance s tandard for

~phP ropriate c lothing for use du r ing emergency medical operations. e append ix h o t e l s necessary for those no t familiar with the

realities of the emergency scene. Those tha t have voiced objection to this s tandard have based their substant ia t ion on hospital-based or surgical a r ena in format ion or practices. It is clear f rom such comments , tha t none of the objectors ei ther have knowledge of or work in the field. COMMITTEE ACTION: Accept in Principle. Add new A-l-2.1 to read:

"The federal OSHA standard, 29 CFR 1910.1030 (c) (3) (i), only def ines personal protect ive e q u i p m e n t as appropr ia te "...only if it does no t permi t b lood or o ther potentially infectious materials to pass t h rough or reach the employee 's work clothes, s t reet clothes,

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undergarments, skin, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time which the protective equipment will be used." NFPA 1999 has established the minimum performance standard for personal protective equipment for use during emergency medical operations. The choice of which elements of personal protective clothin$ to

use will be based on an assessment of the risk of exposure at the emergency scene.

Various conditions that exist at the scene of an emergency are uniquely different to those of a hospital based practice.

Such conditions are characterized b~, the uncontrolled environment of an emergency scene. COMMITTEE STATEMENT: The Technical Committee revised text for specific issues.

(Log #49) 1999- 86 - (A-1-3 Single Use): Accept SUBMITTER: Dan Gohlke, W.L. Gore & Assoc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

Revise second and third sentences of A-l-3, Single Use as follows: "A single use could include unpackaging, o r o n e donning, o r o n e

wearing while respgnding. *r contact +~.-fi; 5cd 7 flu-;Sz . . . . any wearing of the element." SUBSTANTIATION" ff a single use is allowed to be defined as one contact, then this item could be used many times before contact occurs. The preconditioning for abrasion and flexing has been removed from single use items, which suggests many wearings before contact is not what the committee has in mind. COMMITTEE ACTION: Accept.

(Log #30) 1999- 87- (A-4-2.4): Reject SUBMrUI'ER; Dan Gohlke, W.L. Gore & Assoc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION: Delete A-4-2.4 and replace with the following: A-4-2.4 The requirement for FDA registration provides further

benefit to the emergency responder. The FDA currently does not req.uire that medical gloves used in emergency medical response be regastered as medical devices. Yet, these same gloves, when worn by emergency personnel inside hospitals and other health care Pdrovision organizations, must be registered as Class 1 medical

evices with the FDA. While FDA registration is not a certification of the product, it is a process by which the manufacturer must provide substantiation for any and all claims made regarding the performance of the product (e.g., its viral barrier performance, levels of quality assurance, and sterility) in either product packaging or maketing literature. The FDA either affirms or denies these claims. Therefore, this requirement helps to ensure that the fire service and emergency medical service personnel are provided with accurate information about the products they purchase. SUBSTANTIATION: This makes the rationale for this requirement in NFPA 1999 the same as in NFPA 1581. COM/~TTEE ACTION: Reject. COMMITTEE STATEMENT: The ROP text ofA-4-2.4 is more appropriate for this document.

(Log #87) 199% 88 - (A-5-1, A-5-2, and A-5-3): Accept SUBMITTER: Jeffrey O. Stull, Int'l Personnel Protection, Inc. COMMENT ON PROPOSAL NO: 199%7 RECOMMENDATION:

Revise sections consistent with final performance requirements of standard.

A-5-1 The performance requirements for emergency medical garments are explained in the following:

(a) Overall Liquid-tight Integrity (5-1.1). This performance requirement entails testing of the complete garment in a "shower- like" test that is designed to assess how well garment materials, seams, and closures and interfaces resist penetration from liquid splashes. The test does not simulate actual exposure from liquid splashes. Instead, the test demonstrates garment integrity by using an inner absorptive garment on a mannequin to show wetting which occurs as the result of liquid penetrating garment based on procedures found in ASTM F 1359, Determining the Liquid-Tight Integrity of Chemical Protective Suits or Ensembles Under Static Conditions. By blocking off the ends of clothing, partial body clothing such as smocks, aprons, and sleeve protectors can be evaluated using this method.

(b) Bacteriophage Penetration Resistance (5-1.2). This test is intended to determine how well garment materials prevent penetration of biological agents (liquid-borne pathogens). The resistance of protective clothing materials to penetration by blood- borne pathogens is determined using ASTM F 1670, Standard Test Method for Resistance of Protective Clothing Materials to Viral Penetration by Blood Borne Pathogens using Phi-X-174 Bacteriophage Penetration as a Test System. This test was chosen since it is the only known national consensus-based test method for measuring the viral penetration resistance of protective clothing materials. It also has been demonstrated to distinguish material performance consistent with. evaluations or actual viral penetration and human factors evaluations as shown by both Henry and Montefiori ("The Resistance of ClothingMaterials to Biological Liquid," Performance of Protective Clothing, Fourth Volume, ASTM STP 1133, ASTM, Philadelphia, 1992, pp. 58-64) and McCullough and Schoenberger, "Liquid Barrier Properties of Nine Surgical Gown Fabrics," (INDIA Journal of Nonwovens Research, Vol. 3, No. 3 Summer 1991). In this test, specimens of protective clothing materials or seams are challenged with a Phi-X-174 Bacteriophage suspension for 5 minutes at atmospheric pressure, 1 minute at 2.0 psi, and 54 minutes at atmospheric pressure. The test is terminated at the end of one hour or until observing liquid penetration. Then the reverse side of the test material is rinsed and essayed for the Phi-X-174. Phi-X-174 Bacteriophage best approximates Hepatitis C virus but also simulates Hepatitis B virus and Human Immunodeficiency Virus (HIV). It was chosen as the most appropriate blood-borne pathogen model because of its size, spherical morphology, environmental stability, non-human infectivity, high assay sensitivity, rapid growth, and high titer (available in large concentrations).

Testing prior to degradation by other physical, chemical, and thermal stress that could negatively impact the performance of the protective barrier could lead to a false sense of security. Other effects might, be shelf life, laundering,, and sterilization. Prewetting by such things as alcohol and contamination by such things as

[ perspiration can also affect barrier performance of the material. [The authority having jurisdiction should consider these effects ]when comparing materials. ] (c) Tensile Strength (5-1.3). This requirement was designed to ensure materials . . . . provide adequate strength when pulled or stretched. Testing is performed in accordance vath ASTM D 751,

]Standard Methods for Testing Coated Fabrics, which involves clamping a rectangular specimen in a tensile testing machine and pulling the specimen along its long axis until it breaks. The force recorded at breaking is reported as the tensile strength. High tensile strengths indicate stronger materials. The minimum requirement of 133.5 N (30 lbs) was based on a field study of disposable clothing in simulated working environment.

(d) Burst Strength (5-1.4). This requirement was designed to simulate material bursting from protruding objects within the emergency medical garment. Testing is performed in accordance with ASTM D 751, Standard Methods for Testing Coated Fabrics, which involves clamping a circular specimen in a Mullen Burst Tester. An oil-filled diaphragm is inflated by increasing pressure under the specimen until the specimen bursts. The force recording at the burst is reported as the burst strength. High burst strengths indicate stronger materials. The minimum requirement of 345 kPa (50 psi) was based on a field study of disposable clothing in simulated working environment.

(e) Puncture Progagation Tear Resistance (5-1.5). This requirement is designed to simulate material snagging and subsequent tearing from sharp objects, such as walking past a protruding rail. Testing isperformed in accordance with ASTM D 2582, Standard Test Methodfor Puncture Propagation Tear Resistance of Plastic Film and Thin Sheeting. In this test, a rectangular specimen is draped over holder. A puncture probe is then allowed to fall down a track, striking the specimen, puncturing it and causing a small straight tear. The length of the tear is then related to the force required to create the tear. High puncture propagation tear forces indicate materials more like to

!resist snagginl~ and tearinlt. The minimum requirement of 24.5 N i(5.5 lbs) was based on a ~eld study of disposafale clothing in simulated working environment.

(f) Tear Resistance (5-1.6). This requirement is designed to simulate how the material tears when pulled apart. Testing is performed in accordance with Section 6-7 which involves clamping a notch-cut, trapezoidal shaped specimen in a tensile testing machine and pulling the specimen at the notch cut until it tears apart. The forces recorded during the specimen tearing are averaged and reported as the tear force. High tear forces indicate materials which are more tear resistant. The minimum requirement of 133.5 N (30 lbs) was based on a field study of disposable clothing in simulated working environment.

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(g) Seam and Closure Strength (5-1.7, 5-1.8). These requirements are based on pulling and strength of garments seams or closures. Testing i s p e r f o r m e d i n accordance with ASTM D 751, Standard Methods for Testing Coated Fabrics, which involves clamping a rectangular seam or closure specimen in a tensile testing machine and pulling the specimen along its long axis until it breaks. The force recorded at the breaking of seam or closure is repor ted as the tensile strength. High tensile strengths indicate s tronger materials. The min imum requi rement of 66.7 N/50.8 mm (15 lbs/2 in.) was based on a field study of disposable clothing in simulated working environment. A-5-2 The per formance requirements for emergency medical

gloves are explained in the following: (a) Liquid-tight Integrity (5-2.1). This requi rement assesses the

overall integrity of the gloves in a procedure specified by the FDA and described in ASTM D 5151, Standard Test Method for Holes in Medical Gloves. In this test, a liter of water is poured into each glove and the glove is checked for leakage after 2 minutes.

(b) Bacteriophage Penetrat ion Resistance (5-2.2). This requi rement is analogous to the Bacteriophage Penetrat ion Resistance test described in A-5-1 (c). The test is conducted differently in that entire gloves are evaluated as opposed to material specimens. Gloves are placed in a flask containing the Phi-X-174 Bacteriophage. The inside surface of the glove is filled with sterile media which is assayed for Bacteriophage after 1 hour or glove/flash agitation. The analysis of the assay media is evaluated in the same manne r as done for garment material specimens.

(c) Ultimate Tensile Strength and 300 Percent Modulus (5-2.3). This requ i rement is designed to simulate the failure mode of gloves that occurs from pulling the glove onto the hand with its subsequent breaking and tearing. Testing is conducted using ASTM D 412, Standard Test Method for Rubber Properties in Tension wiaere dumbbell shaped specimens are pulled in a tensile testing machine. The force measured when the specimen is s t re tched to 3 times its length (300 percent modulus) and at breakage (ultimate tensile strength) are reported. Higher ultimate tensile s t rength indicate s t ronger gloves while lower 300 percent modulus indicate more break resistant gloves. Performance criteria were based on a comparison of labora tory data with field information about glove failures.

(d) Isopropanol Degradation and Heat Aging Resistance (5-2.4). In tiffs requirement , the degradation resistance of the glove is measured following a 2-hour immersion in isopropanol with measurement of glove elongation (by ASTM D 419, Standard Test Method for Rubber Properties in Tension). The inability of the glove to elongate 500 percent is cause for failure. Isopropanol is a common medical solvent that, when in contact with glove materials, may remove plasticizer or other additives necessary for adequate glove function.

In a similar manner , the heat aging degradation resistance is measured by subjecting sample gloves to an accelerated heat aging at 70°C (158°F) for 166 hours. This protocol was adopted from ASTM D 3577, Standard Specification for Rubber Surgical Gloves in tended to simulate the effects of long term storage of gloves at elevated temperature and subsequent glove degradation tbrough loss of plasticizers or other additives necessary for adequate glove function. Glove degradat ion resistance is measure using glove elongation. Performance criteria were based on a comparison of laboratory data with field information about glove failures.

(e) Puncture Resistance (5-2.5). This requi rement is designated to simulate the puncture of gloves by sharp (nail-like)objects. It is no t des igned to simulate needle-pricks or similar medical ins t rument punctures. Testing is conducted using ASTM F 1342, Standard Test Method for Resistance of Protective Clothing Materials to Puncture. The test measures the force required for a sharp probe to puncture through a clamped specimen. Higher specimen puncture forces indicate gloves with better puncture resistance. Performance criteria were based on a comparison of laboratory data with field information about glove failures.

(f) Dexterity (5-2.7). The overall glove performance is assessed through a s tandard glove dexterity test in which test subjects ability to manipulate fine objects is de termined. Test subject

per formance is compared with and without gloves using a procedure known as the Crawford Small Parts Dexterity test. The requi rement is based on the expectation that gloves have a min imum impact on wearer f ine h a n d manipulat ions when the correct size of glove is used.

(g) Protein Levels (5-2.8). Use current A-5-2.8

A-5-3 There are one design and three performance requirements for emergency medical face protect ion devices. The basis and rationale for each requ i rement are given below:

(a) Visual Acuity (5-3.1). This requ i rement ensures emergency medical devices provide clear and undistor ted visor th rough the vision or eye piece port ions of the device. Although similar, this requi rement is riot the same as that established in ANSI Z87.1 for protective visors. Instead it is based on an eye chart test involving human subjects wearing face protect ion devices.

(b) Liquid-tight Integrity (5-3.2). This requi rement is analogous to the t e s t p e r f o r m e d on emergency medical garments described in A-5-1 (b). A modification of the test procedure is used to accommodate face protect ion devices on a headform and different spray orientation.

(c) Bacteriophage Penetrat ion Resistance (5-3.3). This requi rement is analogous to the requi rement for medical emergency garments described in A-5-1 (c). It applies only to those portions of the face protection device in tended to provide

~ r o t e c t l o n to the face or head. UBSTANTIATION: The appendix sections explaining the basis

for the selected performance requirements should correspond to the new requirements. COMMITTEE ACTION: Accept.

(Log #50) 1999- 89 - (A-5-1(a)): Accept SUBMITTER: Dan Gohlke, W.L. Gore & Assoc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

I Revise A-5-1 (a) text as follows: "...using the procedure in Section 6-~2." SUBSTANTIATION: Wrong section referenced. COMMITTEE ACTION: Accept.

(Log #51) 1999- 90 - (A-5-1(e)): Accept SUBMI'ITER: Dan Gohlke, W.L. Gore & Assoc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

Revise A-5-1 (e) text as follows: "...past a protruding ~ SUBSTANTIATION: Spelling error. COMMITTEE ACTION: Accept.

(Log #52) 1999- 91 - (A-6-2.5.1): Accept SUBMITTER: Dan Gohlke, W.L. Gore & Assoc. COMMENT ON PROPOSAL NO: 1999-7 RECOMMENDATION:

I Revise text as follows: "A-6-2.5.1 (b~ Holdin~ the manneuuins feet down on a heavy, flat metal plate.i/; - " SUBSTANTIATION: This change provides a little more unders tanding of what is being r e c o m m e n d e d here. COMMITTEE ACTION: Accept.

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