How is the NFPA standard for firefighter gear developed and updated?
Like all NFPA standards, the standard for firefighter protective gear is developed by a volunteer technical committee, not NFPA. NFPA does not write or dictate the provisions of any standard.
Technical committees usually have about 30 members and are comprised entirely of expert volunteers. These dedicated individuals represent groups like users, consumers, government, industry, and labor, including many representatives from the fire-fighting community. To maintain balance, no single interest category can make up more than one-third of any technical committee.
As with all standards NFPA publishes, the open, transparent, consensus process is important to achieving the final language included in the standard. But it’s not always easy – there are, by definition, many considerations and viewpoints that go into developing the language and requirements of the standards.
The fire service has an important voice in identifying what firefighters need from their gear to help keep them safe given the conditions they are exposed to in the field and the fire-fighting tactics they deploy. Their gear is subject to a number of tests including heat strength, burst strength, seam breaking strength, and impact and puncture resistance, just to name a few. The protective gear is expected to perform in extraordinary and challenging ways given these activities and conditions.
The technical committee members take all this into consideration. They follow a rigorous process, and they must reach a consensus on any item in order for it to become part of an NFPA standard.
NFPA standards are regularly updated, and the balanced, transparent, open process for updating the firefighter protective gear standard is underway now. In fact, there have been several proposals to remove the UV light degradation test from the standard.
Does the NFPA standard require the use of PFAS in firefighter protective gear?
No. The NFPA protective gear standard does not specify or require the use of any particular materials, chemicals or treatments for that gear. It does currently require testing of the moisture barrier in order to ensure the gear will protect the wearer. In the process of developing the standard, direct input is received from firefighters on their activities and the conditions they face in the field. This experience informs the requirements and expectations they have for their protective gear. The members of the technical committee take this information and input from others and apply their experience and expertise to decide how the equipment should be tested to simulate what exposures the gear will face in the field over the course of its life in order to protect the wearer. The manufacturer then decides how to comply with that test.
Does NFPA require the use of its standards?
No, it does not. NFPA has no authority to require the use of its standards. Sometimes government agencies or authorities will require the use of an NFPA standard. Sometimes a private organization or a union like the IAFF itself will require the use of an NFPA standard.
Has IAFF proposed changes to the firefighter gear standard that would prohibit the use of PFAS?
No, IAFF has never proposed such a change. With the exception of NFPA employees, anyone in the world can propose changes to any standard, which the relevant technical committee must then review and respond to. At no point has IAFF, or anyone else for that matter, recommended language to the technical committee that would prohibit the use of PFAS in firefighter protective gear.
Why is there a UV light degradation test of the moisture barrier if it is not exposed to daylight?
The UV light degradation test for moisture barriers was included in the standard because in 1999, a manufacturer of material used as a moisture barrier in firefighter gear informed the fire service that their material was experiencing degradation in the field under certain conditions. An IAFF safety alert on the matter states, “The IAFF continues to believe that [the degradation of the moisture barrier] may pose a significant safety hazard to fire fighters. Not only does the moisture barrier provide primary protection from water, it provides primary protection from many common liquids. Those liquids include some common chemicals and bloodborne pathogens encountered during the normal performance of fire fighting duties. These duties include structural fire fighting operations, aircraft rescue and fire operations, extrication of victims from vehicles and other entrapment situations, provision of first responder or emergency medical care and other fire fighting and rescue situations.”
The inclusion of the UV light degradation test as a means to ensure the integrity of the moisture barrier was in direct response to this safety concern for tactical firefighting and emergency response. The UV light exposure became the way to test the overall performance of the moisture barrier.
What was the fire service’s role in the introduction of the UV light degradation test?
This firefighter gear standard is a good example of how members of an NFPA technical committee work together to reach consensus. An IAFF representative was chair of the technical committee when the moisture barrier test was adopted in 2004 and voted for its inclusion in the standard.
In 2021, when an amendment was submitted into the standards process that would remove the UV test from the protective gear standard, the proposal didn’t gain the support needed in the technical committee. In fact, the proposed amendment didn’t even receive a simple majority of the technical committee votes.
Critically, out of the approximately 12 technical committee members who represented the fire service, only two voted for the amendment that would remove the moisture barrier test. The balance of the committee members who represented the fire service either voted against removing the test, abstained, or did not return a vote. On the other hand, of the seven manufacturers on the committee who voted on the amendment, four voted to approve the amendment to remove the test.
Some Technical Committee members expressed initial concern in removing the UV light test without understanding how that might affect the moisture barrier’s performance (issues with the degradation of the moisture barrier being the reason the UV light test was included in the first place). Comments made through the standard development and revision process reflect both serious concern for cancer and the serious need for gear that protects firefighters from burns, scald injuries, chemicals, etc. In general, comments called for a better understanding of the implications before making a change to the standard.
What proposals have been made to change the standard in the current revision cycle?
As part of NFPA’s regular cycle of updating standards, in September 2022, the technical committee shared a first draft of an updated protective gear standard, which removes the UV light degradation test and replaces it with a multi-environmental conditioning procedure. Since then, there has been a public comment period on the draft, and the technical committee will now review those comments and post a second draft by October 4, 2023. This example shows exactly how the standards-development process allows for evolution and consensus building.
You can follow the standard through the revision process here.
Does NFPA have any type of agreement or special relationship with any gear manufacturer as suggested by the lawsuit?
No. NFPA does not have, nor have we ever had, any special agreements or relationships with any company or organization involved in our standards development process. Every aspect of that process is publicly available, including the names and affiliations of committee members, how they vote, and all actions taken. No more than one-third of any technical committee is represented by the same interest category. We are grateful to those who volunteer their time and expertise to our technical committees. The IAFF’s suggestion that any group exerts undue influence over NFPA’s process is false and defamatory.
How is NFPA addressing concerns around PFAS and firefighter health risks?
NFPA understands the complex health risks that come with firefighting, and we’re deeply sympathetic to the terrible toll that cancer takes on firefighters and their families. We’re proud of the role we’ve played in educating the fire service about firefighter cancer risks and supporting federal legislation to better understand the epidemiology around this important public health issue. We’ve also conducted research on various topics such as a fire service roadmap on firefighting foams and working with the Fire Fighter Cancer Cohort Study. For more than a century, we’ve worked hand-in-hand with the fire service on a shared mission to protect life and property in our communities, and that important work will continue.
At the same time, it’s important to remember that these are complex and evolving issues, and even within the fire service there isn’t total agreement about the best path forward. That’s why NFPA’s technical committee model works so well – it brings together people with different expertise and perspectives to reach a consensus. Additionally, NFPA is working hard to address the larger issue around the many chemical and biological hazards that fire responders are exposed to and has started a new standard project on Exposure and Contamination Control, which is scheduled for completion in late summer 2024.
Why is the IAFF suing NFPA?
While only IAFF can speak to its motivations, the facts make it clear that the suit is misguided and ill-informed, and IAFF’s public comments about it falsely portray NFPA, our standards development process, and the role the IAFF itself plays in that process. We won’t allow our organization, our people, or our valued volunteers to be disparaged or our long-standing process to be politicized by a meritless lawsuit.
The facts are:
- NFPA is a neutral facilitator. We don’t create or dictate the provisions of a standard. That’s the job of technical committees, which are comprised entirely of expert volunteers. These dedicated individuals represent groups like consumers, government, industry and labor, including many representatives from the fire-fighting community.
- NFPA technical committee members are well-respected experts who bring deep expertise to the standards development process. They work diligently to evaluate each and every recommendation submitted. The IAFF’s suggestion that these expert volunteers aren’t acting to make the best technical decisions based on the information presented to them devalues their inestimable contributions to the standards development process.
- NFPA does not have, nor have we ever had, any special agreements or relationships with any company or organization involved in our standards development process. Every aspect of that process is publicly available, including the names and affiliations of committee members, how they vote, and all actions taken. No more than one-third of any technical committee is represented by the same interest category. The IAFF’s suggestion that any group exerts undue influence over NFPA’s process is false and defamatory.
- With the exception of NFPA employees, anyone in the world can propose changes to any standard, which the relevant technical committee must then review. At no point has the IAFF, or anyone else for that matter, recommended language to the technical committee that would prohibit the use of PFAS in firefighter protective gear.
- The NFPA protective gear standard does not specify or require the use of any particular materials, chemicals or treatments for that gear. It does require a moisture barrier test to ensure the gear will protect the wearer. An IAFF representative was chair of the technical committee when the test was included in the standard for the first time in 2007. The manufacturer decides how to comply with that test.
- NFPA does not have the authority to require the use of its standards. Using them is entirely at the discretion of organizations and jurisdictions.
Who appoints technical committee members?
Appointment to a technical committee is based on the qualifications of the applicant, the ability to balance the interest categories on the committee, maintaining the committee at a manageable working size, and the applicant’s ability to attend and participate in committee meetings. Applicants don’t have to be NFPA members.
Why are manufacturers allowed to be members of the technical committee? Doesn’t this present a conflict of interest?
We believe the best standards are developed when there is a diverse set of voices around the table representing all of those who have a stake in the matter. We simply believe that no one voice, or point of view should count more than anyone else’s – whether that’s the fire service, consumers, government, labor, researchers, manufactures, etc.
To be clear, though, NFPA does not have, nor have we ever had, any special agreements or relationships with any company or organization involved in our standards development process. We work very hard to ensure that no single interest category has outsized control in the standards development process as we are bound to do. One important way we accomplish this is by ensuring balance on our committees. For example, no more than one-third of a technical committee can be from a single interest category, and it takes at least two-thirds of a technical committee to make a change. NFPA also provides full transparency into who the members of our committees are, how they vote, and all actions taken by those committee members.