Real Kings of Logistics

Real Kings of Logistics

Monday, February 20, 2012

Firefighter PPE: Understanding limitations of government regulations

December 28, 2011


From: http://www.ppe101.com/Columnists/Jeffrey-O-Stull/articles/1210329-Firefighter-PPE-Understanding-limitations-of-government-regulations/
PPE Update

with Jeffrey O. and Grace G. Stull

Sponsored by Globe


Firefighter PPE: Understanding limitations of government regulations

We are all affected by government regulations. The fire service is no exception. There are a number of regulations from both the federal government and state governments that affect firefighter personal protective equipment.

Included in these regulations are general requirements for fire departments (employers) to provide PPE for their firefighter employees. These requirements extend to not only providing the PPE but also caring and maintaining it, and providing training on the use and limitations of protective clothing and equipment.

These regulations are found in OSHA 29 CFR Part 1910.132. The regulations, sometimes also known as a "general duty clause" or Subpart I, further prescribe fire departments conduct hazard assessments and select the appropriate personal tech equipment based on the identification of hazards.

Well understood

For the most part, these regulations are well understood and, in fact, NFPA 1971 requires that manufacturers include a reference to these regulations in the user information provided for their clothing and equipment products that are certified to the standard.

There are also government regulations that pertain to minimum requirements for personal protective clothing and equipment. One example is OSHA 29 CFR Part 1910.156. These regulations are titled “fire brigades” and specify minimum requirements for personal protective clothing and equipment used by firefighters.

The regulations were first enacted in the early 1980s and unfortunately have not been updated in the past 30 years. Consequently, in specifying protective garment minimum requirements, the federal regulations indicate that garments should comply with the 1975 edition of NFPA 1971, even though there have been a total of six revisions that have followed, with increasing numbers of performance requirements for firefighter clothing.

The OSHA regulations allows the tear strength of outer shell materials to be lower than was required in the NFPA standard and exempts outer shell materials from having to resist charring when exposed to high heat if suitable flame resistance can be demonstrated.

These regulations become problematic because they are the law yet at the same time they do not come anywhere close to specifying the levels of performance that are found in the newer editions of NFPA 1971 since 1975.

When further examined, similar requirements for protective helmets, gloves, and footwear are equally out of date with modern criteria. Protective hoods are not even addressed.

Respective NFPA editions

No competent manufacturer still fabricates their clothing (garments) strictly to these older standards. Occasionally, one may find a reference to the OSHA regulations as part of the label or claims for a particular product, but this information is generally accompanied by the appropriate certification to the then respective edition of NFPA 1971.

Some jurisdictions may require the reference to the OSHA regulations because it is the law, but it should be understood that these federal regulations are woefully inadequate and provide an unsafe basis for specifying firefighter protective clothing performance on their own.

Nonetheless, there are some products where federal or state regulations are basis for the sole representation of firefighter personal protective equipment.

This is most commonly observed for protective gloves because some departments consider gloves to be a commodity given their lower price compared to other parts of the firefighter protective ensemble.

At the time they were prepared, the OSHA regulations did not have the benefit of an existing NFPA standard on firefighter gloves. The first NFPA standard on gloves (numbered 1973) did not become available until 1983.

Therefore, OSHA made reference to a study performed by Arthur D. Little, performed under contract to the National Institute for Occupational Safety and Health.

That study set out to develop specific criteria and test methods for demonstrating the protective qualities of firefighter gloves, which were to become the basis for future requirements for gloves in the NFPA 1973 standard.

Certain portions

For whatever reason, the government only chose to implement certain portions of the government study for gloves. In contrast, the NFPA 1973 standard on gloves accepted nearly all the requirements directly from the Arthur D. Little study.

According to the OSHA Act, the individual states are allowed to develop their own regulations for occupational safety and health as long as those regulations as a minimum meet the existing federal requirements.

In the state of California, for example, regulations have been promulgated for structural fire fighting protective clothing and equipment under Title 8 of the California code of regulations and are found in Article 10.1.

Specific requirements for hand and wrist protection are provided in Section 3407. These regulations specify a few tests for gloves that include conductive heat resistance, radiant heat resistance, flame resistance, dexterity, and grip.

These regulations contrast with the federal regulations in some respects; however, like 29 CFR 1910.156, they deviate substantially from the current requirements provided by NFPA 1971 as well as earlier embodiments of the glove performance standard since its initial release in 1983.

There are substantial differences in the performance requirements for firefighter gloves that exist in both the federal and California state regulations as compared to the NFPA standards.

These include a number of specific performance areas that are simply not addressed as part of the federal or state regulations. For example, there are no regulations for the gloves performance against wet heat transfer, or for that matter, any specific requirement for moisture barrier and the ensuing liquid protection provided by the moisture barrier.

Glove regs

The California state regulations do indicate that “protective gloves for firefighters shall be made of durable outer material designed to withstand the effects of flame, heat, vapor, liquids, sharp objects and other hazards that are encountered in firefighting.”

Yet, criteria are not provided in these regulations that address each performance area though it can be argued that gloves should demonstrate these specific qualities by some means.

In the current edition of NFPA 1971, there are several areas of performance which have been developed over the years to address firefighter concerns for protection of their hands.

It has long been recognized that the hands are very vulnerable to burn injury because of the relative large surface area to volume ratio of the hands as compared to other parts of the body.

Developments that are taking place in the creation of requirements for firefighter hand protection have attempted to address these concerns as well as take into consideration new material and design technologies available for gloves.

Neither the federal regulations, nor the California state regulations are able to keep pace with emerging glove technology or set requirements for the improvements of firefighter health and safety in response to fire service needs.

Cannot be responsive

The respective portions of the government simply cannot be responsive in a timely and periodic manner. For that matter, it is uncertain as to what resources the federal or state government can draw upon for setting requirements. The NFPA process uses balanced membership interests combined with several forums for public input.

The specific problems that ensue from relying only on the federal or California state regulations for firefighter conformity arise in many other forms.

Other than the fact that the regulations are clearly deficient in addressing all protection concerns for firefighters, there is also the absence of requirements for the certification of products, the provision of user information, and appropriate product labeling.

The NFPA standards are relatively robust in covering all parts of the manufacturing process to ensure that products meet the requirements in the standard.

These include that the manufacturer employs quality assurance procedures that ensure that all manufactured products meet the same level of performance as those products that are tested under the standard.

Self-certify

Government regulations do not address certification at all. Manufacturers can self-certify their product to the government regulations and not be subject to independent review, nor any of the other benefits that third party certification provides.

There are no requirements for quality assurance programs to be in place or for independent audits to ensure that quality practices are being followed. Manufacturers are further not required by the government regulations to provide any user information and can label their product however they choose.

These practices put the fire service in a dangerous position and compromise the safety of their members. Unfortunately, fire departments and individual firefighters may not realize how deficient these regulations are.

They assume that because there is some indication of meeting a regulation, the product is acceptable. After all, they cannot be experts in PPE — they are relying on the manufacturers to provide that expertise and any apparent endorsement gives rise to the legitimacy of the product.

It is our opinion that where accepted industry standards exist, products should at least comply with those standards. We do not believe that either the federal or state government regulations alone are a sufficient basis for qualifying the protective product as acceptable.

Sometimes, there may be exceptions but only if coupled to appropriate standards. In our state of Texas, there are state statutes that require career firefighters to wear structural firefighting protective clothing and equipment to meet the current edition of NFPA 1971.

Similar practices exist in some but not all states. Certainly, NFPA standards are voluntary, but they represent the base minimum for what the industry considers acceptable levels of protection and provide a rigorous basis for demonstrating compliance — the same cannot be said for many federal and state regulations that are not regularly updated and lack requirements for conformity assessment.

Sponsored by Globe

Jeffrey O. and Grace G. Stull are president and vice president respectively of International Personnel Protection, Inc., which provides expertise on the design, evaluation, selection and use of personnel protective clothing, equipment and related products to end users and manufacturers. They are considered amongst the leading experts in the field of personal protective equipment. Send questions or feedback to Jeff or Grace at Jeffrey.O.Stull@FireRescue1.com. The views of the author do not necessarily reflect those of the sponsor.

Tomorrow's PPE: Changes planned for SCBA, PASS devices and gear

February 08, 2012


From: http://www.ppe101.com/Columnists/Jeffrey-O-Stull/articles/1234489-Tomorrows-PPE-Changes-planned-for-SCBA-PASS-devices-and-gear/
PPE Update

with Jeffrey O. and Grace G. Stull

Sponsored by Globe

Tomorrow's PPE: Changes planned for SCBA, PASS devices and gear

In the first part of this article, we outlined how standards on personal protective equipment establish minimum levels of performance that are intended to reflect firefighter needs.

Over the next two months, there are several standards under development or revision; these include each of the standards listed below.

NFPA 1851 - Standard on Selection, Care, and Maintenance of Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting

Work is toward a third edition. The most significantly considered topics are the qualifications for service providers on cleaning and repair and how these organizations are qualified, difficulties in implementing the complete liner inspection and the rigor of the hydrostatic test applied to liners after three years, and the mandatory 10-year retirement requirement for all ensemble elements.

The industry is debating how manufacturers can specify companies to provide inspection, cleaning, and repair of their clothing versus the verification of independent service providers that can offer care for any type of clothing.

The adequacy of current procedures for qualifying organizations is being reviewed and being extended from simply addressing repair to cleaning and inspection processes. The committee is considering whether cleaning procedures need to be validated.

There are also concerns for high levels of liner failure during hydrostatic testing noted by some departments that occurs as part of complete liner inspections. Proposals for changing the frequency of this testing or how the testing is conducted are open for consideration.

Lastly, some departments are advocating exceptions to the rule that all clothing and equipment covered by NFPA 1971 be retired 10 years from its manufacturing date.


NFPA 1852 - Standard on Selection, Care, and Maintenance of Open-Circuit Self-Contained Breathing Apparatus (SCBA)

The standard is considered relatively mature and only a few changes have been proposed. These include events and procedures for reporting failures of SCBA, specifying the number of spare cylinders on hand for a given organization, and providing editorial changes to make some requirements more consistent with NIOSH regulations. (Note – Pat, does this line seem OK to you? I'm also checking with the Stulls - Jamie.)

NFPA 1855 - Standard on Selection, Care, and Maintenance of Protective Ensembles for Technical Rescue Incidents

This is a new standard that is intended to establish the companion selection, care, and maintenance requirements for products certified to NFPA 1951, Standard on Protective Ensembles for Technical Rescue Incidents.

The standard has a number of similarities to NFPA 1851, but has some adaptations to address specific issues related to two principle ensembles covered in the standard – utility technical rescue (without barrier) and rescue & recovery operations (with barrier). NFPA 1951 also addresses requirements for a CBRN ensemble.

As proposed, the standard provides detailed procedures for conducting a risk assessment to support the selection of the appropriate ensemble. It also establishes specific requirement for how ensemble elements (garments, helmets, gloves, and footwear) are inspected, cleaned, decontaminated, repaired, and stored as well as the responsibilities for ensemble care and maintenance for the department and individual responder.

NFPA 1975 – Standard on Work/Station Uniforms for the Emergency Services

The standard address clothing that is worn underneath protective clothing and includes an option for the clothing to be flame resistant. The committee is considering the scope of the standard to address some of items of clothing currently worn underneath protective clothing for moisture management and comfort purposes.

The committee is also examining the potential for including other performance properties in the evaluation of this clothing.

The public input period has passed, but any input for the revision of this standard can still be submitted for the committee's consideration. In addition, the same committee is working on a new contaminated water diving standard and a rope and harness selection, care, and maintenance standard.

NFPA 1981 - Standard on Open-Circuit, Self-Contained Breathing Apparatus (SCBA) for Emergency Services

The committee is addressing a number of changes for improving the performance of fire service SCBA. Among these are proposed tests for evaluating the integrity of the facepiece to high heat in response to some reported industry failures.

A new radiant heat resistance test has been put forward for consideration. The committee is also increasing the conditions of the high heat oven exposure prior to the fire exposure in the overall heat and flame test.

A number of other proposed changes have been considered that include new methodology for evaluating SCBA voice communications and changing the alarm level (amount of remaining air) for the end-of-service time indicator.

The standard is also being revised to provide for a range of certifications to address other applications, such as law enforcement, hazardous materials, and other non-fire fighting operations.

NFPA 1982 - Standard on Personal Alert Safety Systems (PASS)

Since its last overhaul in 2007 to address issues related to PASS problems in high heat and moisture conditions, the current revision is focusing on changes that encompass the performance of wireless or radio frequency PASS and their ability to communicate to base stations outside the operating location.

Consequently, a number of new design and performance criteria have been proposed to address various aspects of evolving electronics and their continued functionality for PASS devices. For example, wireless PASS devices are now evaluated for their ability to alarm at a distance that is considered out of range from the base station.

NFPA 1989 - Standard on Breathing Air Quality for Emergency Services Respiratory Protection

This standard covers the quality of breathing air for SCBA and how it is tested. The standard, which has been in existence for two prior editions, is undergoing only relatively minor changes for clarification of the existing procedures.

NFPA 1999 - Standard on Protective Clothing Emergency Medical Operations

The standard was significantly expanded in 2008 to include other categories of clothing and equipment. The majority of current revisions are aimed at improving current test methods or addressing the need for clarification for existing requirements.

A number of items covered by the standards are typically not certified by manufacturers, such as disposal garments, work gloves, and eye and face protection.



We would like to also point out that you can submit input on any standard at any time, whether in revision or not. The submission of specific suggestions or criticisms is always welcome and seen as a valuable part of providing feedback that enable enhancement of the current standards, which in turn help allow the development of better performing clothing and equipment.

We hope that if any of the standards are of interest to you that you take the time to communicate your concerns or needs to the respective committee. The NFPA process is only improved when the actual users of personal protective equipment provide their input.

Sponsored by Globe

Jeffrey O. and Grace G. Stull are president and vice president respectively of International Personnel Protection, Inc., which provides expertise on the design, evaluation, selection and use of personnel protective clothing, equipment and related products to end users and manufacturers. They are considered amongst the leading experts in the field of personal protective equipment. Send questions or feedback to Jeff or Grace at Jeffrey.O.Stull@FireRescue1.com. The views of the author do not necessarily reflect those of the sponsor.

What to wear under your turnouts

February 24, 2011


http://www.ppe101.com/Columnists/Jeffrey-O-Stull/articles/979087-What-to-wear-under-your-turnouts/

PPE Update

with Jeffrey O. and Grace G. Stull

Sponsored by Globe

What to wear under your turnouts

The protection offered by your turnout gear is predicated on the ensemble being worn by itself. NFPA 1971, the standard by which the minimum design and performance of the turnout clothing is established, does not account for what clothing or undergarments are worn in conjunction with your ensemble.

In fact, it assumes that you may be wearing nothing underneath your ensemble. This is a clear departure from the historical consideration of work uniforms and other clothing that was, at one time, included as part of the protective package.

Certainly before most fire departments adopted full bunker clothing in the late 1970s, firefighters relied on their uniform pants to complete part of the protective envelope in addition to long coats and hip boots.

There were even earlier versions of NFPA 1971 where the uniform pants could be considered part of the overall lower torso and leg protection for the purposes of meeting some requirements. However, even as the fire service protective clothing standards have evolved, it can and in some cases does matter what you wear under your turnout clothing.

So, if turnout clothing is designed and certified to protect firefighters by itself, then why does it matter what you wear underneath this clothing? After all, there are some parts of your body that will generally not be covered by anything else but your protective ensemble.

These areas include your arms if wearing a short sleeve shirt, your lower legs if wearing shorts, your neck depending on the style of shirt you are wearing, your face, head and your hands.

The protective ensemble elements that cover your body in these regions are the sole difference between your being protected or not. However there are those that raise the concern that what you do wear can be a problem, and it is possible and sometimes has happened that clothing items have contributed to injuries subtained by the firefighter.

This is why many believe that garments worn under your turnout clothing can create problems if not properly selected.

Debated issue

The question of what to wear beneath your turnout clothing has been a perennially debated issue in the fire service. When the NFPA 1975 standard on station/work uniforms first came out, it mandated the use of flame-resistant fabrics in the construction of uniforms.

Originally, while uniforms were not primary protective clothing, it was believed that in some circumstances firefighters could be exposed to flame and heat and should always be in some type of flame-resistant clothing.

However, back in 1999, NFPA 1975 was revised to permit either 100 percent cotton, 100 percent wool, or materials that were flame resistant as demonstrated by flame resistance testing.

The rationale provided for the change at the time was that the non-melting characteristics of fabrics were considered more important than overall flame resistance, but that interior clothing should not add potential danger in the event of an extreme thermal exposure.

Soon afterwards, the committee responsible for the 1975 standard found that it was more desirable to use an actual test that demonstrates safety from melting, rather than specifying cotton and wool, and eventually developed a thermal stability test that is now part of the standard.

In NFPA 1975, materials cannot melt, drip, or ignite when exposed to high heat. The new test evaluates if fabrics will stick to surfaces or potentially to skin. Flame-resistant garments remain an option, and are still specified by many departments that have determined that flame resistance is an important uniform attribute for their firefighters.

The basic sentiment is that firefighters should not wear any uniform clothing that contains thermoplastic materials such as polyester and nylon because these are capable of melting and contributing to burn injuries

It is argued that this should not matter, because if the temperature at the uniform level reaches the temperature needed to melt polyester or cotton (above 450 F), then the turnout clothing is severely compromised anyway.

While that may be true, we have noted in some post-incident clothing evaluations that polyester-based fabrics underneath turnout clothing does melt if it takes a large localized heat exposure. There are plenty of fabric alternatives which will not melt under these conditions.

Underwear considerations

The design requirements of NFPA 1975 specifically exclude its application to underwear. Nevertheless, some departments have instituted the same practices for using products that do not melt and are recommending that their members not wear nylon, polyester, or materials with high contents of thermoplastic materials.

Requiring members to wear 100 percent cotton gets around the issue of discerning the safety of blends and other materials. This would seem a reasonable approach but is very limiting, and it is expected that cotton this year will be ramping up in price to nearly 80 percent over its current cost.

When it comes to general clothing materials, some fire departments and individuals are intrigued by the new material technologies that promote good moisture management.

The thinking is that moisture under the garment in some circumstances can also contribute to burn injuries since wet gear can be more conductive than dry gear.

We have learned that the role of moisture in clothing is very, very complicated and there are no easy answers. When it comes to the role of moisture in clothing, its effect on protection depends heavily on the conditions of use, including the type of heat exposure, the length of the exposure and exactly where the water is located in the material system.

In some instances, water can provide a degree of cooling; however water can also act as a conductor and as a heat sink, so the level of heat transfer and its rate are critical in determining whether there will be adverse effects or not. Unfortunately, there are just no definitive answers to this issue.

We do believe that 100 percent polyester, nylon, and other fabrics with relatively high thermoplastic fibers should be avoided and should be part of standard operating procedures until additional information becomes available.

What we do not know is what percentage of these fibers constitutes a hazard, other than relying on the current NFPA 1975 test, which at this time only addresses uniforms.

Our hope is that future research will begin to shed light on these issues and help direct the fire service to better understanding of what should be worn with full confidence underneath your turnout clothing.

Sponsored by Globe

Jeffrey O. and Grace G. Stull are president and vice president respectively of International Personnel Protection, Inc., which provides expertise on the design, evaluation, selection and use of personnel protective clothing, equipment and related products to end users and manufacturers. They are considered amongst the leading experts in the field of personal protective equipment. Send questions or feedback to Jeff or Grace at Jeffrey.O.Stull@FireRescue1.com. The views of the author do not necessarily reflect those of the sponsor.

Globe G-Xtreme Video

Here is a link to a video about the model of Globe PPE that we use and are very happy with.

http://www.ppe101.com/articles/video/1007342-Globe-G-XTREME-Turnout-Gear/

Unlock a Car Door with a Shoe String

Information that may be handy some day.

http://lifehacker.com/5885429/unlock-your-car-from-the-outside-with-a-shoelace

Check Engine Light - Personal Vehicles

If your check engine light comes on in a fire department vehicle, please contact Ground Support (Maintenance). Here is some interesting information for your personal vehicles.

http://lifehacker.com/5878754/the-five-most-common-check-engine-problems-and-what-you-should-do-about-them

Twenty-five Documents You Need Before You Die

While not a fire service logistics items, it is important to be prepared in your personal life as well.

http://lifehacker.com/5883371/gather-these-twenty+five-documents-you-need-before-you-die

Friday, February 17, 2012

Mich. department testing 'quick-response' fire trucks amid budget cuts

Pickup trucks with extended cabs and boxes on back can be operated by only 2 firefighters to maintain service with fewer staff
By FireRescue1 Staff

GRAND RAPIDS, Mich. — Officials have approved a Mich. fire department's plan to test three quick-response units amid looming budget cuts.

The pickup trucks with extended cabs and boxes on the back can be operated by only two firefighters, and Fire Chief Laura Knapp of the Grand Rapids Fire Department hopes they will help generate $21 million in savings and maintain service in the event of staff reductions, according to the Grand Rapids Press.

The city wants the department to reduce fire spending by 10 percent in the next three years.

"We need to better align our resources with these single-unit calls to ensure our performance is maintained," Chief Knapp told the Grand Rapids Press. "Right now we don't have a lot of flexibility in our deployment. The [quick-response vehicle] is the answer for our current rigid operational system."

"These vehicles are more nimble," Third Ward Commissioner James B. White said. "They will handle all three kinds of calls" — fire response, medical assistance and vehicle-accident response.

"We have some inherent questions about the technology, but it's something that the chief would like to have for her transformation process," said William E. Smith, president of the firefighters' union.

http://www.firerescue1.com/apparatus/articles/1237052-Mich-department-testing-quick-response-fire-trucks-amid-budget-cuts/

Purchasing pumps: Single-stage or two-stage?

There are several questions you need to answer before making your selection
By FireRescue1 Staff

There has always been a big controversy about what type of pump to choose when you are writing specs for a new piece of apparatus.
If price is a concern when buying your new pumper, then the choice and size of the pump is another area you need to investigate. First of all, do you need a 200gpm single-stage or two-stage pump? Will a 1500 gpm or 1250 pump suffice?
The questions you need to ask yourself go on. What do you need to accomplish? Do you need to pump a lot of volume or pressure? Or, in the case of a two-stage pump, both? Deciding on what type of firefighting operation you normally encounter and if you also have other engines in your district that you use as strictly supply pumpers is another concern.
A single-stage pump has one dual suction impeller that takes water in both sides and provides water discharge to all discharge gates.

A two-stage pump has two impellers operating side by side, which gives, depending what part of the country you're from, the pump operator, MPO or engineer a choice by the use of a transfer valve.
This transfer valve has a volume or pressure position. Obviously a two stage pump can reach higher pressure than a single stage pump. This might be advantageous in operating at a high rise building or for extremely long stretches, for example.
The newer single stage pumps coupled with today's higher horsepower diesel engines are significantly more efficient and provide better performance than pumps from 20 to 30 years past.
Again it comes down to having the right tool for the right job. You and your apparatus committee ultimately have to decide what is the right choice for your department and the type of operation that you are trying to perform.
If you go on the websites of Hale, Waterous and Darley, you can get some useful info on the various types of pumps and their operation and efficiencies.
Another consideration when designing your new pumper is whether you are planning on installing a foam system based on Class A or B Foam, or a complete CAFS.
CAFS will add a considerable cost to the apparatus. If you are planning this option, make sure that your members understand everything about CAFS and how to use it at a fire scene or you might be wasting your time and money having a system installed if you don't plan on using the system on a fairly regular basis.
In any case, proper planning is the key to any apparatus purchase. Install what you feel your department really needs and investigate a great deal before you settle on your options.


http://www.firerescue1.com/fire-products/apparatus-accessories/firefighting-pumps/articles/1238718-Purchasing-pumps-Single-stage-or-two-stage/
About the author
The Apparatus Bay is a column section devoted to the fire truck industry, vehicle safety and the latest technology and vehicles. Articles are written by experts from across the industry. If there's a topic you'd like to see covered, or you are interested in writing for The Apparatus Bay, email editor@firerescue1.com.