BY TONYA HERBERT, OWNER, FLORIDA PPE SERVICES AND THIN RED LINE DECON
NFPA 1851, Standard on the Selection, Care, and Maintenance of Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting, establishes requirements and procedures for cleaning, inspection, and repair of turnout gear.
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The standard outlines what a department needs to do to comply. However, it doesn’t tell the department HOW to do it. It is up to the department to determine the best way to abide by the standard. There are many ways a department can comply with NFPA 1851, from using an ISP for all maintenance to becoming a verified organization. Each has its own set of costs, advantages, and challenges.
First, it is important to address the differences between a verified ISP, a manufacturer-trained organization, and a verified organization:
- A verified ISP is an independent third party certified to perform advanced cleaning, inspection, and repair services.
- A manufacturer-trained organization is a nonverified entity trained to conduct certain maintenance tasks.
- A verified organization has undergone verification to conduct all aspects of gear maintenance internally.
Another important distinction is the difference between “Basic Repairs” and “Advanced Repairs.”
- Basic repairs can be accomplished by trained personnel and include patching of minor tears, char marks, ember burns, and abraded areas on the outer shell; repairing skipped, broken, or missing stitching to an outer shell that does not exceed one inch; replacement of hardware except positive closure systems on outer shells; and closing a liner after a complete liner inspection.
- All other repairs, including any to a thermal liner or moisture barrier, are classified as advanced repairs and must be performed by a verified ISP, a verified organization, or an element manufacturer.
To comply with NFPA 1851, a department must ensure that ensemble elements receive an advanced cleaning every six months, resulting in a minimum of two advanced cleanings in a 12-month period, with one being in conjunction with an advanced inspection. There are numerous ways this can be accomplished, depending on the size of the organization, the resources of the organization, and the proximity and availability of an ISP. On one end of the spectrum is using an ISP for all gear maintenance. On the other end of the spectrum is becoming a verified organization.
Figures courtesy of author.
In between are multiple variations. When deciding the best option for your organization, keep in mind that there are various costs associated with each option including start-up costs, operational costs, payroll costs, and service costs.
In analyzing the various options available, a cost comparison was prepared for each option. To accurately compare each option, the following assumptions were used for each analysis:
- The department has 500 active firefighters.
- Each firefighter has two sets of gear.
- Every set is cleaned two times per year and inspected once a year.
- Gear is cleaned after an exposure to products of combustion and counts toward one of the required advanced cleanings.
- 50% of the gear inspected has some level of repairs needed, with 40% needing advanced repairs.
- There are approximately 600 exposures each year necessitating an advanced cleaning.
- An average of six firefighters are involved in a typical exposure.
- Equipment is depreciated over seven years.
- No facility or software costs are captured in the capital expenditures.
Option 1: Outsourcing Gear Care and Maintenance to an ISP.
The first option is using an ISP for all gear maintenance including all advanced cleanings, advanced inspections, and repairs. There are some departments that, for whatever reason, do not want to or have the ability to do advanced cleanings after exposures and they rely on an ISP to handle all their gear maintenance requirements. Typically, these departments do not have the funding or infrastructure to have their own extractors and rely on an ISP for everything.
In this case, there are very few start-up, operational, or payroll costs associated with gear maintenance. A department typically would have a part-time PPE manager who oversees the gear maintenance program and start-up costs would be limited to equipment and furniture related to that position. Operational costs are limited to PPE required to prepare gear to be sent to an ISP. The most significant costs come from the ISP services for the advanced cleanings, advanced inspections, and repairs.
The advantages of this option are that there is no significant upfront investment in equipment, there is no personnel required other than the part-time manager, and there is less liability for the department. However, during the time gear is being cleaned, inspected, or repaired, it is not available for use. This could affect operational readiness and may lead to the need for additional resources or contingency plans such as a second set of gear or spare gear. Even if a second set of gear is provided, additional spare gear may be required depending on the turnaround time an ISP has been granted by the department.
Option 2: In-House Cleaning with Some Use of ISP. An organization can conduct advanced cleanings after all exposures and contract with an ISP for annual advanced cleanings, advanced inspections, and repairs. Many paid departments have extractors either at a centralized location, located at district stations, or at each station and have trained personnel to conduct an advanced cleaning after exposure to products of combustion. The periodic cleaning would satisfy the requirement for one of the advanced cleanings; the ISP would conduct the other in conjunction with the advanced inspection.
The start-up costs would include extractors, dryers, potentially a soak tank, laundry bins, Z-racks to hang gear, utility tables to process gear, a computer, furniture, and a delivery van. Operational costs include detergent, germicide, and PPE required to process gear as well as utilities. Depending on the size of the department and call volume, a department could expect to have a full-time manager and a full-time processor to manage the program. The most significant part of the costs still involves the services provided by the ISP.
The biggest advantage of this model is that a department can potentially turn gear around faster than if the ISP was conducting the periodic cleaning. Typically, gear could be picked up, cleaned, and returned to the firefighter before the next shift. Because you are using an ISP for your annual advanced cleanings, inspections, and repairs, if the department needed a backup for periodic advanced cleanings (personnel turnover, vacation, equipment issues, etc.), you already have a working relationship with an ISP. The disadvantages of this model include upfront investment in equipment and infrastructure and dependency on internal personnel. There are also variables on the turnaround time for repairs with the ISP.
Option 3: Use ISP Only for Repairs. The department would be responsible for conducting all advanced cleanings and advanced inspections. During the advanced inspection, if the department identifies an issue, it sends the gear to the ISP for repair. This model requires a greater commitment from the department not only for the infrastructure and equipment but for the personnel.
Start-up costs would be similar to the second option, with the addition of inspection equipment and tables. NFPA 1851 requires moisture barriers to be tested using a hydrostatic tester and particulate hoods to be tested with a light evaluation apparatus or a smoke evaluation apparatus. Conducting advanced inspections annually or whenever a routine inspection determines potential damage most likely will require additional personnel, increasing overall payroll costs. And although the ISP is not doing annual advanced inspections, most ISPs would require any gear being sent in for repairs to undergo an advanced inspection by the ISP staff to fully identify any potential damage needing repair. They may also require advanced cleaning to ensure the gear meets their standards of cleanliness before they handle the gear.
The main advantage of a department conducting all advanced cleanings and advanced inspections in house is that turnout gear can be turned around faster than would typically be expected from an ISP. If a department identifies potential damage during a routine inspection, it can conduct an advanced inspection and determine if repairs are necessary. While there might be evidence of thermal exposure on the outer shell, it may not have caused thermal damage to the moisture barrier. Rather than sending the gear to an ISP for advanced inspection, the department can conduct the testing and potentially put the gear back in service if no damage is found. Therefore, only gear that needs repairs is sent to an ISP. The drawback is that there are increases in start-up costs and personnel costs. You will also be duplicating advanced inspections on gear that needs to be repaired, and turnaround times for repairs are dependent on the ISP. Some ISPs will prioritize customers who are paying for full gear maintenance over ones sending in gear just for repairs.
Option 4: Department Performs Nearly All Gear Maintenance.
A larger department may consider a fourth option, one that has the department conducting all advanced cleanings, advanced inspections, and basic repairs. Any advanced repairs, including repairs to the thermal liner or moisture barrier, would be sent to an ISP.
To be able to perform basic repairs, additional hands-on training would be required for the department personnel who will be responsible for making the repairs or managing the repairs. In addition, certain equipment is needed to conduct basic garment repairs including sewing machines; hand presses for hardware; and specific materials needed such as outer shell material, trim, fire-rated thread, hook and loop, and hardware.
A benefit of implementing such a program is less gear must be sent to an ISP for repair and therefore will be back in service faster. There is no verification required for a department to perform its own basic repairs. However, the start-up cost is much greater when sewing machines and presses are included in the upfront investment. Operational costs increase with the materials needed, and personnel costs also increase since more work will be done. As with the previous option, the department is likely to still incur advanced cleaning and inspection charges for gear sent to an ISP for advanced repairs.
Option 5: Become a Verified Organization. The department conducts all advanced cleanings, advanced inspections, and repairs in house. The department, in essence, is its own ISP. Currently there are four verified organizations in the United States.
While many departments may like the sound of this option, thinking it will save money, understand that the verification process is not for the faint of heart. It is comprehensive, intensive, and expensive. The verification is only good for two years, and follow-up inspections are done every six months. It is strongly recommended that if you decide to take this path, you work with a verification consultant who can walk you through the process, assist with the required manual, provide guidance on the testing procedures and samples, and assist with asset purchases. It will be money well spent!
As a verified organization, your department can perform all advanced repairs. Doing so requires additional equipment. To become verified, certain types of repairs on outer shell and thermal liner material must be done by specialized sewing machines. Moisture barrier repairs require a heat press. Therefore, equipment start-up costs are the highest with this option. Operational costs are also the highest as you will need all the various materials that comprise your turnout gear. There are typically minimum order quantities required when purchasing materials and hardware. And the department will be required by the third-party verifying organization to provide liability insurance. Personnel costs will also be the highest of all the options.
Assuming more maintenance responsibilities means that the department has to perform hydrostatic testing as part of advanced liner inspections.
However, as a verified organization, your department will never have to send gear to an ISP for repairs. Several departments that became verified did so to ensure the quality of work being performed as much as to provide faster turnaround times on gear maintenance. And, as a verified organization, you could provide advanced cleaning, advanced inspection, and repair services to neighboring departments.
Deciding on the Best Option. When considering how to comply with NFPA 1851, departments must weigh the costs and benefits of various options. You need to determine your department’s priorities, evaluate your available ISPs, network with other agencies, and attend PPE workshops. By understanding the differences between various organizational structures and their implications, departments can make informed decisions to ensure gear is properly maintained and in compliance with NFPA standards. Remember, NFPA 1851 is a resource to guide departments in establishing effective gear maintenance practices.
