When Tragedy Strikes: Standards and Hazards Assessments—What Protects Us During High-Risk, High-Reward Operations?

PPE SUPPLEMENT

BY NEIL McMILLAN, DIRECTOR, SCIENCE & RESEARCH, INTERNATIONAL ASSOCIATION OF FIRE FIGHTERS LOCAL 162

Tragedy in Newark

At 21:20 on July 5, 2023, security cameras at the Port of Newark showed smoke emanating from the top deck of the Grande Costa d’Avorio cargo vessel, which was being loaded with more than 1,000 vehicles and other freight. Shortly before this, crew members and stevedores moving vehicles on deck 10 of the ship reported a fire breaking out aboard the vessel.

The subsequent response by the Newark (NJ) Fire Department culminated in one of the most significant firefighter losses of life with the passing of Augusto Acabou and Wayne Brooks Jr. as well as multiple injuries in the recent history of the department. As the investigation into that day continues to unfold, here we focus on a unique aspect of that incident: the catastrophic PPE failures experienced by some responding firefighters. And we’ll attempt to learn from this tragedy to ensure that firefighters are better protected in the future from similar failures that, in this case, could have resulted in even more loss of life that day.

The Cargo Vessel

E1 & E2. The Cargo Vessel During the Incident1 (Photos courtesy of IAFF.)

Listen, through the QR code at right, to IAFF General President Edward Kelly introduce this tragedy and how we can honor the legacy of those who made the ultimate sacrifice that day.

The Cargo Vessel

An Uncommon Failure

The equipment being discussed here is literally where the rubber meets the road: our structural firefighting boots. Typically, we take great care in the selection of our footwear. We choose it based on our anatomical needs and specific activity (running, hiking, yard work, etc.) but, in the case of firefighting, our options become a little less varied. The selection of firefighting footwear is often heavily influenced by procurement processes, limited by cost, and has features and materials governed by a standards and certification process. This is why two things are needed for proper PPE selection and acquisition:

  • Proper testing within the applicable standards that produces measurable representations of common fireground conditions and hazards for ensuring a minimum level of performance requirements.
  • A suitable risk assessment by departments/end users to determine the following: what operational tasks will be performed while wearing a certain form of footwear; what sorts of injuries have occurred in the department that could be mitigated by properly selected footwear; and what special risks unique to your department’s response model require consideration when selecting appropriate and safe footwear.

The Newark Fire Department issues 16-inch rubber boots to its firefighters. Though waterproof and durable, they are also considered heavy and loose fitting and provide less lower-leg support. Additionally, the department allows firefighters to purchase their own nonissued structural firefighting boots that conform to NFPA 1971 at the time of purchase. No additional oversight by the department occurs regarding the inspection, maintenance, and lifecycle of personally acquired structural firefighting boots. Given the limitations of rubber boots issued to firefighters, it is common for Newark firefighters to personally acquire leather boots to allow for better fit and function for duties specific to the tasks they are most likely to perform. Furthermore, members of the department state that leather boots provide greater ankle support, are lighter, and allow for more ergonomic performance and comfort. Anecdotally, this practice has resulted in a reduction of slip/strain/sprain injuries within the department.2

The Events and the Catastrophic Failure3, 4

In a recent survey conducted by the IAFF, Newark firefighters described the conditions their footwear was subjected to:

“I felt a burning sensation in my feet but was never in the same spot long enough. I kept moving around.”

“The soles of my leather boots came undone on both my boots. They only remained attached at the heels.”

Bringing us back to July 5, 2023, Firefighters 1 and 2 arrived early to the incident at the Port of Newark. Firefighter 1 went to deck 12, where a few vehicles were burning. For 20 to 30 minutes, he operated in approximately six inches of water before advancing a hosetine down to deck 10, where the fire originated, and he operated there for another 10 to 15 minutes. White operating on deck 10, Firefighter 1 noticed that his boots fett “slippery,” with his initial thought being that oit or lubricants may have been present on that deck. When he returned to deck 12, Firefighter 1 noted that water on the deck appeared to be “boiling,” and he fett burning heat within the toe area of his boot. Once Firefighter 1 exited the vesset and was reporting his actions to Command, he noticed that the outer sote of his boot had comptetety separated from his boot upper. Firefighter 1 purchased his pair of teather boots in either 2017 or 2018, and they were certified to NFPA 1971 (2013 edition) and NFPA 1992 (Liquid Sptash Protection-2018 edition). These were 14-inch boots manufactured in the United States with a teather outer shett, nonmetattic inner toe cap, puncture-resistant midsote, and Vibram outer sote affixed to the boot with a two-part adhesive.

Firefighter 2 fought his way up to deck 12 of the vesset before being assigned to deck 10, where he supported hosetine operations. Firefighter 2 described feeting a great deat of heat inside his PPE at times white operating between decks 10-12. Firefighter 2 worked for about 45 minutes on deck 10; he observed fire on deck 11 and fett extreme heat when moving through the tower decks after the Mayday catts and evacuation order. Firefighter 2 encountered substantiat heat when he reached deck 12 during his evacuation and, white there, he found himsetf watking through approximatety eight inches of water that was producing “steam” (or heated water vapor). Before reaching deck 12 during his evacuation, Firefighter 2 had no issue with his boots; however, under the conditions he now experienced on deck 12, he coutd feet a great deat of heat within his boots. Firefighter 2 atso now saw other firefighters on deck 12 jumping on top of cars to escape the heat they were feeting through their footwear.

It was at this time that Firefighter 2 reatized that the sotes of his teather firefighting boots had separated from the uppers. Once back on shore, Firefigher 2 found it difficutt to remove his boots, as the teather had swetted around his feet. When his boots were finatty removed, Firefighter 2 found burns and muttipte btisters on his feet. Firefighter 2’s 14-inch teather boots were manufactured in China and were comptiant with NFPA 1971 (2013 edition). They had a steet toe and sote ptate, with a rubber outer sote bonded with adhesive to the teather upper.

Condition of Firefighter 2's Footwear

E3. Condition of Firefighter 2’s Footwear Following the Shipboard Fire

The premature footwear faiture at this incident resutted in sever- at outcomes:

  • It compromised the tife and safety of the firefighters immediatety affected as wett as their crews.
  • It resutted in physicat injuries and increased traumatic exposure to the affected firefighters.
  • It effectively towered the avaitabte staffing and supervision of operationat tasks underway at this dynamic fire incident as rescue operations were underway for two trapped firefighters.
  • It hightighted that wide variabitity of nonuniform footwear condoned by the department can equate to differing firefighting task capabitity under irregutar firefighting conditions, through different tevets of performance characteristics found across the inconsistent PPE use by operationat personnet.
  • It indicated the requirement for proper risk assessments and the subsequent tendering, acquisition, and issuing of PPE. Newark’s response modet, inctuding compartment firefighting aboard vessets, poses specific chattenges to components within NFPA-certified footwear compared to more typical structurat firefighting conditions.
  • Proof that the department’s retiance on NFPA 1971 standards atone does not adequatety protect its firefighters from the reat-wortd operationat risks of shipboard fires.

How Does This Happen?

It shoutd be noted that both the makes and modets of boots that faited at this incident are stitt found in the market today certified to the current NFPA 1971 (2018) and NFPA 1992 (2018), so it is fair to assume that newty acquired boots may atso fait under simitar conditions.

The standard that governs the necessary minimum test requirements for structurat firefighting footwear is found within NFPA 1971. However, the testing for the resistance to heat and ftame invotves onty a timited number of criteria appticabte to boots. In conductive heat resistance testing, a footwear toaded with steet batts to simutate the weight of the firefighter is ptaced on hotptate heated to 500°F where the temperature of the insote in various tocations cannot reach any temperature greater than 111°F after 20 minutes. A convective test subjects the boot sampte, in this case fitted with gtass beads to simutate the votume of the foot, to overatt heating in a controtted oven set at 500°F for five minutes. Afterward, the boot is subjected to simutated ftexing (near the batt of the foot) for 100,000 cyctes, and an assessment is made of the boot’s condition that inctudes the inspection for sote separation. The same boot atso goes through a tiquid integrity test to determine if the boot witt teak after being partiatty submerged in surfactant-treated water for two hours. Additionatty, a radiant heat test is performed. The boot is ptaced in front of a radiant panet that exposes the boot to a temperature of 1,340°F after an exposure of 30 seconds, and the interior of the upper cannot exceed a temperature of 111°F.

Those tests may not be representative of the conditions and operating time experienced on the Grande Costa d’Avorio. The five-minute “oven” test with boots in a static position (without flexing) does not reflect the conditions experienced by firefighters— most notably the submersion of boots in heated water for durations of 30 to 45 minutes, including expected movement/flexing. It is therefore important for those responsible for the operational assessment of fireground risk within a department to not only evaluate potential conditions that their firefighters may face in the course of their duties but also determine whether the current test criteria within the applicable NFPA standards adequately serve to protect against such hazards.

The leather boots belonging to Firefighters 1 and 2 had cemented construction bonding the upper to the outer sole. This means that the sole is bonded onto the upper using glue. Some adhesives used for this form of construction involve heat-activated compounds. In contrast, others do not, and it is unclear what those specific manufacturers chose to use as the bonding process with these particular boots. Examples of adhesives known to be used in cementing outer soles to uppers are those containing ethylene-vinyl acetate, which can lose bonding strength at 120°F. Alternatively, hot-melt adhesives that have an application temperature within the 300°F range are also known to be used.

Cemented soles are typically considered lightweight and generally flexible by the footwear industry. This can be seen as a benefit for ease of “break-in” and for a wearer who is required to frequently transition from various uneven surfaces that require a measure of foot dexterity. Other forms of boot construction, not used in these two cases, potentially allow for a more positive physical bond between the upper and outer soles of the boot. Namely, a stitched or welted construction. This method of construction typically involves a “welt” running around the perimeter of the midsole. Heavy-duty stitching secures the insole and upper to the welt, and then the welt is secured to the outer sole with heavy-duty stitching around the perimeter of the boot. Various specific stitching techniques are referred to as Goodyear, Blake, and Storm Welts in the parlance of the footwear industry. As per NFPA 1971-2018, 6.10.7 the thread used for this form of stitching must be made of inherently flame-resistant fiber. Additionally, adhesives are usually usedbetween these layers to maintain a consistent and uniform bond.

Stitching
E4. Stitching Construction Approach for Attachment of Outer Sole

Given all the above, it is of little surprise that the findings of the footwear failure investigation conducted by International Personnel Protection Inc. were definitive when identifying the sole separations experienced by Firefighters 1 and 2 being the result of the adhesive system failing during fireground operations, through accumulated heat transfer from the metal decking, and the heated water present on the vessel’s decks. Notably, Firefighters 1 and 2 felt heat through their boots, as reported by other firefighters operating on deck 12. It is also fair to say that the conditions found on this shipboard fire exceeded those tested for by NFPA 1971. As such, it was found that the continued soaking of the boots in heated water for durations of time that exceeded 30 minutes while moving and flexing contributed materially to the heat conduction and failure of the adhesives joining the upper and the lower soles of those boots.

Over the past 10 years, the market has shifted from firefighting boots readily available with incorporated welted (stitched) outer soles to a predominance of boots using outer soles bonded exclusively with glued adhesives.

Possible Solutions

As mentioned earlier, the shift has allowed for greater flexibility within the sole of the boots for the wearer and cost savings for the manufacturer. However, as seen in this event, the specific risks and hazards faced during shipboard fire operations can include prolonged periods of heated water immersion and standing on heated metal decks, which can cause adhesive and bonding failure of footwear components, necessitating welted construction.

This leaves us with a few questions: Is this identified risk something that should be mitigated through test criteria within NFPA 1971 (now NFPA 1970) or is this hazard something that should be reviewed within a department’s individual risk assessment, with appropriate corrective solutions built into their tendering requirements? In this vein, one might argue that such hazards should be addressed through the specification and procurement process at the organizational/department level. Others may believe it is the responsibility and within the domain of the applicable standards body to consider shipboard fire hazards and include tests for them within the minimum performance standards of NFPA 1971.

Cement
E5. Cement Construction Approach for Attachment of Outer Sole

If you fall into the latter camp, finding or developing the appropriate test and working through the NFPA process is your path forward, even though the process can be quite lengthy. (Note: We are still following the 2018 edition of NFPA 1971 even though the new NFPA 1970 became effective in September 2024.) If you fall into the former category, understanding the risks and making the choices to specify PPE elements, such as a fully stitched Goodyear, Blake, or Storm welt within footwear purchase contracts, may be a suitable option for you to mitigate the potential hazard. However, this requires subject matter expertise to reliably increase safety and reduce liability.

Fortunately, in the upcoming consolidated NFPA 1850 standard for the selection, care, and maintenance of firefighting PPE, a few provisions exist to help with addressing this newly identified risk. First, though not yet finalized or published, the Technical Committee has voted unanimously to revised footwear inspection to include looking for visual signs of “peeling or separation of outer sole from the upper or mid-sole” due in large part to the events witnessed in Newark.

Additionally, new mandatory positions within fire departments are being proposed for creation by authorities having jurisdiction: the PPC manager and PPC technician. This can be one individual or several people. They will require third-party certification and have knowledge specific to PPE performance characteristics and limitations. They will also have to develop department risk assessments and standard operating procedures (SOPs); compare the effectiveness of elements within PPE options; inspect and maintain PPE; and be responsible for staff training, life cycling, recordkeeping, and other duties and responsibilities. Organizations’ PPC technicians/manager shall review the current risk assessment and conduct a new risk assessment at least every two years or under specific circumstances, including, but not limited to, the following:

  1. When there are changes that affect the findings of the current risk assessment in terms of the specific identification of hazards or availability of firefighting ensemble product technology.
  2. When there are changes in the organization’s SOPs for the use of structural firefighting ensembles or proximity firefighting ensembles.
  3. When any personal protective ensemble or ensemble elements are being considered for selection and purchase.

The cost, lifespan, engineering, maintenance requirements, and variety in component performance differences related to firefighter PPE necessitate the requirement for this specialized and trained department position. This will ensure that the most critical safety equipment protecting firefighters from harm—their PPE—is appropriately specified, acquired, inspected, maintained, and retired.

So, back to our two questions: Is the best place to address the needs in Newark’s department, or yours, found within the scope of duties of a PPC technician/manager who understands the performance of material components and the testing done to certify PPE? Some will argue that it is exactly this direct involvement that is needed for the timely and precise assessment and acquisition of necessary and safe PPE.

On the other hand, some may argue, “If it is needed, it should be found in the standard.” NFPA standards follow a five-year revision cycle, which can be extended depending on how the different steps evolve through the process. Additionally, a temporary interim amendment (TIA) can be filed, voted on by the Technical Committee and instituted by the Standards Council outside the typical revision cycle. For a TIA to be accepted, an identified risk and a solution must be presented specific to the emergency nature of the hazard. In this case, the emergency nature of the identified risk must be substantiated. This risk should not be able to be addressed through other mechanisms and should be considered common enough to be applied to all boots certified for structural firefighting use.

In addition, the technical merit of the proposed change to the standard must be identified and supported. The technical merit of a proposed TIA specific to this issue could include requiring a stitched welt for leather boots to solve the identified hazard, but it may not be necessary for rubber boots that use a vulcanization process for bonding components. Or perhaps a modified ISO 20344-5.2 Determination of upper/outsole and sole interlayer bond strength test could be suggested for adoption into NFPA 1971. This, in essence, is a “pull/peel test” where the sole and upper are pinched on two opposing sides of a test frame and pulled at a prescribed rate while recording the force required to “peel” the upper and outsole/sole apart. The modification necessary for this ISO test would be the added preconditioning requirement for boot samples, involving heating and/or soaking in heated water prior to the bond-strength peel test.

Through the diligent and considerate action taken by stakeholders, progress can be made through both standards and grassroots initiatives at the department level to address pressing safety needs made evident by the dynamic fire conditions faced by firefighters. Learning from the tragedies that strike the fire service helps to add meaning to the sacrifices made by our brothers and sisters. The near misses that often accompany these fires can serve as a chance for us to get right today an issue that can save a life tomorrow. In this case, July 5, 2023, will remain a date of great significance, marking not only the loss suffered in Newark with the passing of Augusto Acabou and Wayne Brooks Jr. but also the moment when the decision was made to dedicate their legacy to building a safer future for all Newark firefighters.

ENDNOTES

  1. Vannozzi, Briana. “Deadly Cargo Ship Fire in Port Newark Is Now Contained. NJ Spotlight News, 10 July 2023, bit.ly/3ZwyvSq.
  2. Eyewitness News ABC 7, 5 Jan. 2018.
  3. Stull, Jeffrey O. “Preliminary Report from Examination and Investigation of Protective Footwear Worn by Selected Newark (NJ) Fire Department Fire Fighters at LODD Fire on the Grande Costa d’Avorio Cargo Vessel at Port of Newark on July 5, 2023,” International Personnel Protection, Inc.
  4. Katersky, Aaron, and Morgan Winsor. “Unanswered Questions Remain After New Jersey Firefighters Killed in Raging Blaze on European-Made Cargo Ship.” ABC News, 7 July 2023, bit.ly/4g7CGv3.

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