THE NFPA STANDARD-MAKING PROCESS: HOW TO BE HEARD
A new standard affecting the fireservice is published. You read it and think, I wish it covered this or that point. Are they kidding? How can my department achieve this? Rather than sitting idly by and criticizing the standard that reflects the input of others, why not become involved in the standard-making process yourself? Just as in the case of firefighting, activities before (prevention) are preferable to reaction later (suppression).
You have several options for participating in the NFPA standard-making process. You can become a working member of a technical committee or submit comments and proposals during specified time periods.
TECHNICAL COMMITTEE
A technical committee handles public proposals, develops drafts of the standards, and answers public comments. As a committee member, you must have the time to attend meetings as well as to research, write, review, and comment on draft documents.
Membership on the committees is voluntary; there is no payment for time or expenses. Committee members must pay or obtain financial support for travel, housing, and other costs related to attending meetings. Associations or organizations will help to finance these expenses in some cases.
To apply for membership on a committee, send a formal request to the NFFA Standards Council. After reviewing your application, technical qualifications, and other requirements and conditions for participation, the council will assign you to one of nine committees best suited to your background: applied research/ testing laboratory, consumer, enforcer, installer/maintainer, insurance, labor, manufacturer, special expert, and user.
Committee membership is balanced so that no more than one-third of the members come from a specificcategory or represent a specific interest group. You will not be appointed to the committee suited to your expertise if your appointment offsets the committee’s balance. In this case, your application will be held, pending changes that would create an opening on the committee. Committee size is limited to keep the groups manageable. The Standards Council makes appointments quarterly.
COMMENT PERIOD
Even if you cannot serve on a committee, you can participate in the standard-making process. You have two opportunities to submit ideas, concepts, and requirements.
It takes about 100 weeks or two years for a proposed standard to complete the preparation/revision cycle. Once the process is underway, publicproposals are requested. During this specified time frame, you can submit proposals, suggestions, and regulatory language to the NFFA. The information should be submitted on the proper form, which may be obtained from the back of any NFFA stand-alone document, subscription service binder, or directory; you also can contact the NFPA directly for a form.
The document drafted by the technical committee is based on the input received during the public proposal period and the results of the committee members’ research and work. Every public proposal received must be addressed and acted on by the committee. The proposals may be accepted, rejected, accepted in part, accepted in principle, or accepted in principie in part by the committee. The committee works to achieve a consensus on the items included in the standard. When a consensus cannot be reached, a vote is taken.
After the technical committee has acted on the public proposals and approved the language of the standard, a draft is printed in the NFPA Technical Committee Report (TCR), which is printed semiannually. The TCR automatically is sent to everyone who has made a public proposal and to subscribers to the standards. Its availability is announced in the NFPA Eire News, the TCR can be obtained without charge from the NFPA’s Customer Service Department.
Anyone can—and fire service personnel should—read the committee’s draft. An approximate 60-day period for public comments on the draft begins at around the time the TCR becomes available. During this interval, you can propose changes in the requirements or the wording of the standard. Your involvement during this stage will help ensure that proper, realistic standards are developed. All comments submitted must be on the proper NFPA form or they will be discarded by the committee. The form is printed in the front of the TCR, which also describes the procedures for completing the form.
The technical committee then reviews and considers every comment submitted. Those not accepted as presented must be answered by the committee; they must be acted on in the same manner as the public proposals. This can take considerable discussion and time.
All technical committee meetings are open, and an individual who has made a proposal or comment can request to address the committee on the specific proposal or comment. Guests can attend committee meetings and comment on relevant subjects; they must notify the chairman of their intention to attend at least 10 days prior to the meeting.
The committee’s response to the submitted comments is published in the TCR prior to the next approaching (annual or fall) NFPA meeting. Individuals whose public comments are rejected still have an opportunity to be heard. They can bring their already proposed but committee-denied suggestion before the general membership for consideration at the NFPA meeting.
Members present at the meeting vote on the recommended changes to the standard. If a comment is again denied, its author can appeal to the Standards Council at its subsequent meeting, where the council approves new and revised standards for publication.
Members of the fire service have multiple opportunities for directly affecting the standard-making process. Taking advantage of them will result in standards that will make it easier for us to protect ourselves and our communities.