Changes Challenging PPE Choices and Care

PPE SUPPLEMENT

THE NEW CONSOLIDATED National Fire Protection Association (NFPA) 1970, Standard on Protective Ensembles for Structural and Proximity Firefighting, Work Apparel, Open- Circuit Self-Contained Breathing Apparatus (SCBA) for Emergency Services, and Personal Alert Safety Systems (PASS), has arrived. It became effective near the end of September 2024. For turnout clothing and emergency services work apparel, any existing product must be certified to the new requirements one year later in September 2025 (SCBA and PASS devices must meet the new standard by March 2026).

The lead up to the new standard has not been without controversy. With a multitude of last-minute actions in the form of challenges to the standard at the annual NFPA meeting, concurrent amendments before publication, and final appeals and hearings, the ultimate content for the standard remained uncertain to the very end. Now, industry is literally gearing up to meet a new set of requirements, where some products will be affected more than others and some items may not be available.

• Optimizing Firefighter Glove Fit: AI-Driven Solutions for Enhanced Safety
• When Tragedy Strikes: Standards and Hazards Assessments—What Protects Us During High-Risk, High-Reward Operations?
• Frequently Asked Questions on Restricted Substances in Protective Clothing
• How Do I Comply with NFPA 1851? Five Options
• New Roles for Fire Department PPC Manager and Technicians
• Challenges Facing ISPs and the Turnout Gear Cleaning Industry

The upheaval of requirements for other personal protective equipment (PPE) products continues with changes affecting related gear as a second consolidated standard-NFPA 1950, Standard on Protective Clothing, Ensembles, and Equipment for Technical Rescue Incidents, Emergency Medical Operations, and Wildland Firefighting, and Urban Interface Firefighting-is now moving forward with planned publication in April 2025. It will combine NFPA 1951 (technical rescue), NFPA 1999 (emergency medical), and NFPA 1977 (wildland/ urban interface firefighting) standards into one. Interestingly, the positioning of three mission types in one standard now opens the opportunity to better address multifunctional gear, a type of product offering that will potentially make it easier for the fire service and manufacturers to collectively address “all-hazards” gear where structural gear is not warranted, too cumbersome, or simply not the right choice for some fire departments with increasing diverse response functions.

In the theme of continuing change, NFPA 1850, Standard on Protective Ensembles for Structural and Proximity Firefighting and Self-Contained Breathing Apparatus (SCBA), is on track to become a third consolidated PPE-related standard, which in this case combines requirements for selection, care, and maintenance of PPE found in NFPA 1851 (turnout gear) and NFPA 1852 (SCBA). That standard is slated for adoption in August 2025. Major changes are afoot as the responsible technical committees have focused considerable attention on cleaning and decontamination of clothing and equipment. The broadening of verification for attaining acceptable levels of contaminant removal will provide new information to the fire service for making more informed changes for how they clean PPE. It will also bring about some upticks in available technology with concurrent validation of claims.

As a backdrop of all the standards changes and their impact on the fire service, there is still the reality that many fire departments are still resource-challenged and while “newer” may be considered better, it is not always possible. Departments often have to weigh upgrades in clothing and equipment along with what it takes to keep capabilities viable and at a reasonable minimum level. Over the past several years, industry costs for new gear and the related care/maintenance have climbed much faster than inflation and there is some perception and evidence that gear longevity is declining. In the possible short-term horizon, there is also the prospect of dramatically updated regulations from the U.S. Occupational Safety and Health Administration (OSHA) that may impact many fire departments.

The new regulations would require that fire departments and other emergency response organizations comply with specific NFPA standards related to training, occupational safety and health, and PPE.

This 2025 PPE Supplement intends to do the following:

• Inform fire departments and firefighters as to what to expect with the new NFPA 1970 standard and how their choices of some protective clothing and equipment will change.
• Provide an overview of anticipated changes to technical rescue, wildland, and emergency medical protective clothing as well as describe a new category of multifunction protective clothing that offers a broad utility set of PPE serving some fire department needs.
• Cover upcoming modified requirements to be associated with how fire departments approach the selection, care, and maintenance of structural firefighting protective clothing and equipment, including the qualification of products and services for this aspect of PPE.
• Predict some of the ongoing trends for fire service PPE and offer some observations about how fire departments may have to adapt their approach for the selection, use, care, and maintenance of PPE in future years.

As with many prior supplements dating back to January 2018, this supplement is organized in a question- and-answer format. It contains supplemental information from a number of contributors, who have been asked to address related PPE topics and offer their perspectives on each of these subjects. Contributors include the following:

• Ben Mead of the U.S. offices of Hohenstein Institute (out of Germany) will answer questions about restricted substance lists (RSL) as they pertain to clothing products in general and now more pertinently to RSL limits in NFPA 1970, which is believed to be one of the more consequential new changes for 2025. The answers are intended to provide a better understanding of how the test requirements came about, why they are now becoming more commonplace in clothing, and how they are being implemented to limit hazardous substance use in clothing.
  
  
• In the 2024 PPE Supplement, Iowa State University researchers provided an overview of their work toward helping to better establish improved glove fit of firefighters using artificial intelligence (AI). That work has more recently advanced. A phone-based app has been developed for measuring the firefighter’s hand. The dimensions can then be matched to available manufacturer gloves that have been similarly scanned for interior dimensions. Dr. Mengying Zhang, Dr. Rui Li, and Dr. Guowen Song (ISU) and Dr. Linsey Griffin (University of Minnesota) provide an update on research for how an AI-based program can become a new basis to drive improved glove fit and function for a fire service that includes an increasingly diverse population.
  
  

• Researchers from the Textile Protection and Comfort Center (TPACC) of North Carolina State University provide an updated perspective on system levels PPE testing. TPACC has gained extensive knowledge of firefighter protective clothing through decades of research experience in a wide range of protective performance on the span of firefighter PPE. Their involvement in related human subject and manikin testing provides insights on how full ensembles can be evaluated and selected. Dr. Roger Barker and his research associates describe how this topic is now even more relevant since optional systems testing has been added to the new NFPA 1970 standard.
  
  

• In the area of selection, care, and maintenance, Robert Tutterow, president of the Fire Industry Education Resource Organization (F.I.E.R.O.), and Bruce Varner, chief (ret.), Santa Rosa (CA) Fire Department, discuss the new roles of the PPC manager and PPC technician. The near-final NFPA 1580 portion of the standard that applies to turnout gear created these roles within fire departments to aid in the competency and assignment of responsibilities related to PPE. The authors explain what these functions are and how they can be integrated into department organizations to provide a level of specialization needed to account for the increasing complexity of PPE in the fire service. F.I.E.R.O. has long been a strong advocate for improved health and safety for firefighter PPE selection, care, and maintenance.
  
  

  

  
  
• Tonya Herbert, owner and president of Florida PPE Services in Altamonte Springs, Florida, provides the options that fire departments have for setting up or arranging cleaning and repair services for gear, including in-house capabilities vs. outside independentservice providers and hybrid solutions. This guidance is in response to the increased fire department needs for keeping gear clean and serviceable.
  
  

• As a firefighter for the Addison (TX) Fire Department and the current chairman of the Technical Committee on Structural and Proximity Fire Fighting Protective Clothing and Equipment responsible for NFPA 1971 and 1851, Tim Tomlinson offers his views of the future challenges facing the selection, care, and maintenance of firefighter protective clothing. This information serves as a reminder of the need for ongoing evolution of standardization approaches supported by applied research.
  
  

  

  
  
• Neil McMillan, director of science & research for the International Association of Fire Fighters (IAFF), an Ottawa (Canada) firefighter, and a member of IAFF Local 162, provides the results of a detailed review of a specific situation affecting footwear in a large shipboard fire involving two line-of-duty deaths and offers his investigative findings and recommendations for addressing boot performance as a result of this incident. He has worked closely with the IAFF Heath, Safety, and Medicine Division over the past several years and is a new member of the NFPA technical committees.
  
  

  

  
  

As with prior supplements, this supplement provides the latest information on PPE technology with both insight for what is considered relevant and impactful as well as guidance on what the fire service should expect from the rapidly occurring changes in this industry.

The New NFPA 1970: Impactful Changes to Protective Clothing and Equipment (Formerly Under NFPA 1971)

(1) What is the origin of NFPA 1970 and how does it address PPE relative to older standards? A new standard was created over the past several years that consolidates four former individual standards:

• NFPA 1971 (2018), Standard on Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting.
• NFPA 1975 (2019), Standard on Emergency Services Work Apparel.
• NFPA 1981 (2019), Standard on Open-Circuit Self-Contained Breathing Apparatus (SCBA) for Emergency Services.
• NFPA 1982 (2018), Standard on Personal Alert Safety Systems (PASS).

This new standard is the result of a process by the NFPA to reduce the more than 130 original fire service standards into a smaller, more manageable number of standards that are easier to maintain into the future of its standards development process. Additional reasons provided for the consolidation have included the following:

• Allowing for related products and topics to benefit from “synergism” in terminology, general requirements, and criteria.
• Ensuring that related products remain aligned and benefit from concurrent advancements.
• Permitting future harmonization of requirements for consistency of protection, including the advancement of overall systems approaches.

Figure 1 courtesy of author.

In the consolidation and development of NFPA 1970, the individual committees responsible for the individual standards worked as they normally did through the NFPA process of soliciting public inputs, creating a first draft, following up with a solicitation of public comments, and then completing a second draft. However, putting all four standards into a single “book” required additional coordination and having one of the committees take responsibility for the common content.

The new standard is structured to help preserve the existing identity for being able to reference the older standards numbers (e.g., NFPA 1971):

• In the first consolidation, an overall introduction is a “roadmap” to the standard that is provided in the first chapter.
• Common chapters are provided for referenced documents, terminology, and general certification requirements (Chapters 2 through 4).
• The principal requirements in successive chapters group the original content of theexisting standards, collectively addressing scope/certification requirements, labeling and information requirements, design requirements, performance requirements, and test methods.
  • Chapters 5-9 apply to NFPA 1971.
  • Chapters 10-14 apply to NFPA 1975.
  • Chapters 15-19 apply to NFPA 1981.
  • Chapters 20-24 apply to NFPA 1982.
• Several nonmandatory annexes are provided for clarifying information and other specific purposes. Notably, Annex G provides a number of supplemental test methods primarily aimed at conducting full ensemble testing to evaluate different relevant, but not required, performance properties.

This development process was not without its difficulties. As explained above, the creation of the new NFPA 1970 standard included the normal opportunities for public participation and committee deliberation in considering new or modified content based on emerging product needs or clarifications of existing requirements. The numbers of inputs, comments, revisions, amending motions, and concurrent amendments on each part of the standard are shown in Figure 2. Because there were several areas of major changes being addressed particularly for turnout clothing, some supporting substantiation was hurried and other areas required refinement. There were also several contentious issues for some revisions that were difficult to resolve. As a result, there were some additional actions that played out to the very end of the NFPA 1970 development process where the largest consequence was that the fire service and the PPE industry remained uncertain about what would be in or out of the standard until it was finally issued in late September 2024 (see “The NFPA 1970 Roller Coaster”).

Key: TIAs = Tentative Interim Amendments; number represents specific numbers of actions for respective standard in each column. (Figure 2 courtesy of author.)

 

(2) What is the schedule for the Implementation of NFPA 1970 and how is the fire service impacted by this schedule? The new standard was issued with an effective date of September 29, 2024. As of that date, NFPA 1970 replaces the existing individual four standards that were consolidated. Consequences include the following:

• No new products can be certified to the older editions of the standards that are part of the consolidated standard. New products will have to be certified to the new NFPA 1970.
• Manufacturers are permitted to maintain the certifications of existing products to the older standards for a period of up to 12 months following the effective date of the standard for products formerly meeting NFPA 1971-2018 for turnout clothing and NFPA 1975-2019 for work apparel.
• For SCBA and PASS, a longer grace period is afforded for up to 18 months. This was partly undertaken because SCBA certification is affected by government approval and testing, which is not always as responsive as the commercial sector.
• These grace periods effectively permit manufacturers to get products ready for the new standard by going through their certification laboratory to demonstrate that they can meet the new criteria. This applies to all products, even if the product has not changed to meet the new standard.
• Typically, manufacturers take some time to have their products certified to a new edition of a standard because of a backlog of testing that rapidly develops at the certification organizations once the new standard issues. While manufacturers can try to undertake some preliminary testing ahead of the issue date, certification to a new edition cannot occur until the new edition becomes effective.
• Manufacturers of some products, particularly turnout clothing and station uniforms, are often dependent on separate suppliers having their respective materials and components “recognized” to the applicable requirements of the standard to be able to complete their certifications. This process of “component recognition” helps keep testing costs lower since many of the same materials and components are shared by several end-product manufacturers.
• Products certified to the new NFPA 1970 are not likely to show up until several months into 2025. The ramp up efforts for getting products ready, getting samples submitted, and addressing new requirements are expected to take some time. In many cases, manufacturers like to try to introduce upgraded products at the Fire Department Instructors Conference, but this year, some product introductions may be delayed.

It is understood that this period of transition can affect many fire departments’ PPE purchasing decisions, particularly when products may be needed in the short term for reoccurring demand and for the fact that once newly certified products become available, the lead times can become longer. You should speak directly with your manufacturer representative to find out what you can expect in terms of product availability and check back on a frequent basis, as delays are inevitable.

You can view and obtain the new NFPA 1970 standard in the following ways, each through the NFPA Web site:

• You can view the standard through free access. This version has limited features.
• A paid subscription service called “Link” is available to view the standard. It allows search capabilities and other options to make it easier to navigate through the standard.
• You can order a 400-plus-page hard copy. PDF versions of NFPA standards are no longer available due to copyright restrictions.

Unfortunately, because the entire NFPA 1970 standard is new, indications of changed areas that were notated in prior editions of the standard no longer appear. This means that the differences between new and old requirements are not evident. Consequently, gaining an understanding of the changes is helpful to departments considering products meeting the new standard. For this supplement, the majority of emphasis is on turnout clothing, where most changes were made. Work uniforms, SCBA, and PASS are covered less extensively in the next major section of this supplement.

(3) What are the key significant changes affecting turnout gear clothing choices? Multiple areas of the standard were changed through public input and comments, coupled with work by a balanced Technical Committee. The main objectives of these changes were to do the following:

• Address emerging protection needs or fire service concerns.
• Account for new technology in products and testing.
• Update criteria and methods.
• Fix errors or clarify existing requirements.
• Address consolidation.

While there are a multitude of changes in NFPA 1970 regarding turnout clothing, the most important of these include the following.

• Key Change #1: Mandating all structural protective hoods to have particulate-blocking capabilities.
• Key Change #2: Providing a basis for manufacturers to make PFAS-free claims and address restricted substances in clothing.
• Key Change #3: Establishing new criteria to ensure that turnout gear maintains performance properties over its expected service life.
• Key Change #4: Lessening of some moisture barrier requirements to open up options for non-PFAS products.
• Key Change #5: Adding a new test method and requirement for clothing breathability.
• Key Change #6: Attempting to address glove sizing through an alternative scheme and overall quality of product labeling.
• Key Change #7: Examining the ability to effectively clean clothing materials to remove fireground contaminants.
• Key Change #8: Creating a new set of optional criteria to address “systems” performance of complete firefighter protective ensembles.

These changes are further described in answers for the questions below.

(4) What are the new hood requirements and how will these criteria affect available hoods? In NFPA 1970, new structural firefighting hoods can only be certified if they meet the particulate-blocking capabilities. Proximity firefighting hoods are exempted but can become particulate blocking if the optional additional particulate-blocking requirements are applied. The reason that proximity hoods are not required to be particulate blocking is because the U.S. Navy petitioned NFPA against this mandatory change and it is one of the largest groups of firefighters using hoods. They argued that the aluminized shrouds used with the helmet made the use of a particulate-blocking hood unnecessary. They were also concerned about the additional heat stress associated with these hoods and the cost of outfitting the entire naval firefighting force to remain compliant with the new standard.

In addition to becoming mandatory for structural firefighting, the requirements for particulate-blocking hoods were modified to include the following:

• The particulate-blocking layer must now cover the entire the hood, with the exception of a small portion around the hood opening and hems of the hood bib.
• Particulate-blocking test requirements are also being applied to hood seams, not just the material. In the past, some current particulate-blocking hoods did not meet the criteria for seams, though the material still blocked 90% of the particulates.
• While a more rigorous preconditioning of materials and seams prior to particle penetration resistance testing had beenproposed to better simulate the expected use and exposure of hoods, it was not found to show any difference in performance. Hoods are now subjected to a combination of 10 washings and one 10-minute heat exposure at 285ºF before being tested.
• Hood and hood seams involving the particulate-blocking layer that are not air-permeable can skip the particulate-blocking test if the material shows no air permeable using a conventional test. This exemption is made because a hood material that does not pass air will also not allow particles to pass through.
• A minimum number of sizes must be provided to ensure sizing of the majority of firefighter population since most particulate-blocking hood materials do not stretch like their knit-only counterparts permitted by earlier versions of NFPA 1971.
• Hoods will now be tested for stored heat energy transfer, but no criteria were established since the committee was unsure what limits to set. Instead, manufacturers will be required to report and explain performance values.
• The decontamination effectiveness of hood materials must also be reported in terms of a percent removal of organic and heavy metal contaminants based on standardized testing and washer/ extractor-based cleaning.

A particulate-blocking hood (right), while looking the same as a standard knit hood (left), is expected to have some different attributes that may or may not be noticed by firefighters. (Figure 3 courtesy of Majestic Apparel.)

There are multiple implications for these approved changes. Particulate-blocking hoods require some type of barrier layer that imparts different characteristics to the hood, potentially affecting both insulation and comfort. Some prior work undertaken by North Carolina State University showed that it will be difficult for many three-layer hoods to comply with the new requirements since total heat loss (THL), the same property measured for protective garments, remains at a level of 325 W/m². Many of the thicker hoods cannot meet this requirement and will no longer be offered. Hoods that are designed to emulate turnout clothing with similar shell materials also will be affected and will have to be fully redesigned to comply with the new requirements. The combination of THL and a thermal protective performance (TPP) criterion at 20 cal/cm² creates a balance where only certain types of material combinations will work, including the type of particulate-blocking layer that is used.

Other ramifications of having only particulate-blocking hoods may be related to some of the attributes that have already been noted with existing products in the marketplace. Some hoods are noisy based on the nature of the particulate-blocking layer. Some firefighters have complained that their hoods inhibit their ability to hear. The lack of elasticity has also meant that new doffing techniques must be applied for these hoods, which is likely beneficial, because recommended procedures for pulling off the hood with the SCBA limits the amount of contamination transfer to the firefighter’s neck.

Figure 4 courtesy of Illinois Fire Service Institute and North Carolina State University.

In addition, hoods will most likely need to be available in more than one size. The Technical Committee struggled with putting together sizing requirements. Instead of designating specific sizes, NFPA 1970 dictates that manufacturers must demonstrate that their hoods can accommodate a range of head sizes (5th to 95th percentile) based on three head measurements where the measurements of male and female firefighter head dimensions were collected in a large government anthropometric study database.

As with other products, protective hoods will be subject to the optional PFAS claims and limitations on restricted substances (see next section). Overall, hoods will no longer be a commodity. In general, new NFPA 1970 hoods are expected to be at least twice and more often three times more expensive than their earlier nonparticulate-blocking hood counterparts.

(5) How does NFPA 1970 address PFAS and other restricted substances in turnout clothing? Perhaps the most controversial changes going into NFPA 1970 revolve around PFAS and restricted substances. The activity to progress this topic began in 2018 right after the approval of the 2018 edition of NFPA 1971. At that time, PFAS in turnout clothing was an emerging issue as individual states were ramping up legislation for at least the disclosure of PFAS in PPE (Washington State was the first with regulations, which became effective in July 2018). Moreover, substances other than PFAS have come under scrutiny for their use in protective clothing over the years including heavy metals like antimony, various brominated and chlorinated fire retardants, plasticizers such as phthalates, and other chemicals that are considered to represent human health and environmental concerns when used in excess or added irresponsibly to materials and components. The ensuing positions taken by state governments, some fire departments, trade organizations, and individual firefighters warranted that this topic should be addressed in standards, though some pundits had indicated that the topic was best left to industry to handle and police.

PFAS

For PFAS, NFPA 1970 handles the topic in two ways:

• An optional labeling requirement permits manufacturers of turnout clothing products to make a claim about limited PFAS in their product. This claim is based on specific independent testing of key materials used in the construction of the item.
• Separate requirements are in place that mandate that manufacturer suppliers have their materials and components independently tested for certain PFAS chemicals. The respective materials and components can only be used in the manufacturer of the clothing item when the respective materials and components are shown to be absent or at very low levels of PFAS.

The optional labeling requirement appears in the following form: “THIS [type of protective element] UPON CERTIFICATION HAS A PFAS (TOTAL FLUORINE) CONCENTRATION OF NO MORE THAN 100 PPM.”

Of note is the fact that the statement does not say “PFAS-Free” or “No intentional PFAS added to the product.” These omissions were intentional for several reasons:

• There is no current standardized methodology by which all 10,000-plus PFAS chemicals can be analyzed and quantified. This is because there is such a range of PFAS chemicals that no one analytical technique can measure them. There are only approximately 100 standards for specific quantification of PFAS using appropriate measurement approaches. Some types of PFAS, in polymers such as the parts of moisture barrier films that have historically included PFAS, cannot be directly measured. Instead, the total amount of PFAS in a material or component is based on the proxy measurement of total fluorine.
• To date, the only commonly available means of representing total PFAS in a solid sample has been the use of equipment called combustion iron chromatography, where the sample is fully burned and decomposed into its various atoms, allowing the determination of how many of those atoms are fluorine. If the assumption is made that any fluorine atoms are associated with PFAS chemicals, then an overall value can be assigned to that material or component. The shortcoming of this analytical technique is that some fluorine may not be associated with PFAS chemicals and instead includes other types of fluorine such as fluoride, a common component found in toothpaste and drinking water. Thus, the total fluorine number may overreport the actual level of PFAS in the product.
• Claiming a product is “PFAS-Free” is also a misnomer because PFAS contamination has become so ubiquitous that very small levels can be found in many products even when not intentionally added. The sources of these residual PFAS levels are many where certain raw materials can be contaminated with PFAS that was not added, some processes for textiles use water that can contain PFAS, and machinery that has PFAS can contaminate products during the fabrication process.

The 100-ppm limitation is based on what is currently considered the most restrictive constraint for PFAS in a range of textile products including apparel from the State of California, which, beginning this year (2025), limits total organic fluorine to a level of 100 ppm. According to the same state regulations, that limit will be reduced to 50 ppm in early 2028. Even when a manufacturer cannot or chooses not to report a PFAS-related claim under NFPA 1970, the manufacturer material/component supplier is still obliged to report the total fluorine level.

PFAS has been historically used in two ways for turnout clothing:

• As a durable water repellent (DWR) on outer shells, some moisture barriers, and some other material components. It has also had limited use in very few thermal barriers and other textile components.
• It has been the backbone functional polymer barrier film in the form of expanded polytetrafluoroethylene (ePTFE) for garment moisture barriers and barriers in many gloves and footwear products.

Its use as a DWR on outer shells and thermal barriers has been pretty much phased out over the past few years by current material suppliers and garment manufacturers. This transition is also occurring in moisture barrier technology with the introduction of a few moisture barriers during 2024 that no longer rely on ePTFE. With the new requirements in NFPA 1970 along with other changes indicated in the answers to some questions below, it is expected that a larger range of materials will become available.

It is important to understand that only key materials are evaluated from respective products and some materials have been excluded altogether. The following table shows the materials for which PFAS and other restricted substance limitation criteria are applied. Right now, NFPA 1970 focuses mainly on textile-based materials found in each of the five elements of the ensemble—garments, helmets, gloves, footwear, and hoods. Certain materials such as leather and plastics are excluded. This is mainly because effective methods for their characterization for PFAS levels have not yet occurred.

An important takeaway from the PFAS restrictions in NFPA 1970 is that manufacturers will still be able to sell PFAS containing products, though some of the substances will be restricted to very low levels and manufacturers can make a non-PFAS product claim only when demonstrated. The most important advancement in this approach for standardizing the topic is that manufacturers and material/component suppliers are now being held accountable with required independent verification in conjunction with the certification process.

Other Restricted Substances

PFAS represents only one category of restricted substances being addressed in NFPA 1970. To be more proactive in the safety of gear to the wearer, the new standard also provides for the application of limitations for hundreds of other chemicals used in textile-based products for apparel. This application is nothing new in the textile industry. In fact, some companies have voluntarily complied for years with requirements set by specific restricted substance list. These lists arise from a variety of sources globally on the health and safety of products, which consider the entire service life of materials, not only in their use but also in their origin and ultimate recycling or disposal. Table 2 provides the major categories of restricted substances. There are hundreds of chemicals that comprise these categories that warrant this level of scrutiny with the realization that turnout clothing, unlike much of the consumer apparel, is subject to many rigors of environmental exposure including repeatedly high heat, UV light, liquid exposure, wear and tear, and laundering.

The application of other restricted substance requirements works similarly as it does for PFAS chemicals using the following approach:

• Specific categories and individual chemicals are identified as part of an overall RSL.
• Material and component suppliers submit their materials to an independent testing laboratory that evaluates supplier products for levels of restricted substances against the limitation requirements in NFPA 1970 using specific or equivalent test methods.
• The independent testing laboratory (what NFPA 1970 refers to as an attestation organization) reports the test results for the relevant restricted substances and provides a certificate that attests that the restricted substance limitations established in NFPA 1970 have been met.
• For the material and components that are subject to this requirement, end-product manufacturers can only use materials and components that have attestation certificates.
• If a supplier does not choose to comply with these requirements, the end-product manufacturer can undertake the testing through the attestation organization on its own to permit use of the material.

 

RSL requirements are complicated because they comprise a variety of chemical oversight practices established by various groups including regulatory authorities in North America, Europe, and globally. Fortunately, these requirements have been made easier with the creation of standard RSLs by a couple of organizations. One of those organizations is the Hohenstein Institute that sets its own RSL standards under the brand name OEKO-TEX®. This includes two specific standards-OEKO-TEX® Standard 100 and OEKO-TEX® PPE Supplement. The NFPA task group that put together the RSL requirements pertaining to turnout clothing relied on the 2024 edition of this standard along with information from a separate RSL known as AFFIRM that is very similar, but not identical, from the American Apparel and Footwear Association. Both organizations are active in keeping their RSLs up to date.

Naturally, given the newness of these requirements, a lot of questions have arisen about restricted substances, particularly how they are identified, how limits are set, and how testing is carried out to ascertain compliance with RSLs. Ben Mead from the Hohenstein Institute answers these questions in “Frequently Asked Questions for Restricted Substances.” The Hohenstein Institute is one of the attestation organizations that two principal turnout clothing certification organizations (Safety Equipment Institute and UL Solutions) are accepting material or component attestation certificates from for NFPA 1970 RSLs.

(6) What is NFPA 1970 doing to address gear outer shell long-term performance and durability?

There have been numerous investigations conducted over the past couple of decades to examine how turnout clothing continues to provide performance consistent with the requirements of NFPA 1971. These studies have shown that some properties are expected to degrade over time, some are less affected, and some improve. While this information has been of interest, and sometimes used to explain how gear reacts to a given set of circumstances in the field, no definitive trends in gear durability have been established. Instead, feedback from the fire service has mainly informed what expectations exist for the durability of firefighter protective clothing and the materials used in its construction.

Outer Shell Strength/Durability

More recently, there have been findings, some anecdotal in nature with others much more documented, to indicate that over the past few years, protective garments are simply wearing out quicker than in previous decades. Most of these observations are attributed to outer shells. In some cases, observations by ISPs indicated that some fabrics became so weak that they could be torn by hand easily, with this degradation taking place much earlier in their service life than expected. The potential reasons for the shorter lifespan can include several factors:

• Newer fabrics tend to be lighter weight and are of a more flexible construction. They are less rugged than their predecessors. These fabrics are generally weaker and without reinforcing fibers found in some shell fabrics that consequently may break down more quickly from ordinary wear and tear.
• Garments are now being subjected to advanced cleaning (i.e., machine washing) more frequently. It is well-established that increasing the number of cleanings shortens the lifespan of clothing using conventional wet laundering in washer/extractors. This is generally true for all types of textile-based apparel.
• Changes in finish technology may be contributing to lower durability, particularly if the finishes wear off over time, which they do. For this factor, there is a theory that durable water-repellent coatings on individual fibers provides some lubricity that lessens abrasion of those fibers when they rub together during movement of the fabric. If the finishes are gradually removed during washing, then the fibers may break down at a faster rate.

Despite understanding some of these possible reasons for diminished gear service life, no laboratory testing to date has been able to replicate the conditions that unambiguously show premature wear of clothing materials. The NFPA Technical Committee has attempted to address these issues by applying a rather extensive set of preconditions to outer shell fabrics before being subjected to tear resistance testing, involving the application of the following:

 

• 20 laundering cycles.
• Exposure to high heat—285°F for 10 minutes.
• Repeated rigorous flexing of the material for 3,000 cycles.

Figure 5 courtesy of Web Marshall, Command and Control, LLC.

While these conditions have not replicated field observations, they are believed to help demonstrate improved durability of fabrics in general. Abrasion believed to be a factor in the testing simply was not practical to apply given the type of available test approaches. The committee was also unsure about where to set criteria for a post UV light exposure of the outer shell material. While UV light exposure is a well demonstrated factor for early degradation of certain fibers commonly used in turnout gear fabrics, outer shell strength following UV light exposure will only be reported without any specific acceptance criteria. The thinking was that the accumulation of these data over time would permit the committee to set a minimum strength in the future.

Outer Shell Oil-Based Resistance

Another test was added for reporting results only for outer shell resistance to exposure to diesel fuel. In this test, a small amount of diesel fuel is poured down on top of the material, which rests in a curved, inclined trough. The test determines how much diesel fuel is repelled (indicated by the amount that reaches a beaker at the end of the trough), how much penetrates the shell onto an underlying blotter, and how much is absorbed into the outer shell. Outer shells exposed in this manner are tested both new and after 10 cycles of laundering. Manufacturers are required to report indices of repellency, penetration, and absorption. No acceptance criteria are established in this test.

As an adjunct to this test, samples that have been subjected to the diesel fuel exposure are further evaluated for flame resistance both following the liquid exposure and after one cycle of laundering. This testing is intended to show whether outer shell fabrics retain diesel fuel and if laundering removes a sufficient amount of fuel to prevent exacerbated burning. The majority of tests conducted in this fashion indicate that representative outer shell materials show no enhanced burning following cleaning when exposed to a small amount of diesel fuel. Some sample results are shown in Figure 4.

(7) What changes were made to the requirements for moisture barriers relative to allowing new barrier technology? With concerns arising about the use of PFAS in several protective garment materials, there is an overriding belief that some of the criteria had been put in place for moisture barriers beginning in the early 1980s that preferentially favors products based on ePTFE (a PFAS polymer). To permit different types of film layers used in moisture barriers, a number of changes were considered and enacted as part of the new NFPA 1970 standard:

 

• Instead of being evaluated as a single layer, moisture barriers are now tested as a sandwich between the thermal barrier and outer shell (the “overall” composite) when exposed to high heat in the oven heat and thermal resistance test. This change was made to better emulate the way that this portion of the turnout clothing is actually exposed on the fireground.
• The viral penetration resistance test that rigorously evaluates the ability of the moisture barrier to prevent the penetration of bloodborne pathogens was replaced by a hydrostatic test that is used in the medical industry for Level 3 surgical and isolation gowns. Level 3 is the second highest barrier classification of these products for moderate exposures of healthcare providers. In contrast, the viral penetration resistance test is classified as Level 4 barrier protection for healthcare providers for extreme exposure conditions such as orthopedic surgery or childbirth. The rationale for this change was that the viral penetration test was simply too harsh and not considered realistic for firefighter expected exposures to blood and body fluids. It was further noted that medical apparel often consists of a very thin single barrier layer in contrast to the multilayered, much thicker composites used in firefighter turnout clothing. Thus, the Level 3 barrier performance was judged as adequate. Regardless, moisture barrier suppliers still have the option of applying the more rigorous viral penetration test, but the minimum requirement was reduced to the more commensurate Level 3 performance. That option was added in a late amendment to the standard.
  
  

  

  
  
  

  
  

  Most differences between materials lessen when laundered. (Figure 6 courtesy of author.)

  
  
• The phosphate ester base hydraulic fluid used in liquid penetration testing for demonstrating moisture barrier performance of common fireground liquids was replaced by a more innocuous mineral oil-based hydraulic fluid that is more common in firefighting for the use of hydraulic tool. The phosphate ester base hydraulic fluid was considered to be a relatively aggressive liquid that causes deterioration of some non-ePTFE materials. Furthermore, the moisture barrier penetration resistance test is performed directly against the moisture barrier without the benefit of the outer shell that attenuates some of the liquid exposure. The other liquid chemicals used for evaluating the barrier effectiveness of moisture barriers such as AFFF, antifreeze liquid, battery acid, gasoline, and swimming pool chlorine additive were retained.
• The UV light degradation test that has been the subject of an earlier attempted amendment for its removal back in 2021 was in fact removed from the NFPA requirements in its current form. The committee later voted through a late amendment to put in a milder form of the UV light degradation test. This new evaluation approach was considered to be more representative of field exposure. In the prior UV light degradation test, moisture barrier films were directly exposed to the UV light despite the fact that the film layers are protected by both the outer shell and a textile layer on top of the film. Further, some flaws in the original basis for the testing were discovered during the amendment process.

(8) What changes were made in NFPA 1970 to address physiological stress imposed by turnout clothing? Total heat loss (THL) has long been considered the balancing factor for thermal protective performance (TPP) interms of protection from heat. The two test methods are frequently used by the fire service in their specification of turnout gear to find the correct balance between heat insulation and the stress impact from the clothing. Whereas it is understood that TPP can be misleading in terms of firefighter protection from all types of fireground exposures, it has nevertheless become the main test information that departments often look to for defining how much thermal protection their gear should have. In fact, TPP only represents clothing insulation during an emergency fireground condition such as a flashover or backdraft and does not represent ordinary routine fireground conditions that involve much lower levels of radiant and convective heat exposure. Similarly, THL is but one type of measurement to reflect how gear prevents the escape of heat by both conduction and the firefighter sweating. But it is an evaluation under one set of conditions just like TPP (for heat protection) that does not tell the whole story for gear physiological impact on the firefighter.

Ret vs. THL

NFPA 1970 has added a new requirement for the maximum evaporative resistance (Ret) of firefighter garments. Like THL and TPP, this test applies to the principal three- layer composite used in the construction of these garments including the outer shell, moisture barrier, and thermal barrier. Unlike THL, lower numbers are better than higher numbers. The committee set the criterion at less than or equal to 45 Pascal square meters per Watt. This is a rather awkward set of units that is not intuitive like the Watts per square meter used for THL or the calories per square centimeter for TPP. This is because Ret is a resistance where higher resistances mean less effective heat transfer or heat loss.

The introduction of the new Ret requirement is going to change how departments judge garment breathability while also considering THL. While the two tests provide measures of garment heat loss, there are important differences and reasons for it being recommended in NFPA 1970:

• THL is a very good test for evaluating the ability of materials/gear to manage heat stress, but it only evaluates these properties at one condition (77°F: 65% RH).
• Materials with similar THL values can perform quite differently in conditions different than the THL test conditions. These conditions include warmer and low-level radiant conditions (e.g., from the sun, from hot surfaces, from nearby fires), which generally create higher challenges to effective heat stress management.
• Ret testing is conducted in warmer conditions than THL (95°F: 40% RH); therefore, Ret is expected to help provide some of that insight into firefighter heat buildup inside garments.
• Both the THL test and the Ret test are part of the same ASTM standard and use the same testing equipment.
• Ret only measures evaporative heat loss (breathability)-THL includes nonevaporative forms of heat loss as well.

The reason that breathability is important is because the insulation provided by firefighter protective clothing, while keeping external high heat from causing burn injury, also traps heat that causes physiological effects such as increased core temperature, skin temperature, and heart rate. The human body can only withstand so much increase in core temperature and other heat accumulation effects before harmful health impacts begin such as heat stress, heat stroke, and heat exhaustion. Both THL and Ret tests have been based on seeing what differences exist in physiological measurements for firefighters when wearing different composites used in the construction of garments. For example, Figure 7 shows the rate of core temperature rise that has been predicted based on three composites with different Ret values. Reducing the rate of core temperature rise is essential for firefighter health and safety.

Liquid penetration resistance criteria are added to firefighter PPE to prevent exposure to hazardous liquids. (Figure 7 courtesy of Getty Images and Excel Hydraulics.)

 

Limitations for Ret and THL

No matter how favorable the Ret and THL values may be for a given garment composite, once the firefighter enters conditions where there are high levels of outside heat or high humidity, the benefits of better heat loss or breathable garments diminish significantly. Nevertheless, the real value of favorable Ret and THL values occurs when the firefighter is outside the fire structure and is undertaking work activities where it is important to keep the core temperatures as low as possible before entering more hostile conditions. Furthermore, since both Ret and THL are measured only on the three-layer composite used in garment construction, other materials such as trim, reinforcements, pockets, and labels all reduce the heat loss capabilities and breathability of the garment. This is why full garment or systems-based testing described in the response to Question 11 can represent a better measurement of the garment system’s impacts on the wearer as compared to simpler material tests.

They have essentially the same THL values but much different Ret values. (Figure 8 courtesy of North Carolina State University.

(9) How has NFPA 1970 attempted to address ensemble element sizing concerns? The effectiveness of firefighter PPE is strongly dependent on the fit of individual ensemble elements including garments, helmets, gloves, footwear, and hoods. For many of these elements, robust sizing requirements exist. For example, garments are required to be manufactured in a range of ordinary apparel dimensions for both male and female firefighters. Similarly, firefighter footwear has some of the most rigorous sizing criteria for any type of boots to address both male and female sizing in terms of a wide range of full and half sizes and also in three widths. Helmets generally do not create sizing issues as long as there is sufficient adjustability of the suspension and retention systems.

Protective Hoods

For Question 4, it was explained that sizing will now become an issue for hoods. Since the mandatory addition of particulate-blocking capabilities for these products, a less elastic barrier layer will be necessary, resulting in a product that may not easily conform to an individual’s head as with traditional knit hoods. The newness of particulate-blocking hoods for the fire service has already prompted some manufacturers to offer more than one size instead of the “one size fits most” approach of the past. With the specification of easily acquired human head measurements in the standard as the basis for ensuring that the majority of head sizes are accommodated, it has yet to be seen how hood manufacturers will respond. Nevertheless, the interchangeability of hoods, where in some cases departments would issue newly cleaned hoods to firefighters at the fire scene, will now have to account for different sizes.

Protective Gloves

The perennial issues of sizing and fit have been for gloves. Prior editions of NFPA 1971 have indicated the need for manufacturers to provide gloves in at least seven sizes. In the edition of the standard before 2018, sizes were represented as extra extra small through extra extra large. While minimum dimensions were provided for how a given manufacturer size was supposed to fit a range of hand dimensions, there are still multiple complaints by many firefighters as to the relative fit and function of available gloves. In 2018, an entirely new sizing system was introduced related to the length of the index finger along with the width of the hand. That sizing system was met with resistance because of its unusual size designations (e.g., “70N”), which firefighters could not relate to. More importantly, there are still multiple complaints about glove sizing, particularly for female firefighters.

For NFPA 1970, the more recently adopted sizing system has been maintained but manufacturers are now given the option to use firefighter anthropometric data for demonstrating that their sizing system will fit the 5th to 95th percentile of hand dimensions for both male and female firefighters. While possible offering the potential for unique sizing systems, it is uncertain whether this approach will work to reduce the number of glove sizing complaints.

Research conducted at Iowa State University showing promising progress in relating just how well gloves fit firefighter hands has taken the technological leap for applying artificial intelligence for hand size measurement in determining conformance with available gloves. This progress is reported in “Optimizing Firefighter Glove Fit: AI-Driven Solutions for Enhanced Safety.”

(10) How has NFPA 1970 addressed contamination control for protective clothing? It is already recognized that firefighter protective clothing is being cleaned more frequently and secondary contamination that may reside in unclean clothing can be a hazard for firefighter health and safety. In prior editions of NFPA 1971, cleaning procedures have only been applied as a precondition for certain tests principally as a means of showing durability or the continuance of some performance property. In this edition, testing techniques borrowed from NFPA 1851 for verification of cleaning/de- contamination effectiveness of firefighter clothing had ISPs and other organizations introduced into the standard.

New requirements have been added to protective garments, helmet textile materials, and hoods for evaluating effectiveness of standard washer/ex- tractor-based cleaning for the removal of specific contaminants. The selected contaminants are the very same ones that are used in NFPA 1851 for cleaning verification that include certain semi-volatile organic compounds and heavy metals. In the new standard, garment outer shell, moisture barrier, and thermal barrier materials will be subject to these requirements where manufacturers/ suppliers will be required to report this information if requested by the purchaser. Similar requirements exist for helmet textile materials that include cover, suspension, and chinstrap materials. Particulate-blocking hoods will also be subject to these requirements.

The expected ramifications of this test information are as follows:

• Information on decontamination efficiency from advanced cleaning procedures is expected to help material suppliers improve fabrics for contamination resistance or provide improved cleaning protocols.
• Fire departments may be able to consider the ease of cleaning as a factor in selecting clothing.

Table 4 shows sample data for different materials.

In a way, the additional new outer shell test for diesel fuel contamination and flame resistance described in the response to Question 6 is another means for addressing decontamination effectiveness-specific cleaning. Manufacturers are already required to provide additional information related to cleaning and decontamination.

Lastly, while a condition of helmet design in the 2018 edition, the ability for firefighters to more easily remove helmet textiles for separate cleaning has been addressed with slightly more rigorous criteria.

(11) What is the significance of new optional tests provided in Annex G of NFPA 1970? Annex G was added to include different test methods for measuring overall ensemble performance for thermal protection, heat stress impact, protection from smoke particulates and fire gases, and functionality. The optional test methods are set up for use by PPE manufacturers and test laboratories but can also be used by fire departments. No specific criteria are set for these tests, but instructional information is provided for how to interpret and apply results.

The newly proposed full ensemble and other specialized tests are intended to provide the following benefits:

• New test methods will place more emphasis on interfaces and gear interoperability.
• Procedures will standardize claims for areas of performance not addressed in current requirements that can be applied to full products, which include ensembles of turnout clothing with and without SCBA or complete elements (e.g., gloves, boots, etc.).
• The fire service will be able to assess how different PPE works together and affects firefighters.

While it is expected that use of these optional tests may be initially limited, some movement to more comprehensive information about specific clothing items and ensembles is expected to better inform fire departments in the selection of PPE.

(12) Are there any other consequential changes for NFPA 1970 relative to turnout gear? A large of number of other changes were made in the standard that were not described above:

• New criteria and test methods were added to address the safety and continued performance of electronic components such as radio frequency identification (RFID) chips integrated into clothing.
• Criteria have been added to address the intrinsic safety of any electronics added to turnout clothing.
• The test to assess the deployment of and access to drag rescue devices (DRDs) in protective coats was made more difficult to better simulate field use.
• The former optional requirements for overall ensemble liquid and particulate protection have been modified/updated for making this claim only on garments.
• Manufacturers will be required to be more explicit in the identification of materials used in the construction of the product.

(13) With the focus of this PPE Supplement on protective clothing, what changes, if any, were made for other items in NFPA 1970?

NFPA 1975-Work Apparel

Though the responsible Technical Committee considered broadening the scope and changing some of the test methodology, in the end, no significant changes were made to the work apparel requirements since the prior 2018 edition other than those affected by consolidation of all four standards. The one change that was incorporated applies to any electrical circuitry that may be placed in a work uniform in terms of its intrinsic safety.

NFPA 1981-Open-Circuit Self-Contained Breathing Apparatus (SCBA)

A number of changes have also been proposed for improving SCBA. As with gear, some changes are primarily to clarify existing requirements, but several are expected to be consequential.

Intrinsic safety criteria were updated. Intrinsic safety is an approach to the design of equipment going into hazardous areas. The idea is to reduce the available energy to a level where it is too low to cause ignition. That also means preventing sparks and keeping temperatures low.

This change is important given that more functions for SCBA have become electronic in nature. The new change mainly points to the need for careful scrutiny of criteria to ensure that the electronics and related connections of electronic or electrical SCBA components can be rated for explosion environments in at least one of five defined explosion protection categories and the application of updated outside standards applied in this area.

Another area of changes was for the improved function integration of other electronic devices. These included the following:

• SCBA that include a wired connection to portable radio components complying with NFPA 1802 will be required to include appropriate radio frequency device connectors that are specified in NFPA 1802 design criteria.
• SCBA that include a wireless connection to portable radio components complying with NFPA 1802 will be required to include wireless status indication in the heads-up display (HUD).
• Additional criteria are established for wireless interfaces in SCBA to other devices, where used. SCBA will require wireless status indication in the HUD or other location on the SCBA discernible by the end user when the face piece is worn.
• The indicator has to show both when the device is paired with the SCBA and when the connection is lost.

Another significant change was the modification of the end-of-service-time indicator (EOSTI) and HUD remaining volume indications based on cylinder pressure. New criteria have been established to define EOSTI and HUD indication pressures that are proportional to the rated cylinder volume. The new criteria accounts for the compressibility of air and recognition that the relationship between remaining cylinder pressure and remaining cylinder volume is not linear. The impact includes the following:

• The EOSTI and HUD indicated air levels are consistently related to the cylinder volume.
• The alarm activation is unique to each pressure where different rated pressure cylinders will activate at their own unique pressures. This may change the amount of time available for a firefighter in an IDLH environment.
• The rate of air consumption is still dependent on the fire conditions, the physical condition of the firefighter, and the physical activity on the fireground.
• Fire departments will need to train their firefighters to understand and apply the new EOSTI and HUD air level indications.

As with apparel, the new NFPA 1981 will place requirements on manufacturers to make it easier for end users to remove harness straps, padding, and other soft goods in the design of their SCBA so that these items can be cleaned separately if deemed necessary as the result of fire- ground exposures. This change will further enable easier future replacement. The implications for this change include the following:

• The removable soft goods component of the new standard is a step toward cancer prevention and assistance with gross decontamination and clean cab technology.
• Soft goods may be removed, decontaminated, or washed and replaced on the SCBA.
• Departments may consider purchasing additional sets of soft goods. Once gross decontamination is completed on the fireground and the frame portion of the SCBA is dry, a fresh set of soft goods may be placed back on the pack. The pack may then be placed back on the apparatus (whether it’s in a cab or compartment) knowing it’s ready for the next incident.

Some testing technology in NFPA 1981 has been updated to more modern techniques. For example, the specifications for the breathing machine that uniquely evaluates how the SCBA maintains positive pressure inside the face piece was updated. In addition, more robust instructions for cleaning and disinfection of SCBA will now have to be provided by manufacturers. Finally, the requirement for indicating a low battery has been changed from two hours to one hour.

NFPA 1982-Personal Alert Safety Systems (PASS)

For this portion of NFPA 1970, the committee did not get through all the changes it intended to consider during the revision process. The following revisions were achieved:

• A new universal alarm tone was established.
• Updated requirements were applied for nonincendive performance and intrinsic safety of electronic equipment similar to SCBA.
• The label language was revised to align with portable radios.
• An allowance was to provide the end user information digitally.
• Several test methods were subject to minor improvements and clarifications.

Anticipating NFPA 1950: The Consolidated Standard for Technical Rescue, EMS, and Wildland/Urban Interface PPE

(1) What is NFPA 1950 and what is its scope? Like NFPA 1970, NFPA 1950 consolidates multiple PPE standards from different technical committees. It covers the combination of standards from different types of fire service missions.

• NFPA 1970 is intended to address the PPE items of a protective system that principally pertains to structural firefighting. Certainly, SCBA can be used for other types of emergency responses other than structural firefighting such as hazardous materials incidents. Work apparel can be further associated with any number of fire service missions but was included with NFPA 1970 because it seemed to make sense that the hazards being addressed in the original NFPA 1975 (heat resistance and thermal stability) were associated with high heat exposures most commonly resulting from structural fires.
• In the case of NFPA 1950, the standard spans three entirely different sets of fire service missions and, in some cases, nonfire service missions-tech- nical rescue for structural collapses; high angle rescue; vehicle victim extrication; responses to various natural disasters; emergency medical operations mainly involving emergency patient care and transport; and wildland firefighting, which is increasingly expanding to wildland urban interface firefighting.

These different missions that can be part of any fire department’s responsibilities also have their collectively different constituent groups of end users.

• Technical rescue or special operations groups are often separate teams within a larger fire department but can equally be a function where some capabilities more broadly exist for at least some members of many departments. On the other hand, there are highly specialized groups such as the Federal Emergency Management Agency (FEMA) Urban Search and Rescue Teams that exclusively engage in technical rescue activities.
• Depending on how municipal services are divided in a locality, many fire departments offer basic life support and advanced life support services that are integrated into department response capabilities. However, there are also separate ambulance and other emergency services that exclusively provide EMS. Sometimes, these services further expand into other specialized prehospital teams, particularly for large-scale events, that operate under different circumstances.
• While wildland firefighting has become a more prolific activity involving a greater number of firefighters, there are also multiple areas throughout the United States that operate wildland firefighting groups, which specialize only in wildland firefighting and to some degree urban interface firefighting, such as the U.S. Forest Service and CAL FIRE.

Each of these mission areas, while sometimes overlapping, further have a different range of PPE items that have been covered in the three individual standards that have previously covered these products:

• NFPA 1951, Standard on Protective Ensembles for Technical Rescue Incidents (2020 Edition).
• NFPA 1999, Standard on Protective Clothing and Ensembles for Emergency Medical Operations (2018).
• NFPA 1977, Standard on Protective Clothing and Equipment for Wildland Fire Fighting and Urban Interface Fire Fighting, 2022 Edition.

As with NFPA 1970, the upcoming NFPA 1950 consolidation effort has been the result of activity by different technical committees undertaking a number of revisions to each of the standards being combined. The questions below seek to capture the expected principal changes that will likely be addressed when the new standard is promulgated.

(2) What changes can be expected for technical rescue protective clothing and equipment? When this standard was first created, the prevailing hazards guiding protection needs were the impact of a rugged physical environment combined with potential for exposures during a flash fire (ignition of a combustible environment within ensuing very short duration fire exposure), bloodborne pathogens from engaging with disaster victims, contact with chemicals from broken containers, and the need to be visible in a relatively complex response setting. Consequently, many requirements from structural firefighting protective clothing and equipment were borrowed for the purpose of defining technical rescue products. Over the years, the requirements that applied to this ensemble consisting of garments, helmets, gloves, footwear, and goggles have become increasingly pragmatic. The standard now focuses mainly on the physical protection requirements with lighter levels of thermal protection. The need for barrier protection against either liquid chemicals or infectious fluids is optional.

For the consolidation of these requirements into the new NFPA 1950, principal changes in the standard will likely include the following:

• Further qualification of garment fabrics using an instrumented manikin test that simulates a flash fire exposure.
• More detailed requirements for barrier garments that entail additional criteria for bloodborne pathogen and liquid chemical exposures while making allowances for different test approaches based on new material technologies.
• The use of evaporative resistance requirements for composites providing optional liquid barrier garments (see discussion of this requirement for NFPA 1970).
• The readdition of optional visibility requirements in the form of using fluorescent and retroreflective high-visibility materials on garments according to the national standard on high visibility safety apparel.
• Simplification of the helmet requirements that result in a universal helmet that will apply to both EMS and wildland firefighting. This included the creation of a new helmet roll-off test for evaluating how well the retention system stays in place for the helmet.
• Some downward adjustment of the exposure temperatures used for footwear that permit synthetic leather alternative upper materials.
• The ability to use machine-readable tags in place of labels.
• Provision of intrinsic safety and nonincendive criteria for any electrical circuitry that may be used in the construction of these products.

(3) How are the NFPA 1999 PPE requirements being updated? The standard for emergency medical operations protective clothing and equipment is a much broader standard that has been put together more in a menu format offering different clothing or equipment items that could be used during various missions where exposure to blood or other infectious liquids as well now as exposure to transmissible airborne diseases may be encountered at the emergency scene. Typically, first responders rely on examination gloves, then some eye face protection, and then some form of garments based on their perception of likely exposure risks. For this reason, the standard establishes multiple categories for types of garments, gloves, eye and face protective devices, footwear, and specialized respirators. The standard further defines the integration of all these items into different full-body ensembles for more extreme exposures as may occur in a serious disease outbreak such as Ebola or the release of a biological agent. Further, distinctions are made between what are considered single-use (disposable) and multiple-use (reusable) products. Many of the changes since the 2018 edition of the standard were based on lessons learned from the COVID-19 pandemic.

Principal changes to NFPA 1999 as part of the new NFPA 1950 are expected to include the following:

• The addition of an evaporative resistance requirement for garments to supplement total heat loss for easing the physiological burden for long-term wearing of garments.
• Referencing existing ASTM standards for different types of examination gloves in lieu of the very specific NFPA requirements previously specified.
• An optional provision for making permeation resistance protection claims against fentanyl and other opioid drugs for both examination and cleaning gloves.
• Direct referencing of ASTM requirements for both medical masks in the new category of limited protection barrier face coverings that were updated in response to pandemic concerns.
• The recognition of a new classification of eye and face protection specifically designed for blood/bodily fluid sprays and spurts according to a recently introduced American National Standard for these types of products.
• Removal of the existing helmet criteria with a reference to use the new universal NFPA 1951 technical rescue helmet instead.
• The identification of new powered air purifying respirators as one form of suitable respiratory protection called PAPR 100s, which are lighter and quieter than industrial devices of the same type now available through NIOSH approval.
• The ability to use machine-readable tags in place of labels.
• Provision of intrinsic safety and nonincendive criteria for any electrical circuitry that may be used in the construction of these garments.

A large number of these changes were made to identify specific equipment likely to already be commercially available based on more conventional healthcare product specifications. These changes were made to make it possible for greater accessibility of clothing and equipment meeting the NFPA 1999 portion of the NFPA 1950 standard.

Figure 9 courtesy of author.

 

(4) Were many revisions made to NFPA 1977 since it was just revised in 2022? While the standard on wildland protective clothing and equipment had just recently been updated, the Technical Committee had an opportunity based on the consolidation to address some topics that had not been completely resolved during the earlier revision. Some key changes that will likely ensue for this product mission area follow:

• Revamping the detailed sizing requirements for garments. For example, the specific inclusion of new women’s upper torso garment dimensions by size has been introduced. The NFPA 1977 requirements are relatively unique for protective garments in that they specify exact dimensions for standardized garments in terms of permitted measurement ranges. These requirements are applied to both shirt/pant combinations and coveralls.
• The specification of a minimum three-inch collar height for upper torso garments.
• Some adjustments were made to the performance requirements for the new optional requirements for particulate-blocking garments.
• The requirement that gloves be available in five sizes.
• The removal of detailed specific shelter requirements altogether that were added to the previous edition but discontinued because the testing capabilities were no longer in place. Requirements for shelters will now default to the specifications for these products as provided by the U.S. Forest Service.
• The ability to use machine-readable tags in place of labels.
• Provision of intrinsic safety and nonincendive criteria for any electrical circuitry that may be used in the construction of these garments.

(5) What is the new category of multifunctional protective clothing in NFPA 1950? One of the benefits of combining the three standards into one was to create a new category of protective products called multifunctional ensembles. Some fire departments already defined utility in a second set of garments that can address multiple missions where turnout clothing may be considered too bulky, heavy, and inappropriate for those very same functions. To date, several manufacturers have offered products that are certified to different combinations of standards such as technical rescue and EMS for garments that have barriers and technical rescue and wildland firefighting for garments that do not have barrier. Garments with these multiple certifications provide a way of addressing combined hazards in one product but are often expensive to certify because even when the same tests are called out, there are slight differences in the test parameters or criteria that require duplicate tests of prospective products.

In the new proposed NFPA 1950, a separate category with its own certification and labeling requirements is now established for multifunctional gear that includes garments, helmets, gloves, footwear, and goggles. This has already been accomplished for protective helmets where the same design and performance requirements are now going to be applied to technical rescue, EMS, and wildland firefighting. In the new product category, references are made to other parts of the standards that are considered the most appropriate set of criteria for a multifunctional item be it a garment, glove, or footwear. While the new multifunctional items are not a replacement for a given mission category of specific clothing or equipment, they will bear a label and certification listing that defines their use in multiple types of missions. It is expected that this new clothing category could be of interest to some departments that are weighing how frequently they use their turnout clothing, which is knowingly wearing out quicker and increasingly expensive for only a small proportion of the responses for which structural firefighting occurs.

(6) When will the new NFPA 1950 be issued and when can new gear be expected? At the time of this writing, it is believed that the new NFPA 1950 will be published sometime in April or May 2025. As with other standards, there will be a 12-month grace period for which products meeting current editions of the NFPA 1951, NFPA 1999, and NFPA 1977 standards can be carried forward. Nevertheless, new products created to meet the new NFPA 1950 standard may be somewhat delayed because the capacity for new product certification will be exceeded as structural firefighting protective clothing products are making their way through the certification process for complying with the new NFPA 1970 standard. This logjam in testing and certification will likely push the availability of products complying with the new standard toward the end of 2025.

Figure 10 courtesy of Innotex.

Expected Changes for the Upcoming Consolidated NFPA 1850

(1) What is the new NFPA 1850 standard and what will it encompass? Work has been ongoing for the past several years on NFPA 1850, which combines the requirements for selection, care, and maintenance of both protective clothing (now covered in NFPA 1851) and SCBA that has been found in NFPA 1852.

The standard is currently moving forward where the respective Technical Committees having nearly finished the second drafts for their portions of the consolidated standard. The current proposed title of the new standard is NFPA 1850, Standard on Selection, Care, and Maintenance of Protective Ensembles for Structural and Proximity Firefighting and Self-Contained Breathing Apparatus (SCBA). It is expected that the new standard will be issued in September 2025.

Selection, care, and maintenance practices are becoming increasingly more important for firefighter PPE, partly due to broader awareness for minimizing contaminant transfer to firefighters but also due to the fact that many items are becoming more complex and questions still abound relative to individual product service life and continued performance. Several parts of the new NFPA 1970 will impact these areas. While the standard is not yet fully finished, this portion of the PPE Supplement provides a preview of some of the key expected changes. Even though the organization of the new NFPA 1950 standard will be organized by having the NFPA 1851 and NFPA 1852 portions separated in the consolidated standard, expected changes are presented in by topical area for both turnout clothing and SCBA rather than by the individual standards.

(2) What changes can be expected for how departments manage their PPE program including selection approaches? Within the NFPA 1852 standard and as a general practice for SCBA, specific responsibilities have been in place for a technician, who is an individual that is qualified and authorized by the SCBA manufacturer to provide care and maintenance of SCBA that includes performing inspection, repair, and testing beyond normal competency levels for individual firefighters. The NFPA 1852 requirements remain unchanged in this regard. However, for protective clothing, new categories for a personal protective clothing (PPC) manager and technician have been defined within the portion of the consolidated standard that addresses protective clothing. This change has come about to address a long-standing need for fire departments to have specially trained individuals with minimum levels of competence for addressing some of the details for increasingly more complex protective clothing items, especially as related to how they are cleaned and repaired.

The proposed NFPA 1851 portion of the standard provides flexible requirements that allow departments with varying resources to accomplish how these roles may be fulfilled. Additional information is provided in a nonmandatory annex of the new standard to assist as a starting point for how departments can set up their own specific PPC programs around these criteria. A separate annex also identifies the individual areas of responsibility that apply to the PPC manager and PPC technician.

The importance of training with respect to different groups providing guidance to firefighters and fire departments is also being addressed. Historically, protective clothing manufacturers as well as ISPs have been empowered by the standard to provide this training. These requirements have been clarified as to which entities are qualified to provide training in different aspects of selection, care, and maintenance. NFPA 1850 stipulates that training be provided within one year following the issuance of NFPA 1850.

The hazard/risk assessment portion of the standard has been supplemented to provide additional guidance to fire departments. Much of this guidance has been moved to a separate informative annex that helps instruct fire departments on how they can make decisions when selecting gear. There is also new information related to how departments can manage providing replacement clothing when gear is taken out of service for cleaning and decontamination.

In the area of turnout clothing selection, there is a new requirement to consider restricted substances and the compliance of PPE with state/local regulations as part of the selection process. These criteria have become pertinent as the new NFPA 1970, issued in late September 2024, now mandates that certain toxic or hazardous substances in key materials (e.g., formaldehyde) used in the construction of turnout clothing not exceed maximum levels through independent testing. To further address this topic, the proposed new standard also recommends that clothing be subjected to an advanced cleaning before being issued to individual firefighters. This recommendation is being made to remove any residues on clothing that may occur in its manufacture.

It can help fill department gaps when gear is being cleaned or as needed for short-term use. (Figure 11 courtesy of 911 Safety.)

 

The NFPA 1852 part of the standard will now require more robust fire department standard operating procedures with respect to inspection and the various forms of cleaning and decontamination, including the use of preliminary exposure reduction as part of an on scene means for reducing exterior contamination following exposures during structural firefighting.

A somewhat different approach is being applied for indicating how prior edition SCBA remain serviceable. In the past, NFPA 1852 indicated those editions of the standard for which the SCBA are certified and allowed these SCBA to still be used. Clarifications in the proposed new requirements generally promote retirement of SCBA following 15 years after the date of manufacture. Nevertheless, different provisions are being made by which SCBA certified to earlier editions of NFPA 1981 can be allowed to stay in service. Depending on the number of upgrades that have been applied to new editions, some older-edition SCBA can have their service life extended for approximately 20 years after the year of manufacture, depending on the specific edition of the SCBA product standard used for certification.

Some of the fire service will be disappointed that there has been no change in the mandatory 10-year retirement requirement for NFPA 1971-compliant protective clothing. Every time this topic comes up, there is considerable debate within the committee as to whether to permit an extended service life past 10 years based on certain factors, such as the amount of clothing use or nonuse and if specific techniques are available to evaluate whether item service life can be extended. No agreements were reached in this area and therefore these requirements remain essentially unchanged.

Increasing wash temperatures or repeated cleaning improves contaminant removal efficiences. (Figure 12 courtesy of author.)

(3) How are cleaning and decontamination procedures being expanded? As with the last edition of NFPA 1851, a substantial amount of the revision activity was focused on addressing cleaning and decontamination of turnout clothing. A number of changes were specifically proposed to enable more modern cleaning methods to be applied to different elements of clothing or to identify parameters that could improve contaminant removal efficiency. For example, some elements of turnout clothing were originally only indicated for handwashing. The new edition of the standard will recognize existing or emerging machine-based cleaning/decon- tamination technology so that these procedures can be more easily implemented when available and when found not to damage the clothing. Not only have liquefied carbon dioxide cleaning procedures made their way into the marketplace since the last edition, but so have other machines that are capable of cleaning items such as helmets and SCBA. Specific to SCBA, provisions now exist where specific types of machine cleaning can be performed if approved by the respective SCBA manufacturer.

A very large change that has occurred for cleaning clothing has been raising the maximum wash temperature for advanced cleaning from 105°F to 120°F. Previously, there had been some resistance to increasing the temperature because of concerns related to the durability of certain components on protective clothing. Many of those concerns have been allayed and it is well-established that a 15°F increase in temperature can significantly improve the removal of certain contaminants (Figure 11). Part of the advanced cleaning procedures also now includes a maximum limit on water hardness. When excessive, high levels of water hardness can diminish cleaning effectiveness. The need to routinely clean and disinfect washer/extractors will also now be a requirement, as well as monitoring federal, state, and local requirements for the discharge of wastewater or other effluent from the cleaning process (an increasing concern now especially because some PFAS from finishes of older gear are incrementally removed during cleaning).

The matrix for determining when to apply the different cleaning/decontamination approaches has also been updated, principally to address lithium-ion battery fires originating from vehicles or storage facilities as a form of specialized cleaning, depending on the circumstances of exposure for the engaged firefighters and their PPE. A placeholder has also been put in for this topic to provide more extensive requirements and guidance information into the standards once research yields findings that help establish best practices for any the unique contaminants associated with these fires and related events.

Lithium-Ion Battery Fire Decontamination Concerns

The growing incidence of fires involving lithium-ion batteries (LIBs) creating unique contaminants and dynamic fireground conditions has warranted its separate consideration in the cleaning and decontamination part of the NFPA 1950/1951 (Figure 12). Current efforts for revising the standard address considerations for whether specialized cleaning is needed by assessing:

• The total amount and proportion of fire contents attributed to LIBs or related products.
• The degree to which firefighters have expected exposure to LIBs or related product decomposition products from the fire.
• The environmental characteristics of the fire location.
• The availability of any protective element, other surface, or air measurements that reveal unusual or high levels of contaminants that are believed to be associated with fires involving decomposition of LIBs or related products.
• Prior experience in being able to successfully remove contaminants by current advanced cleaning procedures from protective elements that have been exposed during operations involving a significant content of LIBs or related products.
• The availability of independent documentation on to the demonstrated ability of specific cleaning processes or agents to remove contaminants from protective elements that are associated with fires involving the decomposition of lithium-ion batteries or related products.
• The ability to perform pre-and post-fire exposure cleaning to examine the effectiveness of the chosen type cleaning.

Though not part of the standard yet, it is anticipated that recent and ongoing research from organizations such as the Texas A&M Engineering Extension Service, UL Research Institutes, Fire Protection Research Foundation, and Iowa State University are expected to yield detailed guidance that will influence updates to NFPA 1950 on this topic.

The NFPA 1852 portions of the new consolidated standard have further been aligned with NFPA 1851 for using the same terminology related to primary exposurereduction, advanced cleaning, sanitization or disinfection, and specialized cleaning. The consolidation of both standards is perceived as one of the ways that cleaning approaches are being harmonized among the different types of PPE that require cleaning and decontamination.

Note: Red outlined area new proposal to NFPA 1850. (Figure 13 courtesy of author.)

(4) What updates can be expected for PPE inspection, repair, and storage procedures? More robust requirements have been set for protecting individuals who must handle and clean various forms of contaminated fire service PPE. The new provisions are more specific as to the types of gloves, face/eye protection, protective clothing, and respirators and were warranted for personnel who engage in inspecting and cleaning clothing that has not yet been subject to advanced or specialized cleaning.

With the addition of the PPC manager and technician roles within the NFPA 1851 part of the consolidated standard, fire departments will be required to ensure that advanced inspection and cleaning will be performed by trained individuals. Newinspection details are further provided for some of the elements and are augmented by simple tests that can help evaluate the continued barrier qualities of gloves, footwear, and particulate-blocking hoods. Some additional clarifications have been added to the types of repairs that can be undertaken by fire departments vs. those by a verified ISP, manufacturer, or other qualified facility.

Different approaches are now prescribed for storing protective clothing, whether on duty, off-duty, or for transport to an ISP or verified cleaning facility. The new requirements are intended to help minimize continued exposure to personnel by having them isolated from firefighters in practical ways until needed for use.

Overall, fire departments face different choices for how they go about providing care and maintenance of clothing and equipment that include cleaning, inspection, and repairs. Tonya Herbert of Florida PPE Services provides a detailed assessment of the advantages, disadvantages, and costs associated with different options.

(5) Are cleaning/decontami- nation verification requirements for ISPs and other organizations being improved? A pivotal part of the new 2020 edition for NFPA 1851 was the establishment of verification for ISPs and other facilities for cleaning of firefighter protective clothing. These procedures that are now nearly three years into their implementation have resulted in the verification of more than 80 facilities in North America with a couple in other continents. The verification process conducted by independent certification organizations, including Intertek Testing Services and UL Solutions, has established accountability for commercial organizations that provide inspection, cleaning, and repair of firefighter PPE. Cleaning effectiveness against representative contaminants is quantitatively verified.

A large part of the discussion for cleaning verification for the new edition was whether to increase the current minimum effectiveness requirement for certain organic and heavy metal contaminants from 50% to 70%. However, that change was not undertaken because of a number of other revisions affecting the verification procedures and changes in permissible cleaning parameters that made it difficult to judge whether the higher efficiencies could be achieved. Figure 13 shows a composite of cleaning effectiveness measurements from both UL and Intertek Testing Services that provide verification of ISP and other facility cleaning. While an increased level of decontamination effectiveness is not being added at this time, this topic remains an area of keen interest for the committee to address in the near future. Still, the new standard will require greater disclosure of cleaning effectiveness information from the facilities that become verified under the new standard.

In the new proposed edition of NFPA 1850, changes are being sought to streamline the verification process that make it both more precise and accessible to different organizations. Furthermore, verification has been extended in a number of ways for assessing cleaning up different garment material layers beyond the outer shell as well as hoods in other types of contaminants. For example, separate optional verification procedures have been established for removing the highly hazardous and persistent polycyclic aromatic hydrocarbons (PAHs) encountered in nearly all fires and certain PFAS chemicals. Optional procedures have also been added to assess the impact of repeated cleaning on gear in terms of how a specific process can degrade performance properties over a large number of cleaning cycles. Lastly, placeholders have been into the standard for verification to address:

Both current and proposed NFPA 1851 require removal efficiencies above 50% on metals and SVOCs. (Figure 14 courtesy of author.)

• Lithium-ion battery fire contaminants.
• The means for simulating certain fireground contamination from small- scale burn tests.
• Separate procedures for verifying standalone cleaning equipment and detergents or cleaning agents.

(6) What does the overall direction and implementation schedule look like for NFPA 1850? As indicated in the introduction, the new consolidated NFPA 1950 is expected to be promulgated in late spring or summer of 2025. The Technical Committees have yet to ratify all the changes that have been proposed as part of the near final draft. Nevertheless, the process will conclude in early 2025 and there still will be an opportunity for any additional consideration for the proposed changes through an open, public process that the NFPA permits for completing any standard. Moreover, there is an expectation that certain amendments may be proposed in parallel to either update orclarify some of the new proposed content going into the standard. Regardless, the majority of end users involved in the revision process feel that the advancements being made in the areas of selection, care, and maintenance for firefighter PPE are likely to promote health and safety for the fire service. In about another year, the final revised standard should start to have a positive impact on firefighters.

What Do All These New Standards Mean for the Fire Service?

Some in the fire service could claim that all the standards activity for addressing PPE may be for naught and contribute to an excess of rules and regulations that are increasingly difficult for fire departments to comply with. They would argue that everything is fine the way it is—why mess with something that they believe to be working? Certainly, this is a position that some fire departments would like to take, but it is unrealistic, since we live in an ever-changing world where technology, people, and expectations evolve.

Another attitude exists where the need for change is recognized but in a different way than which it usually occurs. In this perspective, others in the fire service believe in the need for change but question how the change is coming about. The creation of and, more importantly, the revisions to NFPA standards generally take the path of continually adding new “stuff.” Rarely is the old stuff reexamined for its continued value.

Moreover, if we are continually adding new requirements, including additional criteria and other test methods, the outcomes for compliance of products accounting for the agglomeration of both historical and emerging requirements may not align with fire service needs. There is nothing wrong in taking a step back and reflecting on what you have and whether it is at the right level for how the current fire service hazards stack up in modern-day response approaches. Certainly, tactics have changed, often informed by new tools and resources in addition to science that teaches us lessons for how some improvements can be made. For example, outside firefighting, wearing total encapsulating Level A suits for most hazmat responses simply does not make sense when hazmat teams are better equipped and trained that tells them that they are better off in PPE that makes them more agile and tactical. Might this also be the case for structural firefighting and related emergency response missions despite the constantly changing fireground environment?

If every requirement was analyzed for its true value for what it brings to an “appropriate” level of protection starting from scratch, could PPE look a lot different than it currently does? This is something to contemplate because by responding to every new instance of need, the complexity of PPE dramatically increases and the ability to recognize both its capabilities and limitations can sometimes be obscured.

Still, with new hazards presented such as by the tremendous increased use of lithium-ion batteries for the unique exposures created being now more common fire contents, in addition to other situations that have not been fully anticipated, there is a balancing act as to what PPE can do as well as what PPE should not be expected to do. This can also translate into improved training and recognizing what can be safely and practically accomplished during certain types of emergency situations. One example of interest is a line-of- duty-death (LODD) fire that I investigated: a Newark, New Jersey, shipboard fire in 2023. Neil McMillan of the IAFF provides his take on the role of PPE and whether this should be addressed by standards, tactics, or both.

Regardless of fire service opinion related to how far PPE standards should go, there is the potential upcoming reality that OSHA may enact new comprehensive regulations that govern the health and safety of firefighters and other emergency responders. In the proposed regulations provided in a notice of public rulemaking earlier in 2024 and announced in 2023, a number of very specific recommendations were made to overhaul the fire brigade regulations found in Title 29, Code of Federal Regulations Part 1910.156 as well as related regulations. These regulations substantially call for the use of NFPA standards to improve firefighter health and safety. In fact, of the 250 pages for this proposed notice of an Emergency Response Standard, approximately only the last 14 pages pertain to the actual regulations that address a range of safety and health matters including staff, qualifications, training, apparatus safety, and PPE. The majority of the front end comprises a detailed analysis of emergency response hazards and statistics, as well as potential costs associated with the compliance to the proposed regulations.

For PPE, specific provisions are made for emergency response organizations to provide their members with PPE that complies with several NFPA standards discussed in this supplement including NFPA 1971 (structural/proximity gear), NFPA 1981 (SCBA), NFPA 1982 (PASS), NFPA 1951 (technical rescue PPE), NFPA 1999 (EMS PPE), and NFPA 1977 (wildland/urban interface PPE). While the proposed regulations do not reference NFPA 1851 or NFPA 1852, certain provisions address ensuring that gear is kept clean and serviceable for safe use.

During the extended public comment period, thousands of comments were submitted with a large majority complaining about the reach of the federal government to regulate the fire service and, in particular, how the costs of compliance would make it unduly difficultfor poorly resourced fire departments. Hearings held in November and December 2024 further provided public comment on the proposed regulations.

While there is uncertainty on the final form these regulations will take, it is expected that, if enacted, the OSHA regulations for emergency response will continue to reference NFPA standards as the basis of minimum requirements for PPE.

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JEFFREY O. STULL is president of International Personnel Protection, Inc., which provides expertise and research on the design, evaluation, selection, and use of personal protective clothing and equipment and related products to end users and manufacturers. He has conducted numerous studies relative to the effectiveness and performance of protective clothing and equipment in a variety of applications. Stull is the past chairman of the American Society for Testing and Materials F23 Committee on Protective Clothing, a member of several National Fire Protection Association technicalcommittees on emergency responder protective clothing and related equipment, a participant in the government’s Interagency Board for Equipment Standardization and Interoperability, and the former lead U.S. delegate to the International Standards Organization for Protective Clothing. He was president of TRI/Environmental, Inc. from 1988 to 1993, an organization that provided certification testing and conducted research projects related to protective clothing. He was a project officer for the U.S. Coast Guard Office of Research and Development from 1983 to 1988, where he headed several programs related to personnel protection. He has an M.S. degree in chemical engineering from the Georgia Institute of Technology, an M.S. degree in engineering management from the Catholic University of America, and a B.S. degree in physical sciences from the U.S. Coast Guard Academy. He is well-published in all areas related to protective clothing and equipment, including peer-reviewed articles related to protective clothing performance. He is a subject matter expert in the area of personal protective equipment.