Accessibility to the NFPA standards process
Overcoming complexities and learning how firefighters can impact PPE requirements
Most in the fire service recognize that the NFPA impacts their work in several ways, whether it be in professional qualifications, equipment specifications, general health and safety requirements or training. And, naturally, many of our columns reference standards on fire service PPE developed by the NFPA. While there is a general understanding among firefighters that there are various committees that put the standards together, not everyone understands the full scope of the process and what individuals can do to make a difference.
How NFPA creates standards
Every consensus standards development organization has procedures that it must follow to create a standard in a balanced, open and consistent manner. The rules applied for these processes have been set by the American National Standards Institute (ANSI), which is the overarching body for how standards are developed in the United States. These rules address how participation in the development process must be balanced within the respective committees and how opportunities should be provided to allow for input from individuals outside the committee.
Technical committees: NFPA relies on technical committees that often have 30-plus members, but the essential aspect of committee structure is that no one interest category can have more than one-third of the voting membership. Interest categories are divided among categories that include users, consumers, enforcement authorities, labor, manufacturers, research and testing laboratories, and installers/maintainers. For PPE committees, fabricators and material/component suppliers are considered manufacturers. The balance created by this committee structure is to ensure that no one interest dominates the standards development process, particularly in voting on creating new or revising old standards.
Standards structure: The process to create or revise standards starts with a draft of the standard that is typically created by the committee. The structure of the standard is governed by various format and style issues that have been adopted by the NFPA. NFPA PPE product standards that are directed toward manufacturers include an administrative chapter that provides the scope and purpose of the standard, which is followed by chapters on referenced documents and definitions. Unique to the NFPA standards on PPE is a chapter for product certification that describes how products are mandatorily and independently evaluated for their compliance with the standard. The next several chapters address various requirements in terms of product labeling and user information, design criteria, performance criteria, and test methods. There is also an extensive annex that includes non-mandatory information about various parts of the standard to provide clarifications and suggested interpretations of requirements applied in the main body of the standard.
Standards related to the selection, care and maintenance of PPE have a different structure. Those standards are directed to fire departments and other end-users. These standards also have the same chapters for administrative information, referenced documents, and definitions, but then deviate to establish chapters on organization program requirements as well as the key PPE topics of appropriate selection, inspection, cleaning and decontamination, repairs, storage, and special provisions such as PPE retirement, long-term disposition, and handling during special incidents.
Comment period: Up until the development of a new draft standard, the process mainly takes place within the committee. However, there are then two stages for outside involvement called public input and public comment.
- Public input: In the case of public input, the new draft of the standard or the existing edition is put out for any individual to make recommendations for changes to any part of the standard that can include new, revised or deleted requirements. NFPA provides a process on its website by which public inputs can be submitted. After the period for public input closes, the committee reviews each input and decides whether to go forward with the change or not. The collection of actions taken on public input, as well as any other changes that the committee desires, is voted upon and becomes the first draft.
- Public comment: The draft is then subjected to public comment as a second stage allowing modification of the standard. In general, public comments must relate back to earlier changes during the public input or first revisions to the original draft or edition of the standard being revised. Again, all public comments are reviewed with actions taken to accept, modify or reject proposed modifications. The result of the public comment stage is the second draft.
Upon the completion of the second draft, the NFPA makes the standard available for further review and allows final opportunities for the public to challenge changes that were made in the creation of the second draft. This stage is referred to as the “Notice to Make a Motion at the Annual Meeting” or NITMAM. At this stage, the only option is to allow the reversal of specific actions that created changes in the proposed next edition of the standard. Though the committee responsible for the standard gets to vote as to whether they agree to these reversals of prior actions, a large part of this last stage takes place at the NFPA Annual Meeting where individuals have their proposed motions presented, and individuals present at the meeting can speak for or against their motions before the overall NFPA members. Based on the outcome of voting from potentially hundreds of individuals in attendance, specific actions affecting the standard are made.
In one last step before ratification of a new standard, the entire record for the development or revision process is reviewed by a group called the NFPA Standards Council. This group decides if the procedures have been properly followed and provides an opportunity for formal hearings on any actions in which appeals can be heard.
The importance of fire service participation
The NFPA standards development process described above can be daunting and difficult to comprehend given the multiple stages and nuances in the procedures. We recognize that some firefighters can be intimidated by the process even when they have strong concerns and a desire to impact standards to affect their health and safety. For example, it takes a certain amount of knowledge to be able to navigate the NFPA website despite attempts for its continued simplification. This is partly because standards have become increasingly complex, and making changes requires an understanding for how requirements are written, and more importantly, how they can be changed.
As part of this exacting revision process, NFPA requires that most public input or comments indicates specific changes to the actual language within individual sections, paragraphs or sentences of the standard. Often, isolating the specific narrative within the standard can be difficult, and many times, there are related sections that should also be modified in order for the change to be properly implemented.
A separate requirement and easier way to submit a public input or comment is to have the submitter provide justification for what they want changed. Submitters also have an option of submitting a “global” change to the standard, which is way of asking for a general, sometimes conceptual, modification to the standard that does not require showing specific changes to existing language. Fortunately, many committee members are willing to help those in the fire service articulate their specific concerns and assist in the preparation of both public input and public comments. Sometimes, NFPA staff can also provide guidance for individuals in submitting public input and comments.
Despite the balance provided in the NFPA membership process, standards can only become better for the fire service when broad input and comment from outside the committee is received. Consequently, we urge firefighters and other emergency responders to seek out individuals on the committee to voice their opinions as to whether they believe standards are creating the products and practices that they believe are in their best interests for overall firefighter health and safety.
We are providing this refresher on the NFPA process because there are ongoing events that affect the most frequently referenced standard in our prior columns. The NFPA 1971 standard on structural firefighting protective clothing and equipment is nearing the final stages of its approval process. That standard, which is been consolidated with similar standards for station/work uniforms, SCBA and PASS, has completed the second draft stage with the handling of public comments early this year. The standard is now open for NITMAM where individuals can indicate their disagreement with the actions taken in putting forward the second draft. The second draft will become the final draft that is published unless there are actions through NITMAM or as the result of hearings at an upcoming Standards Council meeting.
The original closing date for NITMAM was Nov. 1, 2023, for the current edition, which has already passed. However, the deadline was extended through Dec. 4, 2023, to account for a discrepancy in NFPA’s announcement of the closing date for NITMAM through ANSI.
The NFPA 1970 includes a large number of controversial and highly debated changes, which we covered in the webinar “Gear up for PPE changes: What’s ahead for NFPA 1971.” That includes such topics as the requirement to transition exclusively particulate-blocking hoods, the addition of an alternative approach to glove-sizing, the incorporation of restricted substance criteria for turnout clothing materials, and the ability for manufacturers to make “PFAS-free” claims.
For any firefighter who wishes to be heard, this is the last part of a relatively extensive development process to make their voice heard.
To learn more, please register for the upcoming webinar “How changes in the new NFPA standards for turnout gear and SCBA will affect the fire service” on Nov. 15, 2023.
Note: The views of the author do not necessarily reflect those of the sponsor.