For seven years, Texas fire departments have been required to comply with NFPA 1851, Selection, Care and Maintenance of Protective Ensembles for Structural Firefighting and Proximity Firefighting. On June 24, the 2008 edition went into effect, bringing with it more rigorous testing requirements and for many departments, more cost.

The first edition of NFPA 1851 was released in 2001. It covers eight sections: records, protecting personnel from contamination, selection, inspection, cleaning and decontamination, repair, storage and retirement, disposition and special incident procedures. A state bill adopted the initial regulations of NFPA 1851 in 2001. Since then, the Texas Commission on Fire Protection has conducted routine inspections of fire departments to ensure compliance.

The commission has six officers throughout the state inspecting departments every two years. Inspectors ensure the departments have standard operating procedures in place to keep gear in good working condition and check records for any outside testing and repairs that need to be done. Departments themselves are primarily responsible for routinely inspecting their personal protective equipment, making repairs, and retiring worn or out-of-date turnout gear.

The 2008 edition of NFPA 1851, however, requires more rigorous tests that cannot be done in-house without training from the manufacturer, and according to Texas Fire Commission Compliance Program Manager Miles Skipper, this could cause headaches for fire departments across the state.

The new tests are:

Light test

A light is held inside the clothing to show either places in the thermal barrier where the material bunches up or is thinned. The light is sized to fit in the sleeve of a coat, should not touch the liner and should not produce heat damage to the liner. The test is performed annually.

Puddle test

The liner is placed over a 5-gallon bucket, with specific, high-wear areas to be tested. An alcohol/water mixture is poured over the liner to indicate degree of wear. This is performed in years one and two. This was recommended in the previous edition of NFPA 1851, but not required.

Pressure test

This is a water-penetration barrier evaluation requiring special equipment to test specific areas of the garment. It is performed at year three and every year after. Skinner says that this test has been problematic for some departments. “We're getting reports of a lot of protective clothing failing the pressure test,” he says, “even new stuff. That's a manufacturing problem.”

Another problem facing departments is the 2008 edition's mandatory 10-year retirement rule for structure gear. “That caused quite a stir,” says Skinner. “A lot of departments have reserve gear in case of emergency, if a firefighter's gear was torn or needed to be repaired. In the meantime, they would bring out this old gear, some of which was over 10 years old. By the commission adopting NFPA 1851 in total, that required those departments to get rid of it.”

NFPA 1851 also mandates that the outer shell of aircraft firefighter gear must be retired after five years, the liner after 10. Retired structure gear still can be used for non-live-fire training.

This likely will affect a department's bottom line when it comes to rotating PPE, in keeping the clothing up to NFPA 1851's rigorous expectations. According to the commission, the average cost for a verified independent service provider to re-stitch seams is 50 cents per inch — that may or may not be included in the cost for cleaning and inspection, which is approximately $30 to $35 per piece. The commission suggests that specifying that the thermal and vapor barriers attach to each other in way that would allow inspection without removing stitches could help keep costs down.

It is important to consider the cost of purchasing and installing proper cleaning equipment against that of contracting out those services or repairing and replacing gear if improper equipment is used. The initial costs might be high, but departments doing proper in-house cleaning and inspection will save money overall. For small departments with smaller budgets, the commission recommends sharing the costs with several nearby small departments and keeping the equipment in a central location.

Skinner says that the commission is granting fire departments extra time to work any necessary changes into their budgets.

“Some departments already have five- to seven-year rotation plans, so it will be a lesser impact on them,” he says. “But there will be budget increases. Any time you talk about safety issues, it's tempered with what you can afford. Most people don't drive the safest car on the road; they drive what they can afford with the minimum safety features built in. As you can afford it, you move up and drive a safer car. The same is true with protective clothing. We mandate fire departments do at least the minimum in Texas to meet safety standards.”

One Texas fire department meeting more than the minimum safety standard is the McKinney Fire Department. Neil Howard, division chief of administration, has been working to keep PPE in his department at high safety levels for the last eight to 10 years. McKinney is a moderately affluent suburb of Dallas.

“Around that time, there were a lot of news reports about firefighters getting burned and there was a big push to better maintain gear and protect firefighters,” he says. “We took that as a warning to stay ahead of the curve.”

Howard agrees with Skinner: a department has to start small. “You have to see what kind of cost is involved in doing your maintenance,” Howard says. “If you have a lot of old gear, it will be more cost-effective to replace your gear than to have it tested and repaired. If you have a small department with, say, 60 members, 20 sets of gear is going to be hard to start off with financially. You might have to start out with five or 10 and build yourself up. You might do five every year on a five-year replacement. Five sets of gear will run you $5,000 to $6,000, and even a small department should be able to budget that to put toward gear. It might take five years to get to everyone in the department, but it still keeps them in compliance and it's a small piece of the pie. Take it in small steps. It's like life; we don't always get to live in the big house or drive the fancy cars when we're young, you have to wait till later in life to afford them. You have to crawl before you walk.”

Because maintenance and inspection of gear has been a high priority for the McKinney Fire Department, the revisions to NFPA 1851 haven't affected the department too drastically. While it will need to perform the three new mandatory tests, it currently is on a three-year gear rotation plan, which has been a four-year process to complete. “This is the first year where a third of the department will have two sets of gear,” Howard says. “The second set is less than six years old. When we replace gear at the three-year mark, the old gear goes into reserve.”

Howard credits then-president of Safety Solutions Jim Evans with helping the department beef up its inspection and maintenance procedures. Two and half years ago, Evans instigated a lot of the changes that are in practice today. “We learned a lot about cleaning properly,” Howard says, “like not hot-air drying the material and trying to keep gear out of the sun.” Five of the department's seven stations have extractors and RAM air dryers. Two of the stations have enclosed storage rooms to keep bunker gear out of direct ultraviolet light.

McKinney also has a single employee who inspects and cleans all bunker gear. He reports back to Howard on whose gear needs to be retired and how many sets need to be ordered each year. “You have to have somebody assigned,” Howard says. It has to be a project that someone will take on and treat as theirs.”

McKinney's policy requires captains to inspect gear every month, contacting the bunker gear inspector if any problems are detected. The gear inspector will check it over, clean it in-house if possible, and send it out to Safety Solutions for repairs if significant damage is reported.

As will most departments, budgets still are a primary issue for McKinney. “We've had limited budgets over the years,” Howard says, “but we started out small, and as the department grows, we add new sets of gear.”

Everybody In Vests

To reduce pedestrian traffic fatalities, the Federal Highway Administration recently enacted new rules that require all responders use high-visibility safety apparel when within the rights-of-way of a federal-aid highway. The rule will take effect Nov. 24. A new study concludes that NFPA 1971 turnout gear is as effective at creating conspicuity as the rules' specified garments.

The new rule explicitly references ANSI/ISEA 107-2004 in determining whether a garment satisfies the new FHWA requirement for high-visibility safety. The design of standard firefighter turnout gear, however, is not consistent with ANSI/ISEA 107-2004, although it is compatible with the heat and flame standards. As such, firefighters responding to highway scenes will need to wear safety vests.

A study was conducted on a closed track in both daytime and nighttime conditions to compare the conspicuity of three different types of safety garment for use by first responders — NPFA 1971 turnout gear coats and ANSI/ISEA 107 and 207 safety vests. Eight participants, balanced for gender and age, drove instrumented vehicles on the track, indicating the distance at which they could detect pedestrians in a simulated emergency response scene. Pedestrians, wearing one of the safety garments, stood adjacent to the emergency scene.

These tests were conducted by the researchers at University of Michigan Transportation Research Institute, who published the findings in “The Conspicuity of First-Responder Safety Garments.” The objective of the study was to compare garments that are consistent with the recent FHWA rule (ANSI/ISEA 107-2004 compliant) with those compliant with the future 2009 MUTCD regulation (ANSI/ISEA 207-2006 compliant), and those intended to serve firefighters (NFPA 1971-2007 compliant) to determine if one garment makes pedestrians more conspicuous.

Four garments were tested for daytime and nighttime conspicuity: two ANSI/ISEA-compliant vests and two firefighter jackets. All garments were new. One was an ANSI/ISEA 107-2004-compliant Class 2 vest having one horizontal band of 50-mm retroreflective trim around the torso and two vertical bands over the shoulders. A second vest, an ANSI/ISEA 207-2006-compliant garment, had combination trim around the torso and two vertical bands of combination trim over the shoulders. Both vests had fluorescent yellow-green background material with silver retroreflective trim. The firefighter turnout gear was compliant with NFPA 1971 and used the standard New York Fire Department pattern of combination trim with two horizontal bands around the torso and two bands on each arm. The jacket was tested with two different background colors (black and gold), but both had identical yellow-green and silver combination trim.

The results show that there was no statistically significant difference in the distance at which the pedestrians were detected, regardless of which garment was worn; all three standards of garment provided levels of conspicuity under the conditions examined. Time of day was a significant factor, with mean detection distances being longer during the daytime for all garments. The results suggest that all of the garments studied should be considered equivalent relative to making first responders conspicuous when working in close proximity to traffic.