REFLECTING ON FIRE P.P.E.
(Recent Update: National Fire Protection Association staff members have advised Industrial Fire World magazine and the Industrial Fire Emergency Response Group that NFPA intends to issue a temporary interim amendment to NFPA standard No. 1500 giving incident commanders the authority to determine what PPE is appropriate for a specific emergency. This is in response to a 1998 OSHA opinion interpreting NFPA standards as requiring a greatly expanded use of proximity PPE in municipal and industrial firefighting. This issue has been closely followed by Industrial Fire World. Check "FURTHER REFLECTION" below for more details on NFPA No. 1500.)
What color is your bunker gear? If it is structural PPE, you have a wide range of colors from which to choose, although yellow seems to be traditional. If it is proximity PPE, you only get one choice -- reflective silver. The color that your fire brigade or emergency response team should be wearing depends on how you interpret the current National Fire Protection Association standards on protective clothing.
Aluminum-coated reflective PPE (personal protective equipment), commonly known as "silvers," was standard industrial fire fighting apparel as recently as the 1970s. Today, while such proximity fire fighting gear is often still on hand, most industrial fire brigades operate using non-reflective PPE approved for structural fire fighting. Phasing out silvers back in the 1970s was mainly due to changes in government regulations at that time.
The regulatory pendulum is now swinging back toward reflective proximity gear. In January 1998, the Occupational Safety and Health Administration issued an opinion stating that a widely overlooked NFPA standard passed in 1992 required expanded use of proximity PPE.
"Based on the definition of proximity fire fighting, we believe firefighters in refineries and petrochemical plants should wear protective clothing as specified by NFPA (standard) 1976 when fighting fires involving flammable liquids or gases in bulk," states the letter issued by OSHA's directorate of compliance.
NFPA No. 1976 sets the technical specifications for reflective protective clothing used in proximity fire fighting. It defines proximity fire fighting to include "aircraft fires, bulk flammable gas fires, and bulk flammable liquid fires." The OSHA opinion seized on this definition, stating that under the Occupational Safety and Health Act's General Duty Clause, 29 U.S.C. ?654(a), employers are under legal obligation to provide the correct gear for proximity fire fighting.
That gear is reflective PPE, the opinion mandates.
That interpretation is challenged by a growing number of industrial fire chiefs who insist that proximity PPE is outdated given advances in fire fighting techniques and technologies in the past two decades. Returning to reflective gear would be prohibitively expensive with doubtful improvement in protection. Chiefs also raise issues about the gear's durability.
"I personally feel that you don't gain that much protection with aluminum gear over what (standard structural fire fighting bunker gear) provides," said one prominent chief interviewed by Industrial Fire World. "The quality of the (structural gear) being produced today is far superior to anything we've had in the past. The fact that the aluminum gear gives you radiant heat qualities is not really an issue for us."
In the last year, several important industrial coalitions have joined forces to push for revision of No. 1976 and other NFPA standards. The revision process was already scheduled when the controversy arose. However, until NFPA takes some formal action, it is unlikely that OSHA will reconsider its position, said Alcmene Haloftis of OSHA's directorate of compliance.
"If NFPA revises their standard, I'm sure we will look into it too, but as of this time, the interpretation has not changed," Haloftis said.
The battle to keep structural PPE may be won or lost in the next few months during the NFPA revision process. It is a process that industry has not been well involved in during year's past.
"Industry hasn't really had representation on the drafting of these standards because (those standards) haven't really affected industry in the past," the fire chief quoted above said. "All of a sudden we are being swept up into these things because someone says 'Hey, why don't we bring industry into this?' "
About 25 years ago, industrial fire brigades had the shiniest attire this side of the disco dance floor. Reflective fire gear was common apparel in the era before monster fire trucks, 2,000 gallon-per-minute volume nozzles and fixed deluge systems.
Then, like disco, reflective PPE began to fade from the scene in the late 1970s. In 1978, OSHA mandated that all industrial firefighters wear structural PPE that met NFPA No. 1971, governing the technical specifications for structural fire protective clothing. That gear utilizes fire-resistant man-made fibers such as Hoechst Celanese's PBI or DuPont's NOMEX. No reflective outer coating was required.
Furthering reflective gear's demise, NFPA No. 600 governing the operation of industrial fire brigades, also required the use of NFPA No. 1971 compliant structural PPE.
"This was not done without some thought or reason," said industry consultant David White, publisher of IFW. "The reason was (structural PPE) provided better protection than the aluminized garment existing prior to the NFPA No. 1971 standard. Basically, there had been no standard for protective clothing before 1975 (when No. 1971 passed)."
With reference to protective clothing, OSHA 1910.156, subpart L, section (e), part (ii) deals with body protection. It states that the "performance, construction, and testing of fire-resistive coats and protective trousers shall be at least equivalent to the requirements of standard NFPA No. 1971-1975, 'Protective Clothing for Structural Fire Fighting.' "
Despite the difficult maintenance problems associated with reflective gear, industry firefighters were reluctant to surrender it. It had an excellent safety record for the kind of up close and personal fire fighting common before big volume water systems gained a foothold in the 1980s. However, other than a few sets kept around for worst-case situations, reflective gear at American plants was pushed into the history books.
Other than the 1978 OSHA ruling, NFPA standards rarely affected industrial fire fighting on such a grand scale. Therefore, most industrial fire chiefs were oblivious that, in May 1992, NFPA passed a new standard for protective gear. That new standard, designated No. 1976, would hit close to home.
NFPA No. 1976 differentiates between gear used in structural fires and the type of fires more common to industry. No. 1976 states that its purpose is to "provide minimum performance requirements for proximity protective clothing worn by firefighters primarily responsible for aircraft rescue and fire fighting, bulk flammable liquids fire fighting, bulk flammable gas fire fighting, and singular situations releasing high levels of radiant heat."
The new standard basically borrowed the requirements and tests specified for protective clothing used under No. 1971 for withstanding convective and conductive heat. However, it goes beyond No. 1971 in setting requirements for limited exposure to high radiant (infrared) heat. To meet that standard, No. 1976 requires one important addition -- a reflective outer coating.
An NFPA subcommittee worked five years on developing this new standard, further emphasizing how far removed industrial firefighters were from the standard-making process. One source on the original No. 1976 technical committee said that input from industry was difficult to obtain. Most of the user input to No. 1976 came from the military whose risk exposure was in aircraft crash and rescue.
Other than PPE manufacturers providing more detailed warning labels in their garments, No. 1976 had little immediate impact. Strangely enough, it was the military that first raised questions about whether the new standard applied to their operations. At the request of military officials, OSHA issued at least three compliance memorandums during 1997 on No. 1976.
In a July 1997 memorandum, director of Federal Agency Programs John E. Plummer stated that if a firefighter's primary job is aircraft crash and rescue, then that firefighter must have the appropriate protective clothing.
"In the case ... cited, that of San Diego's combined fire department, where a firefighter can be tasked to do any type of fire fighting at any time (usually on a rotational basis), then all 300 firefighters are going to have to be equipped to fight any type of fire," the memo states. However, with reference to another fire department where "aircraft crash and rescue is less than five percent of the tasking, then proximity fire fighting is 'incidental' and not the primary job."
Making a final determination is left to the OSHA compliance officer on-site, the memo states.
In August 1997, the Navy's Fire and Emergency Services requested that OSHA elaborate further on the proximity clothing issue. A variety of scenarios listed by the Navy includes structural fire fighting personnel participating in bulk petroleum fire fighting operations wearing protective clothing approved under NFPA No. 1971, not No. 1976.
Again, Plummer's response takes a strict interpretation of No. 1976 based on the type of fires it identifies as producing radiant heat. The scenario would be OSHA-citable as it does not meet the requirements of NFPA 1976 where the hazard is radiant heat, Plummer's memo states.
Despite the pro-reflective input during the drafting of No. 1976, a leading company in the field of laundering fire gear reports that proximity gear is hardly the hands-down favorite of military firefighters.
"We do a lot of cleaning for military bases and about half are using structural gear," said John Schenck, president of Southern Laboratories. "They refuse to wear the aluminized gear for everything. They will have one or two sets for rescue operations."
Finally, in Sept. 1997, IFW publisher David White asked OSHA for a definitive opinion on how No. 1976 affects industrial fire fighting. The question of liability if an industrial firefighter were injured wearing nonregulation gear was the principal concern. The OSHA opinion, although issued by another department, proved consistent with the previous memos by Plummer.
Questioning why OSHA's interpretation is based on No. 1976 seems to be one of the few points of common ground between NFPA officials and the industrial fire chiefs. In particular, the technical committee supervising the No. 1976's routine revision process has caught much of the resulting heat. Industry representatives attended several of the No. 1976 committee meetings in the past year, said Bruce Teele, an NFPA senior fire service specialist serving as staff liaison to the committee.
"Their biggest concern seemed to be that No. 1976, based on this OSHA ruling that came down, required them to wear (reflective) protective clothing," Teele said. "We said it really doesn't because No. 1976 is a product standard for this equipment."
No. 1976 merely sets the technical standards required for protective clothing fire gear used in proximity fire fighting, Teele said. The NFPA standards that seem more appropriate as targets of concern are No. 600, which governs fire fighting operations of industrial fire brigades, and No. 1500, which governs the operations of municipal fire departments and incipient "structural-only" industrial fire departments.
Like No. 1976, standard No. 1971 and 600 are also undergoing the mandated revision process. No. 1500 underwent revision last year and is not scheduled to be reconsidered until 2002.
Fire chiefs opposed to aluminum PPE insist that the issue revolves around a basic misconception about modern industrial fire fighting. Proximity fire fighting should not be defined solely by the type of fire being fought. More important is the distance between the firefighters and the fire. Hence, the word "proximity," i.e., closeness.
Ken Martin, vice chairman of the Texas Chemical Council's Occupational Safety Committee, is also the safety engineer for a chemical plant. Besides "proximity fire fighting," the other key phrase in No. 1976 is "approach fire fighting," Martin said.
"In No. 1976, it talks about proximity fire fighting," Martin said. "It also talks about approach fire fighting. Nobody ever looks at that one. Approach fire fighting takes the same definition as proximity fire fighting except that you do it a greater distance from the flames at a lower heat level. And that's really what we do in industry."
NFPA No. 1976 defines proximity fire fighting as specialized fire fighting operations "that can include the activities of rescue, fire suppression, and property conservation at incidents involving fires producing very high levels of conductive, convective and radiant heat." Although direct entry into the flames is not made, proximity fire fighting requires "specialized thermal protection" because personnel are operating close to the fire.
In the same standard, approach fire fighting is defined as limited, specialized exterior fire fighting operations at incidents involving "fires producing very high levels of conductive, convective and radiant heat. Personnel require "specialized thermal protection" from radiant heat, even though approach fire fighting is done at a greater distance from the fire.
Since the object of modern industrial fire fighting is to keep firefighters away from the flames, the difference between approach fire fighting and proximity fire fighting is crucial. In practice, the difference can be as great as standing 500 yards from a fire or as close as 100 feet. For all its concern about radiant heat, No. 1976 fails to provide any applicable scale by temperature or distance to support the case for proximity gear.
"There is no definition for what constitutes 'radiant heat,' so it puts us at a disadvantage to try to deal with this issue," one fire chief said. "The NFPA standards talk about radiant heat, but there is no definition of where it begins or ends."
No. 1976 is extremely specific regarding radiant reflective testing of aluminized fabric. However, the testing results are hardly an easy reference tool for firefighters. The fabric being tested covers a heat sensor placed one inch away from a bank of five 500-watt infrared quartz lamps subjected to a thermal flux of 2 Cal/cn2/sec. of 100 percent radiant heat. A shutter is used to limit the heat exposure to 25 seconds. The average from five tests serves as the final figure.
Fabric used in either structural or proximity gear must not melt, separate or ignite at 500 degrees F at a minimum exposure of five minutes.
No one denies that a firefighter going close to the flames needs all the protection he or she can get from heat, radiant and otherwise. The most effective barrier for stopping radiant heat is a metalized surface that reflects it away rather than allows it to be absorbed through the fabric, said Harry P. Winer, a scientist with the U.S. Navy Clothing & Textile Research Facility. He also serves as secretary on the NFPA No. 1976 technical committee.
"Aluminized proximity gear, if you have high radiant heat, is something you need," Winer said. "Structural clothing does not offer you protection currently from high amounts of radiant heat. It just doesn't do it. I mean, if you are way back hundreds of yards and you are throwing torrents, huge streams of water 200 yards, you wouldn't need it. But if you need to get within proximity of a fuel fire to shut something off or to rescue someone or to do something, you need the proximity clothing."
Firefighters serving as a first line of defense in an industrial fire should be safely protected by using the correct PPE, Winer said.
"Do the people in the back need it?" Winer asked. "No, because radiant heat drops off with distance."
At what distance is structural gear safe? At what temperature is proximity required? Fire chiefs with one major American chemical company are developing a user document on radiant heat as part of the company's emergency response manual. It seeks to incorporate the language such as "hot zone," "warm zone" and "cold zone" as a means to continue using structural PPE when appropriate.
One prominent fire chief participating in drafting the user document said it will show that returning to proximity gear is unwarranted.
"Basically, this is a check list for the emergency response team and officers -- the emergency director, the fire chief and our senior captains -- to be able to check off a number of items to determine the appropriate personal protective equipment for the firefighter to wear," the fire chief said.
As for proximity PPE, the fire chief said his chemical plant brigade has continued to keep aluminized proximity gear on hand since it was phased out of general use in the 1970s. It has gone unused, he said. Even the worst emergency at his plant in recent years -- nine pipeline metering stations on fire at once -- did not require proximity protection.
"It was a very large, spectacular fire, and we never had any radiant heat problems," the fire chief said. "We were able to mitigate the radiant heat with water streams."
Winer said the lack of established operating procedures such as the proposed user document is part of what makes proximity gear necessary.
"The thing I was trying to present to people when I spoke to them about it, especially the different oil companies, was that you come up with a standard operating procedure," Winer said. "This operating procedure should say 'If you are going to operate between this boundary and this boundary, I'm going to have an attack team wearing the right clothing. If I'm going to be operating between here and here, I'm in structural clothing.' "
Winer said he and the other members of the No. 1976 committee were surprised that these procedures were not already in place.
"We asked the people we spoke to when this whole thing hit the fan about a year ago 'What is your procedure?'" Winer said. "No one had anything. Well, we felt the way they felt when they were told that 100 percent of everyone had to be in proximity gear. I don't think anyone really thought that all the hundreds of people in the brigade coming out to help had to be in proximity. But you do need an attack team who does specialized things."
One company that provides fire protection to industry on a contract basis takes exception to OSHA interpretation that companies must provide "correct" fire fighting gear as determined by NFPA standards.
"(We comply) with the OSHA general duty clause despite the fact that we do not provide all of our firefighters with aluminized PPE," a statement issued by the company said. "We accomplish this by using administrative procedures. OSHA does permit engineering controls and administrative procedures to be used in lieu of personal protective equipment."
Those procedures include:
? Attacking fires with large-caliber apparatus-mounted deck guns that have automatic nozzles with superior reach.
? Following the attack by using 5-inch diameter portable monitors that feature automatic nozzles.
? Reach of this equipment keeps personnel in a safe location in regard to radiant heat.
? Every employee trains quarterly on these fire attack techniques.
? Crews on shift train to maintain a "quick attack" proficiency level.
? New employees are required to demonstrate proficiency before graduation from recruit school.
? We use the latest foam concentrates and foam proportioning systems.
? We carry as much as 2,000 gallons of foam concentrate on our first-out fire truck.
Aside from the issue of defining radiant heat, the industrial fire chiefs question the wisdom of tying fire fighting techniques as diverse as industrial fire fighting and aircraft rescue together in one standard.
"The people who put this standard together have no concept of industrial fire fighting," one industrial fire chief said. "These are folks who climb off airport crash trucks where you have this blazing fire and you wade into it with foam and dry chem. They are taking the brunt of all that radiant heat."
That kind of situation does not arise in industrial fire fighting, he said.
"We mitigate the radiant heat so that our (structural gear) will be appropriate for the fire ground," the chief said. "By mitigation, we have very expensive high capacity water deluge systems on all our equipment. Radiant heat would not be an issue for us in a major fire unless there had been an explosion that had in some way damaged that system."
The fixed deluge systems can be used with water or foam. Along with the deluge systems, any team that would have to move in close to the flames would be covered with massive amounts of water and foam from nozzles that deliver volumes that municipal firefighters can only dream about.
"These people who wrote up these positioning standards have no concept of what we do," an industrial fire chief said. "When we try to explain it to them, all they are seeing is a line out there that is 500 gallons per minute or less. Well, we use 20,000 gallons per minute. That is something they can't fathom."
Aluminum PPE opponents insist that statistics do not support a need for change. According to NFPA statistics, only 29 industrial fire fighters died on the job in a 19-year period ending in 1996. Over the same period, the average for career and volunteer firefighters killed was 121.6 annually. Of the industrial firefighters who have died from 1990 to 1997, all succumbed to asphyxiation, not burns. Only three of the 29 died from burns, and those deaths were firefighters battling forest fires outside of their plants.
"Industry stands by their record," industry consultant David White said. "We do not have a poor safety record in fighting fire or getting people injured. We have almost no burns."
A survey undertaken by White of more than 100 industrial plants representing nearly 9,600 industrial firefighters found that the few burns reported were training incidents and never serious.
"These are people who fight the largest, hottest radiant heat fires that ever existed on the planet," White said.
To hear John Schenck, president of Southern Laboratories, talk about laundering proximity bunker gear gives the impression of something so delicate that it would best be hand-washed in the bathroom sink.
"The whole key to it is to use a detergent that is extremely gentle and also gives you a lot of lubrication in the process so that when the aluminum is rubbing against itself, it is slick enough that you are not abrading it," Schenck said. "It's a super gentle cycle for lack of a better phrase."
Southern Laboratories, operating in New Orleans, Houston, Los Angeles and Seattle, specializes in laundering protective clothing for firefighters. Aside from structural gear, Schenck said Southern Laboratories washes nearly 1,000 pieces of proximity gear annually.
Coming up with a safe process for washing proximity gear took nearly a year of research, Schenck said. And, despite all the special care, no piece of proximity PPE has survived more than five washings before being "red tagged" to warn the owner that it is no longer safe to wear.
"I don't think that anyone else in the United States is able to get that many washes other than us," Schenck said. "No one else has been able to provide laboratory testing showing that they can."
Schenck's concerns about maintaining proximity PPE mirrors those of many industrial fire chiefs opposed to the return of silvers as all-purpose fire gear. Proximity gear, up to 30 percent more expensive than structural gear, would require constant maintenance and replacement to deal with the rigors of continuous training, let alone actual fire fighting.
"It's a matter of the quality of the product," one fire chief said. "We would be taking a piece of gear that we get at least two or three years out of if you maintain right, keep it clean and in reasonable condition, and replace it with a product that probably would be a one-time use piece of gear."
Washing the gear is one thing. Maintaining the equipment after it has actually been used in fighting a fire is something else, Schenck said.
"Realistically, if you took any set of aluminized gear out there that has been used (for fire fighting), it probably doesn't meet standards anymore," he said. "That's how delicate this stuff is. It's as close as you can get to throw-away protective clothing and still not call it throw-away protective clothing."
By comparison, it is not unusual for structural fire gear as much as 15-years-old to still be in use, Schenck said. Firefighters typically retire structural fire gear long before it wears out, simply to take advantage of the newest innovations in PPE, he said.
Proponents of proximity PPE insist that the durability and cost issues are balanced by the extra radiant heat protection. Winer, serving on the NFPA No. 1976 committee, said he agrees that not every firefighter on an industrial fire brigade needs proximity clothing. But a limited number of sets should be available for special teams doing proximity fire fighting, he said.
"It wears out faster, okay, so that the life expectancy of the gear isn't as long as that for structural gear," Winer said. "But look at it another way -- How often do you have a fire? How many times are you going to use it? It doesn't degrade hanging in your locker."
One fire chief counters that industrial fire brigades operate far differently from municipal fire departments.
"There are so many things that affect this gear," the fire chief said. "Most municipal fire departments can hang their gear in a locker because the firemen grab it, get on the truck and they are gone. But in industry, most of us put our gear in bags and carry it in vehicles. So it is wadded up or folded up into a bag, which further affects the longevity."
What makes proximity gear so difficult to maintain? Schenck is of the same opinion as many industrial fire chiefs -- the fabric lacks the durability of that used in structural gear. Principally, the problem is keeping the reflective protection in place.
"The problem that you have with it is the aluminum layer is so thin that it rubs off just from average wear," Schenck said. "One of the tests performed to see that the gear meets NFPA standard is to take a cotton cloth and rub the fabric something like 300 wipes, then check and see if the fabric is still good."
Adding a film of aluminum to what is essentially structural PPE has other drawbacks. Most fabrics used for outer shell material in structural gear are 7 to 71/2 ounces per square yard, Schenck said. To keep proximity gear in the same weight range, the base material minus aluminum is as light as 41/2 ounces, he said.
"What is really scary is that you can take a piece of brand new, unused piece of this fabric, put a flashlight behind it, turn off the other lights out in the room, and that light from the flashlight shows through," Schenck said. "That is how thin it is."
NFPA No. 1971 and 1976 require an outer shell tear resistance of at least 22 pounds. Major seams must be able to sustain at least 150 pounds breaking strength. However, Schenck and some fire chiefs have doubts that the new generation of proximity gear is as safe as structural gear.
"In protective clothing, there are so many trade-offs," Schenck said. "The aluminized fabric is great for flexibility and weight, but if you happen to hook it on anything, it is just going to tear to shreds. It just doesn't have a lot of strength to it."
For one fire chief interviewed by IFW, the fear is that the more fragile proximity gear could fail at just the worst time.
"To me, the aluminized gear, if you were in a major emergency, and it tore, you would have an impairment in the system and could get someone burned," the fire chief said. "The issue is that the quality of the base fabric is much less than the (structural gear) that we are wearing now."
However, Winer rejects the idea that the fabric in proximity PPE is more fragile. Modern proximity PPE takes advantage of specially knitted fabrics that may be lighter but still meet the strength specifications under No. 1976. He further notes that the testing specifications for the fabric in proximity gear under No. 1976 are identical to those for structural PPE under No. 1971.
"If the fabric meets the testing standard under No. 1976 or No. 1971 and is still not strong enough, then there is a problem with the standards, not the clothing," Winer said.
In the 1970s when reflective clothing was standard PPE in industry, aluminized gear was thicker. Still, there were always problems keeping it ready for use, one fire chief said. Firefighters used aluminized paint to repair the flaking and peeling surface. It is doubtful the same would be permitted today.
A statement issued by one company that serves as an outside contractor providing industrial fire protection reports that it ceased using proximity gear in 1986.
"The clothing presented additional weight burden over traditional structural fire fighting clothing," the statement said. "The aluminized clothing also presented poor flexibility and greater heat stress load to the wearer. This additional wearer burden may not be of great consequence during short duration aircraft crash rescue fires, but it is of great concern to petrochemical and refinery fire fighters who may need to operate over time spans in excess of 24 hours."
The biggest drawback of proximity gear in its heyday remains unsolved today, TCC's Ken Martin said. Proximity gear still does not "breathe."
"One hardship is that aluminized gear is going to be much hotter to work in," Martin said. "And so heat stress and the amount of time that a firefighter can battle a fire is going to be reduced dramatically. The nice thing about structural fire fighting is that when you are fighting a fire, you get hosed down. You get that bunker gear wet and you get evaporative cooling. You don't get that with aluminized gear."
Which brings us back to the issue of washing proximity gear. NFPA standards require that proximity gear be washed at least twice a year. Since the gear is expressly recommended for use in proximity fire fighting involving burning fuels, an exterior accumulation of unburned hydrocarbon is typical. As for the interior, a full-grown firefighter sealed inside aluminized insulation tends to sweat. A lot. And, yet, because of the risk that washing poses, brigades are reluctant to launder their silvers.
"When it comes to aluminized gear, I would venture to say that if you found someone who washed it once a year, they would be on the leading edge of cleanliness," Schenck said. "Very few people do that because everybody knows it wears out so fast."
Winer counters that interior liners used in PPE are detactable and can be washed separately from the outer shell. (Schenck said that not all brands have detactable liners.) The specifications for liners are the same for structural or proximity PPE, Winer said. Brigades may only send PPE out for professional laundering on an infrequent basis, but use their own washing machine the rest of the time.
On the pro-aluminum side of the proximity clothing debate stands OSHA and NFPA. OSHA is responsible for workplace safety regulations and inspections nationwide. NFPA sets most of the standard and codes for fire prevention across the country. Who is lining up against these agencies as anti-aluminum?
Enter the Industrial Fire Emergency Working Group. Its membership includes the Chemical Manufacturers Association, the American Petroleum Institute, the industrial section of the International Association of Fire Chiefs, Texas Chemical Council, Texas Industrial Fire Training Board and the Louisiana State Industrial Firefighters Association. Add to this mutual aid associations ranging from the world's largest in Houston to Chicago, New Jersey, California, Mississippi; Beaumont, TX, and Lake Charles, LA.
"A majority of industry is represented in this group," said White, an IFEWG organizer.
Central to this organized opposition is the Texas Chemical Council, a trade organization representing nearly 90 percent of Texas' mammoth chemical industry.
"We are trying to get a consensus from a number of different industrial organizations, all the groups that have an interest in this issue," TCC vice chairman Ken Martin said. "The Texas Chemical Council is simply trying to be the focal point for all of this, taking a lead role to see that we all work together and speak with one voice on this."
That TCC is taking a lead role does not make this solely a Texas issue or solely a chemical industry issue. Bill Erny, senior regulatory analyst with the American Petroleum Institute, represents another group concerned with the aluminum fire gear issue.
"Our members are concerned because, and I'm sure this is the same for a lot of the chemical sites, the larger facilities have their own fire brigades on site that are well-trained, have been operating for years and are expert in fighting bulk flammable fires," Erny said. "For the most part, our people haven't relied on aluminized gear."
To Erny, the extent to which NFPA standards now dictate what type of protective clothing can be worn is "clear as mud." Like White, neither Erny nor Martin is impressed with the response from NFPA on the proximity gear issue.
"There have been several attempts made to get clarification that appear to have not been terribly successful," Martin said. "The key thing at this point that we need to clearly establish is that NFPA No. 1976 is a document that provides guidance to manufacturers of (aluminized) clothing, but is not intended to provide guidance in the use of it in fire fighting situations."
NFPA 600 is the primary document that guides industrial fire brigades operating in the field. However, there are at least five NFPA standards that impact industrial fire brigades -- 600, 1500, 1971, 1976 and 1081, which sets requirements for the training of industrial firefighters.
Lending technical assistance to resolving the proximity debate is DuPont. The company's Thermal Testing Laboratory has agreed to test proximity PPE to determine its exact tolerance to radiant heat and direct flame contact. Testing will utilize DuPont's Thermo-Man instrumented manikin system, one of the most advanced life-size thermal burn injury evaluation devices in the world.
Made from a high-temperature composite material, the 6-foot 1-inch tall, size 42 regular manikin is used to measure the protective performance of a variety of garments and clothing systems under realistic flash-fire conditions. Factors such as garment construction, fabric weight, material type, style and fit can be taken into account under controllable, reproducible scientific conditions.
Four manufacturers of proximity protective clothing have volunteered to provide samples for the tests, White said.
"We've been told that this gear is so much better than (structural) gear and that it does better in radiant heat," White said. "We're going to find out. When these test results are out, DuPont and the manufacturers of this gear have consented to let us disseminate the information to the appropriate committees in industry."
Winer counters that while Thermo-Man is excellent for testing that requires direct flame inpingment, it is not designed to monitor radiant heat.
"Testing with Thermo-Man will not prove what we need to know," Winer said.
In 1997, NFPA revised NFPA No. 1971 to combine four separate standards regulating structural coats, trousers, overalls, helmets, gloves and footware. The fifth edition issued in 22 years, No. 1971 now treats structural PPE as a unit rather than separate pieces. The proposed revision of NFPA No. 1976, only its second edition, would do the same for proximity gear.
"It is modeled after NFPA No. 1971," Winer said. "It is going to be set up the same way. You can pick one standard and outfit the complete firefighter. That's the way it should be instead of having a standard for each component."
Every NFPA standard undergoes a routine revision every five to seven years. NFPA No. 1976 is already pushing the seven year limit. Supervising that revision process is the Specialized Fire Fighting Applications Protective Clothing and Equipment Technical Committee. Teele serves as staff liaison to the committee.
"The document has been through the revision process within the committee," Teele said. "It is now in the public comment stage where anybody who is interested can review it, see what the committee is proposing, and make comments to the committee regarding those changes."
Copies of the proposed revisions are available to the public by calling NFPA at (800) 344-3555 or looking it up on the NFPA web site at www.nfpa.org. The deadline for public comment is April 2.
After the public comment stage closes, the committee meets again to review and answer the comments received. The committee then may amend its original report and vote on those amendments. Final action on the new standard will be at the NFPA Fall Meeting November 13-17 in New Orleans. Members in attendance vote on the standard, which becomes effective in January 2000.
One fire chief interviewed by IFW said that because OSHA has chosen to "blanket" NFPA standards, it is essential that industry take a more active role in drafting of new standards and the revision of existing ones. Although NFPA requires that its standards not conflict when addressing similar areas, the gap between No. 600 and OSHA's interpretation of No. 1976 shows this is not always the case, the chief said.
"NFPA is so much in conflict with their documents that they are really going to have to overhaul the system, take a real strong look at it," the fire chief said. "In the meantime, industry and other people are caught in the squeeze."
The staggered revision schedule for NFPA standards makes it difficult to keep ones with similar concerns out of conflict, TCC's Martin said. He sees problems with No. 600 and No. 1500, which covers minimum requirements for fire service-related occupational safety and health.
"As you go through the standards, what happens is each one is on a different schedule for revision and update," Martin said. "NFPA 600 was really written to address the issues of industrial fire fighting. But because it is brand new, it covers things that were covered in NFPA 1500 in the past. So conflicts arise between 600 and 1500, because they don't really match.
"That's where a lot of the challenge is. It is not an attempt by NFPA to confuse things or make things difficult for anybody."
Aside from No. 1976 and No. 600, one other important NFPA standard regarding industrial firefighting is up for revision this year. NFPA No. 1081 sets requirements for the training of industrial firefighters.
To say that someone is standing "too close to the flame" has a double meaning in the debate about proximity protective clothing. It can refer to proximity fire fighting. It can also refer to any industrial fire chief opposed to the OSHA-mandated use of proximity PPE in his plant.
More than one fire chief contacted by IFW has refused to comment. Their reasons are their own. It can be assumed many are concerned about drawing the attention of regulators at a time when most departments are vulnerable. As a result, IFW has chosen to protect the identities of those officials and companies willing to discuss this issue.
However, reluctance to speak or get involved in the standard-making process is a major contributing factor to the proximity gear controversy. Industrial firefighters are a small constituency in the vast American fire service. It is hard to think of any fire chief having an inferiority complex, but perhaps the industrial chiefs feel outgunned in a process geared largely toward municipal fire fighting.
The first and most important way to deal with the proximity gear issue is greater involvement in the standards-making process. Establishing the Industrial Fire Emergency Working Group is a major step in that direction. True, industrial firefighters will always have limited clout within the NFPA. But, organized as a single attention-getting blow, that clout can be formidable.
Having established the necessary clout, the next step is to bring it to bear behind the correct solution. The IFEWG proposal is to give incident commanders the authority to dictate what type of protective gear is most appropriate based on the hazard each firefighter faces. This would be done by inserting a new section in NFPA No. 600, rather than No. 1976.
"It's a real simple section to address the issue of protective clothing for emergency response people," said White, an IFEWG organizer. "Essentially it says that the incident commander shall evaluate the hazard, and the incident commander has the responsibility to dictate what type of protective clothing shall be worn by the emergency response people performing the different tasks and duties at the emergency scene."
The work under way to develop a user document for radiant heat exposure would serve as an important tool for the incident commander making the decision, White said. The radiant heat threat for various operations would be thoroughly researched, defined and no longer subject to a "best guess" approach.
For proximity gear proponents, the new section would give ample attention to radiant heat as a potential hazard. It would insure that if firefighters were forced to move close enough to the flames that radiant heat is a risk, they will be adequately protected. Martin with TCC feels this compromise would be acceptable to fire chiefs.
"The fire chief or whoever is in charge of fire fighting operations on your site needs to be reviewing the kind of fires you can have based on the situations you are going to tackle at that facility," Martin said. "Based on that, you establish what bunker gear you are going to wear for those situations, and certify it as appropriate for your facility."
In the end, who is the best person to make a decision about the right protective clothing to wear in an industrial emergency -- a committee trying to stamp a one-size-fits-all approach on a specialized, yet widely diverse area of the fire service, or the incident commander who is familiar with what the equipment and the personnel at a particular facility can do?
The issue is not about cost, but about safety. If fire gear that costs twice as much as proximity provided 100 percent guaranteed protection against all danger, radiant heat and otherwise, the regulators would not have to insist on its use. Any industry concerned about liability for the lives of its employees would gladly shell out for such foolproof gear. But, unfortunately, no such absolute guarantee exists.
No one PPE will surfice for all occassions. However, sacrificing the sturdy reliability of structural protective clothing for the few seconds of grace from radiant heat that proximity provides hardly seems a fair trade, particularly when the majority of those at the fire scene do not face a radiant heat threat.
As far as the rigors of industrial fire fighting are concerned, the responsibility for choosing the right PPE should rest with the person best suited to evaluate the risks at the fire scene and take the appropriate action to protect life and property -- the incident commander.
Standards Related to Promixity Gear May Impact Municipal Departments
Continuing debate about aluminized protective clothing may force an interim revision to a National Fire Protection Asso-ciation standard governing occupational health and safety at municipal fire departments, an NFPA senior fire service specialist said.
NFPA No. 1500 covers minimum requirements for fire department occupational safety and health. It underwent revision in 1997 and is not scheduled to be reconsidered until 2002. However, a TIA (temporary interim revision) to clarify questions regarding proximity firefighting is under consideration, said Stephen Foley, an NFPA senior fire service specialist. He served as staff liaison to the technical committee supervising that revision.
In question is whether the latest edition of No. 1500 requires that municipal fire departments and some "incipient" industrial fire departments are required to use aluminized gear based on the potential for aircraft accidents or industrial emergencies involving the risk of high radiant heat. The issue first raised its head during development of the most recent edition of No. 1500, Foley said.
"The discussion was whether a small town or a large town or anyone responding or who potentially could respond to an aircraft incident would need to have proximity protective clothing that met NFPA standards," he said. "The committee said 'Of course they would.' "
That a fire department in a big city that was home to an international airport needed proximity gear was not in question, Foley said. But what about a small town department with the misfortune of being on the final approach to a major airport? From a risk analysis standpoint, that department would have a far greater potential to need structural gear than aluminized.
"If you talk to a majority of airport fire departments, they don't carry proximity protective clothing anymore," Foley said. "They carry structural fire fighting protective clothing because the FAA considers the fuselage of an airplane to be a structure. If you have the wings or the center belly tanks rupture and you have flammable liquid spill, your structural fire fighting gear is not going to afford you a level of protection to fight that."
The proposed TIA has expanded the issue still further beyond dealing with aircraft incidents, Foley said. Suppose a gasoline tanker truck overturned and exploded in your community? Would small municipal fire departments have to be prepared by having aluminized gear on hand? The committee, which met last summer, reviewed the TIA and opted to put it on hold.
"That was well beyond what the committee had ever discussed in the development of the No. 1500 standard," Foley said. "So the committee gave it to a small task group to look at and try to come up with some other proposed language the committee could respond to that addressed the issue."
NFPA No. 1500 also regulates incipient fire departments in plants as opposed to full industrial fire brigades as covered by NFPA No. 600, Foley said.
"No. 1500 deals with municipal fire fighting and industrial fire departments, not industrial fire brigades as defined by OSHA," Foley said. "Industrial fire departments would help evacuate the facility and would know how to use the extinguishers, but would not be trained in the use of self-contained breathing apparatus or personal protective clothing. They don't do any hands-on fire fighting."
Passage of the TIA involves, one, arriving at language that the committee can agree on, and, two, determining that the situation cannot wait for the next scheduled revision. If approved, the TIA becomes immediately effective and would be included as a proposal in the next revision of the standard.
The next meeting of the NFPA No. 1500 technical committee is scheduled for the first week in June. Meanwhile, an NFPA educational program on the interrelation between industrial fire brigades and municipal fire departments is scheduled for 8:30 a.m. to 1:30 p.m. Feb. 26 at the Holiday Inn North in Houston.
"We are going to have people on both sides of the aisle discussing the proximity gear issue," Foley said.
STANDARDS RELATED TO PROXIMITY GEAR
NFPA No. 1971: Standard on Protective Clothing for Firefighters
Adopted by NFPA in 1975, this standard set the technical requirements for structural protective coats and trousers, including maximum tolerance for conductive and convective heat. Other NFPA standards governing structural gear include No. 1972 (helmets), No. 1973 (gloves), and No. 1974 (footwear). In 1978, OSHA adopted the NFPA standards for structural gear, mandating under OSHA 1910.156(e)(3)(B)(2) that the "performance, construction, and testing of fire-resistive coats and protective trousers shall be at least equivalent" to NFPA No. 1971-1975. The fifth edition of No. 1971, approved by the NFPA in 1997, consolidated No. 1971 through No. 1975 into one ensemble standard for protective gear.
NFPA No. 1976: Protective Clothing for Proximity Fire Fighting
Adopted by NFPA in 1992, this first edition of NFPA No. 1976 set the technical requirements for aluminized protective clothing. The standard defines proximity fire fighting as operations such as those involving "bulk flammable liquids and bulk flammable gases and during aircraft rescue and fire fighting." The standard adopted maximum tolerances for conductive and convective heat from No. 1971 (1991 edition), but also required a reflective outer shell to prevent absorbing high radiant heat. No. 1976 is undergoing required revision at this time. One proposal under consideration is that all technical standards for proximity fire fighting gear standards be consolidated under No. 1976 as an ensemble, al la No. 1971. Public comment to NFPA on proposed revisions ends April 2.
NFPA No. 600: Standard on Industrial Fire Brigades
The current edition of No. 600 was approved by NFPA in 1996. The standard covers the organizing, operating, training and equipping of private fire brigades. Whereas No. 1971 and No. 1976 set technical standards for protective clothing, No. 600 actually covers the operations of industrial fire brigades. The Industrial Fire Emergency Working Group has proposed amending No. 600 to give incident commanders the final authority on what type of protective clothing is worn at an emergency. A revision of No. 600 is scheduled to be voted on by NFPA's membership this fall.
NFPA No. 1500: Standard on Fire Department Occupational Safety and Health Program
This standard covers minimum requirements for fire service related occupational safety and health in municipal fire departments. It also governs some industrial fire departments of limited size. No. 150 underwent revision in 1997 and is not scheduled for reconsideration until 2002. However, to clarify whether No. 1500 requires widespread use of proximity fire fighting gear, an interim temporary amendment is being considered.