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Report of the Committee on

Fire and Emergency Services Protective Clothing and Equipment

Technical Correlating Committee

Richard M. Duffy, ChairInternational Association of Fire Fighters, DC [L]

Rep. International Association of Fire Fighters

William M. Lambert, SecretaryMine Safety Appliances Co., PA [M]

Rep. Compressed Gas Association

Leslie Anderson, U.S. Forest Service, MT [E]Richard W. Blocker, Jr., The DuPont Company, VA [M]Dennis W. Browner, Scott Aviation, NC [M] Rep. Industrial Safety Equipment AssociationNicholas J. Curtis, Lion Apparel, Inc., OH [M]Robert A. Freese, Globe Manufacturing Company, NH [M]Bill Grilliot, Morning Pride Manufacturing L.L.C., OH [M] Rep. Fire and Emergency Manufacturers and Services Association, Inc.William E. Haskell, III, U.S. Army SBCCOM Natick Soldier Center, MA [U]Virgil Hathaway, San Diego Fire Department, CA [U] Rep. Southern Area Fire Equipment ResearchJames S. Johnson, Lawrence Livermore National Labs, CA [RT]Cy Long, Texas Commission on Fire Protection, TX [E]David G. Matthews, United Kingdom Fire Brigades Association, England [SE] Rep International Standards OrganizationJim Minx, Oklahoma State Firefighters Association, OK [C]Stephen R. Sanders, Safety Equipment Institute (SEI), VA [RT]Denise N. Statham, Southerm Mills, Inc., GA [M]Jeffrey O. Stull, International Personnel Protection, Inc., TX [SE]Robert D. Tutterow, Jr., Charlotte Fire Department, NC [U] Rep. Fire Industry Equipment Research OrganizationBruce H. Varner, City of Carrollton Fire Department, TX [U] Rep. International Fire Service Training AssociationHarry Winer, U.S. Navy, MA [RT]Thomas L. Wollan, Underwriters Laboratories Inc., NC [RT]

Alternates

Janice C. Bradley, Industrial Safety Equipment Association, VA [M] (Alt. to D. W. Browner)Gregory S. Copeland, Celanese AG, NC [M] (Alt. to R. W. Blocker)Patricia A. Freeman, Globe Manufacturing Company, NH [M] (Alt. to R. A. Freese)Patricia A. Gleason, Safety Equipment Institute, VA [RT] (Alt. to S. R. Sanders)Mary I. Grilliot, TFG/Morning Pride Manufacturing Company, Inc., OH [M] (Alt. to B. Grilliot)Tricia Hock, Sprinkfield, L.L.C., SC [M] (Alt. to D. N. Statham)Steven B. Lumry, Oklahoma City Fire Department, OK [C] (Alt. to J. Minx)Daniel P. Ryan, Underwriters Laboratories Inc., NC [RT] (Alt. to T. L. Wollan)Frank P. Taylor, Lion Apparel, Inc., OH [M] (Alt. to N. J. Curtis)

Nonvoting

Donna P. Brehm, Virginia Beach Fire Department, VA [U]Don R. Forrest, United Firefighters of Los Angeles City, CA [L]Bryan C. Heirston, Oklahoma City Fire Department, OK [L] Rep. International Association of Fire FightersWilliam R. Hutfilz, Clark County Fire Department, NV [U]Richard Mangan, USDA Forest Service, MT [RT]Kirk H. Owen, Plano Fire Department, TX [U] Rep. NFPA Fire Service SectionRay F. Reed, Dallas Fire Department, TX [U]

Staff Liaison: Bruce W. Teele

Committee Scope: This Committee shall have primary responsibility for documents on the design, performance, testing, and certification of protective clothing and protective equipment manufactured for fire and emergency services organizations and personnel, to protect against exposures encountered during emergency incident operations. This Committee shall also have the primary responsibility for documents on the selection, care, and maintenance of such protective clothing and protective equipment by fire and emergency services organizations and personnel.

Technical Committee on

Respiratory Protection and Personal Alarm Equipment

Ray F. Reed, ChairDallas Fire Department, TX [U]

W. Lee Birch, SecretaryLuxfer Gas Cylinders, CA [M]

Eric Beck, Mine Safety Appliances, PA [M]A. Paul Bull, Fairfax county Fire and Rescue Department, VA [U]Kenneth R. Ethridge, Texas Commission on Fire Protection, TX [E]Don R. Forrest, United Firefighters of Los Angeles City, CA [L] Rep. International Association of Fire FightersEdward D. Golla, TRI/Environmental, Inc. TX [RT]A. Ira Harkness, U.S. Department of the Navy - Coastal Systems Station, FL [RT]Jack Jarboe, Grace Industries Inc., MD [M]Stephen J. King, New York City Fire Department, NY [U]Michael A. Kreuger, PA [SE]Kevin D. Lentz, City of Garland Texas Fire Department, TX [U]Ian Maxwell, Interspiro Europe AB, Sweden [M]Jerry Phifer, Scott Health and Safety, NC [M]Mark I. Piland, City of Virginia Beach Fire Administration, VA [U]Daniel N. Rossos, City of Portland Fire Bureau, OR [OR]Stephen R. Sanders, Safety Equipment Institute (SEI), VA [RT]Frank Savino, SGS/US Testing, NJ [RT]Robert H. Sell, Draeger Safety, Inc., PA [M]Brian J. Sharkey, USDA Forest Service, MT [RT]Richard A. Smith, Trace Analytics, Inc., TX [RT]Dale W. Soos, Intertek Testing Services NA, Inc., NY [RT]Richard L. Stein, Survivair, CA [M] Rep. Industrial Safety Equipment AssociationSamuel Terry, U.S. National Institute for Occupational Safety & Health, WV [E]Kenton D. Warner, KDW consulting, L.L.C., CT [SE]

Alternates

Marshall (Mark) J. Black, U.S. Department of the Navy - Coastal Systems Station, FL [RT] (Alt. to A. I. Harkness)J. Michael Carlson, TRI/Environmental, Inc., TX [RT] (Alt. to E. D. Golla)Eugene P. Garvin, New York City Fire Department, NY [U] (Alt to S. J. King)David Hodson, Draeger Limited, England [M] (Alt. to R. H. Sell)Rick Hofmeister, Scott Aviation, NC [M] (Alt. to J. Phifer)Keith G. Iole, Mine Safety Appliances, PA [M] (Alt. to E. Beck)Robert William O'Gorman, Intertek Testing Services NA Inc., NY [RT] (Alt. to K. E. Strumlock)Frank Pepe, SGS/US Testing, NJ [RT] (Voting Alt. to SGS/US Testing)

Staff Liaison: Bruce W. Teele

Committee Scope: This Committee shall have primary responsibility for documents on protective equipment that provides respiratory protection for fire fighters or other emergency services responders during incidents involving operations conducted in hazardous or oxygen deficient atmospheres. These operations include the activities of rescue, fire suppression, hazardous materials mitigation, and property conservation where exposures to an oxygen deficient atmosphere or an atmosphere contaminated with harmful particulate,fog, fume, mist, gas, smoke, spray, or vapor will or could occur. This committee shall also have primary responsibility for documents on personal monitor/alarm/distress devices for responders operating in hazardous atmospheres or in hazard areas at incidents where entrapment, disorientation, or other responder personal emergency could occur. Additionally, this committee shall have primary responsibility for documents on the selection, care, and maintenance of respiratory and personal alarm equipment by fire and emergency services organizations and personnel.

These lists represent the membership at the time each Committee was balloted on the text of this edition. Since that time, changes in the membership may have occurred. A key to classifications is found at the front of this book

This portion of the Technical Committee Report of the Committee on Respiratory Protection and Personal Alarm Equipment is presented for adoption.

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NFPA 1981 — May 2002 ROC— Copyright, NFPA This Report on Comments was prepared by the Technical Committee on Respiratory Protection and Personal Alarm Equipment, and documents its action on the comments received on its Report on Proposals on NFPA 1981, Standard on Open-Circuit Self-Contained Breathing Apparatus for the Fire and Emergency Services 1997 edition, as published in the Report on Proposals for the 2002 May Meeting.

This Report on Comments has been submitted to letter ballot of the Technical Committee on Respiratory Protection and Personal Alarm Equipment, which consists of 24 voting members; of whom 18 voted affirmatively, 1 negatively after circulation of negative ballots (Etheridge), 2 abstained (Lentz, Sell), and 2 ballots were not returned (Birch, Piland).

Mr. Etheridge voted negatively stating: He is unable to review the final document and that the proposed revisions do not contain requirements for upgrades.

Mr. Lentz abstained stating: He did not have a completed document to review and believes the Committee should have a totally finished document with all ROC changes in Place to review

Mr. Sell abstained stating: He does not believe the RICUAC system on the high pressure side of the SCBA is the best way to proceed for fire fighter safety, and he feels that the Committee should have a finished document to review all the changes and how they are integrated into the text.

This Report on Comments has also been submitted to letter ballot of the Technical Correlating Committee on Fire and Emergency Service Protective Clothing and Equipment, which consists of 21 voting members of whom 17 voted affirmatively, 1 negatively (Winer), and 3 ballots were not returned (Anderon, Browner, Hathaway.

Mr. Winer voted negatively stating: He disagrees with the addition of the RIC concept and does not believe it should be part of the standard.

(Log #202)1981-1-(Entire Document) : Reject SUBMITTER: Jack Kay, STEDFASTCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Delete 1981-24. SUBSTANTIATION: While Stedfast appreciates the work of the TCC on Section 24 of 1981 we feel that there are far too many variables, which still need to be addressed. Some areas of concern: a) Cost - who will be responsible for funding an investigation B) Time and resources - manpower to accomplish such an investigation C) Who determines whether a safety alert is needed or a total recall D)Intent of individual filing complaint. We also feel that placing the burden of responsibility on a particular certification organization raises many difficult issues. These issues must be looked at carefully and carry with them far reaching implications.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: Although the submitter has recommended the deletion of the entire revision (Proposal 1981-24) the Committee believes the submitter sought to remove the text concerning complaints regarding compliant product and the possibility of product safety alerts or recall. the committee rejects the submitter position that these issues were not sufficiently explored. The certification organization is the logical entity to oversee and participate in the process to protect their mark and certification program and provide reasonable assurance to the end users. The submitter should see the revised text in section 4.6, 4.7 and 4.8 in the ROC preprint.

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(Log #203)1981-2-(Entire Document) : Reject SUBMITTER: Dan Szulczewski, WeinbrennerCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: 1. The wording appears to be so broad that it allows for strict liability no matter what the cause, and does not take into account how the produce was used, i.e., care, maintenance, abuse, durability, environment or conditions said product is introduced to. 2. It appears to make manufactures liable for changes in standards after the product has been put into service. This would make it impossible to predict the costs to manufacturers who could not anticipate future safety standards revision. 3. The arbitrary nature of such a requirement seems to be an unreasonable burden for manufacturers trying to comply with all safety standards. In other words, it makes the manufacturer responsible for safety standards that have not, as yet, been considered. 4. The wording leaves the manufacturer or component manufacturer open to the numerous costs of investigation because some entity decides for whatever reason to target a manufacturer with complaints. SUBSTANTIATION: None.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: Comments were submitted that recommended the entire section submitted by the TCC (Log #CP2 in the November 2001 ROP) be deleted. The committee reviewed the entire Log CP#2 as well as the substantiation of each of the submitters recommending rejection of the TCC section. The committee believes that investigation of potential product nonconformance or potential safety issues related to compliant products is of vital concern to users. The committee substantially revised TCC Log #CP 2 to ameliorate the weaknesses noted by the submitters, but maintained the central requirements.

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(Log #121)1981-3-(Entire Document) : Hold SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add text to read as follows: (new) 1.5.2.X Upgrade. A retrofit to an existing SCBA such that the SCBA meets the applicable requirements of this standard. (new) 2.1.X SCBA which have been upgraded shall be certified to the current standard when it is demonstrated that the SCBA, which is currently certified to a previous edition of NFPA 1981, has been upgraded by a qualified individual according to the manufacturer’s instructions and meets the applicable requirements of this standard. (new) 2.2.X The certification organization shall have a program for the testing and certification of SCBA which have been upgraded to meet the requirements of this standard. As a minimum, the program shall include documentation, demonstration and evaluation of the following: a. Requirements for qualification of the SCBA to be upgraded. b. Requirements for qualification of the person to perform the upgrade. c. Specific instructions for performing the upgrade. SUBSTANTIATION: The upgrading of SCBA to meet the requirements of a new Edition of the Standard can generally be accomplished at a lower cost than the purchase of a new SCBA. Thus, upgrading substantially increases the availability of improved technology of the new Edition of the Standard to the Fire Service. The Certification Program would assure that properly qualified SCBA are selected to be upgraded, that the person(s) performing the upgrade are properly qualified to do so, and that the instructions for

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NFPA 1981 — May 2002 ROC— Copyright, NFPAperforming the upgrade are complete, accurate and understandable. The upgrade process as well as the upgraded SCBA should be evaluated by the certification organization to assure full compliance with the standard. After being discussed and agreed upon in several TC meetings, the requirements for the addition of wording covering SCBA upgrades was omitted from the ROP.COMMITTEE ACTION:HoldCOMMITTEE STATEMENT: The comment introduces text and concepts that have not had public review.

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(Log #CC1)1981-4-( Breathing Air, Char, Cylinder, Drip, Facepiece, Gas, Melt, Model, Product Label, SCBA) : Accept in Principle SUBMITTER: Technical Committee on Respiratory Protection and Personal Alarm Equipment, COMMENT ON PROPOSAL NO:1981-23RECOMMENDATION: Adopt the preferred definitions from the NFPA Glossary of Terms for the following terms: Breathing Air (preferred) NFPA 1901, 1999, ed. Air that meets the requirements specified in CGA G-7.1, Commodity Specification for Air, for Grade D and E air for human respiration and NFPA 1500, Standard on Fire Department Occupational Safety and Health Program. Breathing Air (secondary) NFPA 1981, 1997, ed. See Compressed Breathing Gas. Char (preferred) NFPA 921, 1998, ed. Carbonaceous material that has been burned and has a blackened appearance. Char (secondary) NFPA 1981, 1997, ed. The formation of a brittle residue when material is exposed to thermal energy. Cylinder (preferred) NFPA 560, 1995, ed. A portable compressed gas container, fabricated to or authorized for use by the U.S. Department of Transportation (DOT), or fabricated to Transport Canada (TC) or the ASME Boiler and Pressure Vessel Code, Section VIII, Rules for the Construction of Unfired Pressure Vessels. Cylinder (secondary) NFPA 1981, 1997, ed. See Breathing Gas Cylinder. Drip (preferred) NFPA 1914, 1997, ed. A flow of liquid that lacks sufficient quantity or pressure to form a continuous stream. Drip (secondary) NFPA 1981, 1997, ed. To run or fall in drops or blobs. Facepiece (preferred) NFPA 1404, 1996, ed. The component of a respirator that covers the wearer’s nose, mouth, and eyes. It is designed to make a gastight or particle-tight fit with the face and includes the headbands, exhalation valves, and other necessary components required to connect it to a respirable gas source. Facepiece (secondary) NFPA 1981, 1997, ed. The component of an SCBA that covers as a minimum the wearer’s nose, mouth, and eyes. Gas (preferred) NFPA 68, 1998, ed. The state of matter characterized by complete molecular mobility and unlimited expansion; used synonymously with the term vapor. Gas (secondary) NFPA 1981, 1997, ed. A respirable gas mixture stored in a compressed state and supplied to the user in a gaseous form. Melt (preferred) NFPA 1983, 1995, ed. A response to heat by a material, resulting in evidence of flowing or dripping. Melt (secondary) NFPA 1981, 1997, ed. To change from solid to liquid, or become consumed, by action of heat. Model (preferred) NFPA 1971, 2000, ed. The collective term used to identify a group of individual elements of the same basic design and components from a single manufacturer produced by the same manufacturing and quality assurance procedures that are covered by the same certification. Model (secondary) NFPA 1981, 1997, ed. The collective term used to identify identical SCBA of the same basic design from a single manufacturer produced by the same manufacturing and quality assurance procedures that are covered by the same certification. Product Label (preferred) NFPA 1971, 2000, ed. A label or marking affixed to a product by the manufacturer that provides general information, warnings, instructions for care and maintenance, and other information. The product label is not the label, symbol, or identifying mark of other information. The product label is not the label, symbol, or identifying mark of the certification organization; however, the label, symbol, or identifying mark of the certification organization can be attached to, or can be part of, the product label. Product Label (secondary) NFPA 1981, 1997, ed. A label or marking affixed to the SCBA by the manufacturer containing general information, care, maintenance, or similar data. This product label is not the certification organization’s label, symbol, or identifying mark; however, the certification organization’s label, symbol, or identifying mark shall be permitted to be attached to it or be part of it. (See also Labeled.) SCBA (preferred) NFPA 1982, 1998, ed. Acronym for Self-Contained Breathing Apparatus. SCBA (secondary) NFPA 1981, 1997, ed. See self-contained breathing apparatus.

SUBSTANTIATION: Adoption of preferred definitions will assist the user by providing consistent meaning of defined terms throughout the National Fire Codes.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See new Chapter 3 in the ROC preprint that reflects the definitions as given in the glossary of terms for this project.

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(Log #136)1981-5-(Entire Document) : Accept in Principle SUBMITTER: Dennis W. Browner, Scott AviationCOMMENT ON PROPOSAL NO:9181-24RECOMMENDATION: Change all references to “malperformance” to “product nonconformance.” SUBSTANTIATION: Product nonconformance is normally used, malperformance is not defined.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See action taken on 1981-10 (Log #210) where the term “malperformance” has been deleted and new text added.

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(Log #149)1981-6-(Entire Document) : Reject SUBMITTER: Daniel Ryan, Underwriters Laboratories Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Delete 1981-24 (Log #CP2) text in its entirety. SUBSTANTIATION: The introduction of this language is not consistent with, and is not supported by, the scope of the NFPA 1981 standard. The “recall” debate within the NFPA forum is the result of widely disparate views on the subject of PPE protection longevity. What might be viewed as being a product “defect” warranting an industry wide recall by some is considered to be but one of many PPE field degradation modes by others. What is considered “premature failure” to some is considered by others to be within the expected and reasonable “end of service life” period of use. The CP 2 language does nothing to bridge this “opinion gap.” As written, this language would likely require that all PPE be recalled for the simple reason that it all degrades in some form or manner while in fire fighter service. As written, this language is so vague as to possibly preclude third-arty certification entirely.COMMITTEE ACTION:Reject

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(Log #30)1981-7-(1-2.4 (New) ) : Accept SUBMITTER: W. Lee Birch, Luxfer Gas CylindersCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add 1.2.4 annex material to read: “To help guide the purchase of SCBAs, refer to NFPA 1852.” SUBSTANTIATION: Can the Technical Committee find a place to reference NFPA 1852 in NFPA 1981?COMMITTEE ACTION:Accept

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(Log #79)1981-8-(1-5) : Accept in Principle SUBMITTER: Nicholas J. Curtis, Lion Apparel, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Disregard recommended definition of “compliant product”, and amend 1.5.2.14 as follows: Compliant (product): Meeting or exceeding all applicable requirements of this standard. SUBSTANTIATION: Proposed definition in Proposal 1981-24 (Log #CP2) is unnecessary and redundant to official NFPA definition.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: The Technical Committee will remain with the project definition in the glossary.

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(Log #162)1981-9-(1-5) : Reject SUBMITTER: Patricia A. Freeman, Globe Manufacturing Co., Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text as follows: 1.5X Safety Alert. The action by which a manufacturer identifies a compliant product or a component of a compliant product, provides notice to the end users when they are known, and informs the market place and distributors of potential safety concerns regarding the specific compliant product or compliant product component. SUBSTANTIATION: Since a good deal of protective equipment is sold through distributors, manufacturers are not always able to identify the end user. this added verbiage makes it a requirement to notify the end users when they are known.

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NFPA 1981 — May 2002 ROC— Copyright, NFPACOMMITTEE ACTION:RejectCOMMITTEE STATEMENT: In the situation where all concerned parties are not known, a general and public notice must be made in an attempt to reach all affected parties.

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(Log #210)1981-10-(1-5, Chapter 2 and A.2.2.10.7) : Accept in Principle SUBMITTER: Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment, COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: The TCC is submitting the following text to the Technical Committee to incorporate into Section 1.5, Chapter 2, and Annex A as shown. This text that addresses details related to certification organization investigations of product malperformance or failure, and manufacturer product safety alert and product recall systems. The TCC also asks the TC to consider adding further guidelines in annex item A.2.2.10.7 for relating specific design features, performance properties, or attributes to each of the product defect classes currently proposed. This system of classification is intended to assist the certification organization in determining which action is appropriate upon the investigation or product malperformance or failure. Add two new definitions to Section 1.5 to read: 1.5.X Compliant Product(s). A product(s) that is covered by this standard and has been certified as meeting all applicable requirements of this standard that pertain to the product. 1.5.X Safety Alert. The action by which a manufacturer identifies a compliant product or a component of a compliant product, provides notice to the end users, and informs the market place and distributors of potential safety concerns regarding the specific compliant product or compliant product component.× Add new 2.1.1 to read (renumber the existing paragraphs): 2.1.1 The certification process for SCBA as being compliant with NFPA 1981 shall include the requirements of Section 2.1, General; Section 2.2, Certification Program; Section 2.3, Inspection and Testing; Section 2.4, Recertification; Section 2.5, ISO Registration for Manufacturers; Section 2.6, Manufacturer’s Investigation of Returns and Complaints; and Section 2.7, Manufacturer’s Safety Alert and Product Recall Systems. Revise 2.2.10 to read: 2.2.10 The certification organization shall have a program for investigating field reports alleging malperformance or failure of listed compliant products. Add the following new paragraphs, following 2.2.10, to read: 2.210.1 The certification organization shall conduct an investigation when a written, signed complaint is received that alleges a specific malperformance or failure of a specific compliant product or component of a compliant product. 2.210.2 The investigation by the certification organization shall include an initial determination of the validity of the complaint and if compliant product or compliant product component constitutes a potential safety risk to end users. 2.2.10.3 If the certification organization determines the complaint to be valid and determines that the compliant product or compliant product component constitutes a potential safety risk to end users, then the certification organization shall undertake a more detailed investigation that determines the scope and nature of the safety risk, the nature of possible injury or other consequences from using the compliant product in question, and possible causes or circumstances that led to the compliant product’s or compliant product component’s failure or malperformance. 2.2.10.4 The certification organization’s investigation shall include but not be limited to the extent and scope of the problem, as it might apply to other compliant product or compliant product components manufactured by other manufacturers or certified by other certification organizations, and specific testing against the requirements of the standard to which the compliant product was certified. 2.2.10.5 The certification organization shall also investigate complaints of malperformance or failure that are not anticipated by the performance requirements of the relevant standard to determine if the malperformance or failure presents a safety alert or product recall. 2.2.10.6 The certification organization shall require the manufacturer of the compliant product, or the manufacturer of the compliant product component if applicable, to conduct its own investigation as specified in Section 2.6. 2.2.10.7* The certification organization shall prepare a report with the findings of its investigation. The report shall provide one of three conclusions: (1) that no action is required on the part of the certification organization, (2) that the manufacturer shall issue a safety alert, or (3) that the manufacturer shall conduct a recall of the affected product. 2.2.10.8 The certification organization shall provide the report to the organization or individual submitting the complaint and to the manufacturer of the compliant product or compliant product component. Where the report’s findings involve issuing a safety alert or conducting a product recall, the certification organization shall also provide the report to the NFPA. 2.2.10.9 Where the certification organization’s findings conclude that a recall of the affected compliant product will be conducted the product manufacturer, the certification organization shall suspend or terminate the product manufacturer’s listing of the affected compliant product. 2.2.10.10 Where the certification organization’s findings conclude that a component of compliant product is the basis for recall, the certification organization shall suspend or terminate the compliant product manufacturer’s listing for all compliant products from that particular manufacturer which

incorporate the specific component, and shall investigate the use of the specific component by other manufacturers. 2.2.10.11 Where the manufacturer of the compliant product does not comply with the certification organization’s findings, then the certification organization shall be obligated to terminate all of the product listings of compliance with this standard by the certification organization for that product manufacturer.× Revise 2.2.11 to read: 2.2.11 The certification organization shall require the manufacturer to have a product safety alert system and× a product recall system as part of the manufacturer’s quality assurance program. The certification organization shall verify that the manufacturer’s product safety alert and product recall systems meet the requirements specified in Section 2.7.× Add new Sections 2.6 and 2.7 to read: 2.6 Manufacturer’s Investigation of Returns and Complaints 2.6.1 The manufacturer shall provide corrective action in accordance with ISO 9001, Quality Systems – Model for Quality Assurance in Design, Development, Production, Installation, and Servicing, for investigating returned products and written complaints. 2.6.2 Manufacturer records of returns and complaints related to safety issues shall be retained for at least 5 years. 2.6.3 Where the manufacturer, during the review of specific returns or complaints, discovers that a compliant product or compliant product component can constitute a potential safety risk to end users that is possibly subject to a safety alert or product recall, then the manufacturer shall immediately contact the certification organization and provide all information about their review to assist the certification organization with their investigation. 2.7 Manufacturer’s Safety Alert and Product Recall Systems 2.7.1 The manufacturer shall establish a written safety alert system and a written product recall system that describes the procedures it will use in the event that it decides or is directed by the certification organization to either issue a safety alert or conduct a product recall. 2.7.2 The manufacturer’s safety alert and product recall system shall provide: (1) the establishment of a coordinator and responsibilities by the manufacturer for the handling of safety alerts and product recalls; (2) a method of notifying all dealers, distributors, purchasers and end users, and the NFPA about the safety alert or product recall that can be initiated within a one week period following the manufacturer’s decision to issue a safety alert or to conduct a product recall, or after the manufacturer has been directed by the certification organization to issue a safety alert or conduct a product recall; (3) techniques for communicating accurately and understandably the nature of the safety alert or product recall, in particular the specific hazard or safety issue found to exist; (4) procedures for removing product that is recalled and for documenting the effectiveness of the product recall; and (5) a plan for either repairing, replacing, or compensating purchasers for returned product.× Add new A.2.2.10.7 to read: A.2.2.10.7 The determination of the appropriate action for the certification organization to undertake in event that a specific problem is identified should be take into consideration the severity of the problem and its potential consequences to the safety and health of end users. Testing of affected product against the requirements of this standard should be performed to assist in determining the severity of the problem. It is also recognized that safety alerts and product recalls can be determined necessary for problems or circumstances not anticipated by the requirements in this standard. As with other bases for issuance of safety alerts and product recall, the decision to initiate action based on such problems and circumstances should take into consideration the specific safety risks to end users by the affected compliant product or compliant product component(s). As a guideline for determining between a safety alert and a product recall, the following defects affecting compliant product or compliant product component attributes and performance should be classified among the following categories:Critical – a defect that judgment and experience indicate is likely to result in a condition immediately hazardous to life or health for individuals using or depending upon the compliant product (in this case, an SCBA).Major A – a defect, other than critical, that is likely to result in failure to the degree that the compliant product will not provide protection (in this case, an SCBA that will not provide respiratory protection), or a defect that reduces protection and is not detectable by the end user. Major B – a defect, other than critical or Major A, that is likely to result in reduced protection, and is detectable by the end user. Minor – a defect, other than critical, Major A, or Major B, that is not likely to materially reduce the usability of the compliant product for its intended purpose, or a defect that is a departure from established standards and has little bearing on the effective use or operation of the compliant product. The following actions for handling substantiated product defects or product malperformance are recommended: Critical defect: product recall Major A defect: product recall or safety alert depending on the nature of the specific defect Major B defect: safety alert or no action, depending on the nature of the specific defect Minor defect: no action×

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NFPA 1981 — May 2002 ROC— Copyright, NFPASUBSTANTIATION: The current provisions in NFPA 1981, and all other product standards within this Project, are insufficient in specifying when a field investigation is conducted by the certification organization or how the manufacturer is to conduct a product recall when product malperformance or product failure is substantiated. The TCC is providing this text to the TC to provide clear direction on the necessary procedures for the certification organization conduct of a field investigation alleging product malperformance or failure, and to establish minimum requirements of a manufacturer’s safety alert system and product recall system. It is the intent of the TCC that this text, or very similar text, will become a part of the “boilerplate” text of each certification chapter in all product documents within this Project.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See revised text in section 4.6, 4.7 and 4.8 of the ROC preprint.

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(Log #185)1981-11-(1-5, Chapter 2 and Annex A, 2.1.1, 2.7, 2.2.10.1, 2.2.10.11, 2.6) : Reject SUBMITTER: Richard W. Blocker, Jr., DuPont Advanced Fibers SystemsCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: 1. The TCC is submitting the following text to the Technical Committee to incorporate into Section 1.5, Chapter 2, and Annex A as shown. This text that addresses details related to certification organization investigations of product malperformance or failure, and manufacturer product safety alert and product recall systems. The TCC also asks the TC to consider adding further guidelines in annex item A.2.2.10.7 for relating specific design features, performance properties, or attributes to each of the product defect classes currently proposed. This system of classification is intended to assist the certification organization in determining which action is appropriate upon the investigation or product malperformance or failure. Add two one new definitions to Section 1.5 to read: 1.5.X Compliant Product(s). A product(s) that is covered by this standard and has been certified as meeting all applicable requirements of this standard that pertain to the product. 1.5.X Safety Alert. The action by which a manufacturer identifies a compliant product or a component of a compliant product, provides notice to the end users, and informs the market place and distributors of potential safety concerns regarding the specific compliant product or compliant product component. Add new 2.1.1 to read (renumber the existing paragraphs): 2.1.1 The certification process for SCBA as being compliant with NFPA 1981 shall include the requirements of Section 2.1, General; Section 2.2, Certification Program; Section 2.3, Inspection and Testing; Section 2.4, Recertification; Section 2.5, ISO Registration for Manufacturers; and Section 2.6, Manufacturerís Investigation of Returns and Complaints; and Section 2.7, Manufacturerís Safety Alert and Product Recall Systems. Revise 2.2.10 to read: 2.2.10 The certification organization shall have a program for investigating field reports alleging malperformance or failure of listed compliant products. Add the following new paragraphs, following 2.2.10, to read: 2.210.1 The certification organization shall conduct an investigation when a written, signed complaint is received that alleges a specific malperformance or failure of a specific compliant product or component of a compliant product. The certification organization shall promptly notifyt he manufacturer when the certification organization receives a field report alleging malperformance or failure of a specific compliant product or component of a compliant product and shall engage the manufacturer in any investigation. 2.210.2 The investigation by the certification organization and the manufacturer shall include an initial determination of the validity of the complaint and if compliant product or compliant product component constitutes a potential safety risk to end users. 2.2.10.3 If the certification organization determines the complaint to be valid and determines that the compliant product or compliant product component constitutes a potential safety risk to end users, then the certification organization and the manufacturer may shall undertake a more detailed investigation that determines the scope and nature of the safety risk, the nature of possible injury or other consequences from using the compliant product in question, and possible causes or circumstances that led to the compliant productís or compliant product componentís failure or malperformance. 2.2.10.4 The certification organizationís investigation shall include but not be limited to the extent and scope of the problem, as it might apply to other compliant product or compliant product components manufactured by other manufacturers or certified by other certification organizations, and specific testing against the requirements of the standard to which the compliant product was certified. 2.2.10.5 The certification organization shall also investigate complaints of malperformance or failure that are not anticipated by the performance requirements of the relevant standard to determine if the malperformance or failure presents a safety alert or product recall. 2.2.10.65 The certification organization shall may requestire the manufacturer of the compliant product, or the manufacturer of the compliant product component if applicable, to conduct its own investigation as specified in Section 2.6. 2.2.10.67* The certification organization shall prepare a report with the findings of its investigation. The report shall provide one of three the following conclusions:

(1) that no action is required on the part of the certification organization, or

(2) that the certification orgnization is withdrawing its certidication manufacturer shall issue a safety alert, or

(3) that the manufacturer shall conduct a recall of the affected product. 2.2.10.8 7 The certification organization shall provide the report to the organization or individual submitting the complaint and to the manufacturer of the compliant product or compliant product component. Where the reportís findings involve withdrawal of certification issuing a safety alert or conducting a product recall, the certification organization shall also provide the report to the NFPA. 2.2.10.98 Where the certification organizationís findings conclude that a withdrawal of certification recall of the affected compliant product will be conducted the product manufacturer, the certification organization shall suspend or terminate the product manufacturerís listing of the affected compliant product. 2.2.10.10 9 Where the certification organizationís findings conclude that a component of compliant product is the basis for withdrawal of certification recall, the certification organization shall suspend or terminate the compliant product manufacturerís listing for all compliant products from that particular manufacturer which incorporate the specific component, and shall investigate the use of the specific component by other manufacturers. 2.2.10.11 Where the manufacturer of the compliant product does not comply with the certification organizationís findings, then the certification organization shall be obligated to terminate all of the product listings of compliance with this standard by the certification organization for that product manufacturer Revise 2.2.11 to read: 2.2.11 The certification organization shall require the manufacturer to have a product safety alert system and a product recall system as part of the manufacturerís quality assurance program. The certification organization shall verify that the manufacturerís product safety alert and product recall systems meet the requirements specified in Section 2.7. Add new Sections 2.6 and 2.7 to read: 2.6 Manufacturerís Investigation of Returns and Complaints 2.6.1 The manufacturer shall provide corrective action in accordance with ISO 9001, Quality Systems ñ Model for Quality Assurance in Design, Development, Production, Installation, and Servicing, for investigating returned products and written complaints. 2.6.2 Manufacturer records of returns and complaints related to safety issues shall be retained for at least 5 years. 2.6.3 Where the manufacturer, during the review of specific returns or complaints, discovers that a compliant product or compliant product component can constitute a potential safety risk to end users that is possibly subject to a safety alert or product recall, then the manufacturer shall immediately contact the certification organization and provide all information about their review to assist the certification organization with their investigation. 2.7 Manufacturerís Safety Alert and Product Recall Systems 2.7.1 The manufacturer shall establish a written safety alert system and a written product recall system that describes the procedures it will use in the event that it decides or is directed by the certification organization to either issue a safety alert or conduct a product recall. 2.7.2 The manufacturerís safety alert and product recall system shall provide:

(1) the establishment of a coordinator and responsibilities by the manufacturer for the handling of safety alerts and product recalls;

(2) a method of notifying all dealers, distributors, purchasers and end users, and the NFPA about the safety alert or product recall that can be initiated within a one week period following the manufacturerís decision to issue a safety alert or to conduct a product recall, or after the manufacturer has been directed by the certification organization to issue a safety alert or conduct a product recall;

(3) techniques for communicating accurately and understandably the nature of the safety alert or product recall, in particular the specific hazard or safety issue found to exist;

(4) procedures for removing product that is recalled and for documenting the effectiveness of the product recall; and

(5) a plan for either repairing, replacing, or compensating purchasers for returned product. Add new A.2.2.10.76 to read: A.2.2.10.76 The determination of the appropriate action for the certification organization to undertake in event that a specific problem is identified should be take into consideration the severity of the problem and its potential consequences to the safety and health of end users. Testing of affected product against the requirements of this standard should be performed to assist in determining the severity of the problem. It is also recognized that safety alerts and product recalls can be determined necessary for problems or circumstances not anticipated by the requirements in this standard. As with other bases for issuance of safety alerts and product recall, the decision to initiate action based on such problems and circumstances should take into consideration the specific safety risks to end users by the affected compliant product or compliant product component(s). As a guideline for determining between a safety alert and a product recall, the following defects affecting compliant product or compliant product component attributes and performance should be classified among the following categories:

Critical ñ a defect that judgment and experience indicate is likely to result in a condition immediately hazardous to life or health for

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NFPA 1981 — May 2002 ROC— Copyright, NFPAindividuals using or depending upon the compliant product (in this case, an SCBA).

Major A ñ a defect, other than critical, that is likely to result in failure to the degree that the compliant product will not provide protection (in this case, an SCBA that will not provide respiratory protection), or a defect that reduces protection and is not detectable by the end user.

Major B ñ a defect, other than critical or Major A, that is likely to result in reduced protection, and is detectable by the end user.

Minor ñ a defect, other than critical, Major A, or Major B, that is not likely to materially reduce the usability of the compliant product for its intended purpose, or a defect that is a departure from established standards and has little bearing on the effective use or operation of the compliant product. The following actions for handling substantiated product defects or product malperformance are recommended:

Critical defect: product recallMajor A defect: product recall or safety alert depending on the nature

of the specific defectMajor B defect: safety alert or no action, depending on the nature of

the specific defectMinor defect: no action

SUBSTANTIATION: Our suggested changes to the proposed language in NFPA 1981 - 24 - November 2001 ROP are motivated by a number of concerns. The most fundamental is that none of the NFPA, its members, or the certification organization has power to make a NFPA member issue a Safety Alert or a product recall: their powers are limited to denying membership status to a manufacturer and withdrawing certification. Therefore, it is inappropriate and risky for the NFPA to adopt language that gives apparent authority to itself via the certification organization when there is no real power to enforce orders to issue Safety Alerts or product recalls. Potentially, third parties, relying upon the apparent authority attributed to NFPA, et. al., could argue that the NFPA, its members, and the certification organization have liability for not enforcing orders to the affected member to issue Safety Alerts or initiate product recalls. The NFPA should avoid such a Catch-22 conundrum. Another concern is that determining whether a recall is an appropriate action is highly dependent upon the unique fact situations presented. Reasonable minds can differ as to whether a recall in necessary and appropriate. NFPA should not hold itself out as an authority on the proper methodology to determine the appropriateness of Safety Alert or a product recall or to order a member to take these actions when courts, the government, the affected member, and other reasonable parties could easily differ regarding the proper methodology, the pertinent facts, the relative importance of the facts, and the ultimate decision reached. Without the subpoena power of the government to access all potentially pertinent information, including trade secrets, the NFPA and the certification organization will not be able to make good decisions about the necessity for a Safety Alert or a product recall. Because of the factual complexities of each individual situation, the legal duty to recall is exceedingly rare and the Third Restatement of Torts (Chapter 2, Section 11) attributes liability related to recalls only if a seller fails to recall in compliance with a governmental directive, or, if a seller, in the absence of governmental directive, voluntarily recalls in an unreasonable way. It is not sensible for NFPA to attempt to make Safety Alert and recall determinations when it is unlikely to be able access all facts, when the law does not presume a duty to recall absent a government directive, and when making these determinations likely will subject NFPA members to double standards on issues over which reasonable minds can differ. Last, given the complexity of the various factual situations that may arise, it is inappropriate for NFPA to address how members should investigate returns and complaints. ISO 9001 already provides guidance and there is no advantage in creating a double standard.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: Although the committee feels that many of the submitter’s concerns have been addressed in actions to many comments, but especially in the actin on 1981-10 (Log #210), the committee has rejected their comment as the submitter incorrectly sees NFPA as an “enforcing authority”. The committee has used international standards that address these issues as the basis for the applicable text in NFPA 1981.

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(Log #68)1981-12-(1-5,x Safety Alert) : Accept in Principle SUBMITTER: Ross Cochran, Securitex Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: “The action by which a manufacturer identifies a compliant product or a component of a compliant product, provides notice to the end users, and informs the market place and distributors of potential safety risks concerns regarding the specific compliant product or compliant product component.” SUBSTANTIATION: “Potential safety concerns” are too vague to be the subject of safety alerts. A genuine risk to the safety of the firefighter is worth a safety a alert. “Potential safety concerns” should be addressed by the documentation provided by the manufacturer in accordance with Section 3.2 User Information.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See action taken on Comment 1981-10 (Log #210).

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(Log #80)1981-13-(1-5 Product Hazard.XX (New) ) : Reject SUBMITTER: Nicholas J. Curtis, Lion Apparel, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add new definition to read as follows: Product Hazard. (1) a failure to comply with an applicable consumer product safety rule, or the NFPA Standard under which the product was produced, and which creates a substantial risk of injury to the public end user. (2) A product defect which (because of the pattern of defect, the number of defective products distributed in commerce, the severity of the risk, or otherwise) creates a substantial risk of injury to the public end user. SUBSTANTIATION: Differentiates from product flaws, defects, or perceived failures which may not necessarily be safety issues.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The meaning of “hazard, with respect to a certified product...” is covered in the new text 2.2.11.3 in action taken on Comment 1981-10 (Log #210).

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1981-14-(1-5 Recall (New) ) : Reject SUBMITTER: Bill Grilliot, Morning Pride Mfg Co.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add definition for “recall” as found in NFPA 1971/2000 ed. SUBSTANTIATION: Definition is needed for proper interpretation of a recall within this standard.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: ISO 27 holds the definition for recall and ISO 27 is a mandatory reference in this standard.

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(Log #52)1981-15-(1-5 Specified Service Life—-Time (New) ) : Accept in Principle SUBMITTER: Bill Grilliot, Morning Pride Mfg Co.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add definition for “Specified Service Life—-Time, exposure event, or number of uses to which a compliant product or component is expected to remain functional.” SUBSTANTIATION: Definition is needed for proper interpretation within Log 1981-24 and to be consistent with NFPA 1852 SCAM.COMMITTEE ACTION:Accept in Principle Add new definition to read: “Service Life. The period for which a certified product is useful before retirement.”COMMITTEE STATEMENT: The Committee used the definition from the glossary of terms for this project.

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1981-16-(1-5.2.1 Accessory) : Accept in Principle SUBMITTER: K. R. Ethridge, Texas Commission on Fire ProtectionCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: 1.5.2.1 Accessory. An item, provided by the manufacturer for use with its an SCBA but that is not necessary for the SCBA to meet the requirements of this standard. SUBSTANTIATION: Section 1.5.2.1 currently restricts the definition of accessory to only those items that are provided by the manufacturer. This definition is not consistent with the definition of accessory in other standards in this project and ignores the fact that accessories may be provided by other than the SCBA manufacturer.COMMITTEE ACTION:Accept in Principle Revise 1.5.2.1 to read: Accessory. An item, or items, that are attached to the certified product that are not necessary to meet the requirements of the standard.COMMITTEE STATEMENT: The Committee revised the definition to be consistent with the glossary of terms for this project.

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1981-17-(1-5.2.4.7) : Accept in Principle SUBMITTER: Robert Sell, David Hodson, Draeger Safety, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read: “An atmosphere supplying respirator that supplies a respirable atmosphere to the user from a combination of two breathing air source that is independent of the ambient environment, one of which is a long duration source that is not designed to be carried by the user and the second of which is a shorter duration source that is designed to be carried by the user. For the ...” SUBSTANTIATION: NIOSH and OSHA statements only identify the SAR as an independent air source that is not designed to be carried by the user, and not for use in IDLH atmospheres.COMMITTEE ACTION:Accept in Principle Revise to read: “Supplied Air Respirator. An atmosphere-supplying respirator for which the source of breathing air is not designed to be carried by the user. Also known as an “airline respirator.”COMMITTEE STATEMENT: The Committee revised the definition to be compatible with the NIOSH definition.

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NFPA 1981 — May 2002 ROC— Copyright, NFPA(Log #91)

1981-18-(1-5.2.8 Breathing Air/Gas Cylinder) : Accept SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise definition to read as follows: 1.5.2.8 Breathing Air/Gas Cylinder. See 1.5.2.8 1.5.2.7, Breathing Air Cylinder. SUBSTANTIATION: Incorrect reference.COMMITTEE ACTION:Accept

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(Log #25)1981-19-(1-5.2.10 Certification Organization) : Reject SUBMITTER: W. Lee Birch, Luxfer Gas CylindersCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add to end of definition: For the purposes of 2.10, the Certification Organization is the organization that determined the product’s compliance, or, if no longer in business, is the Certification Organization currently determining compliance for the manufacturer’s product.” SUBSTANTIATION: The TCC proposals in 2.10 have given new requirements to the Certification Organization (CO). But, the CO that originally determined the product’s compliance may no longer be in business? Then what CO will do the investigation? What if the product manufacturer has changed COs? Which CO should conduct the investigation? It is possible that a ‘dumped’ CO may investigate malperformance reports with bias. The above wording is suggested to clarify the CO referred in 2.10.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The standard can not require another entirety to assume the responsibilities of another certification organization.

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1981-20-(2-1) : Accept SUBMITTER: Technical Committee on Respiratory Protection and Personal Alarm Equipment, COMMENT ON PROPOSAL NO:1981-3RECOMMENDATION: Reverse the Committee’s action on ROP 1981-3 (Log 3) from “reject” to an “accept in principle” and add new text for a universal air connection for rapid intervention companies and crews that would allow emergency replenishment of breathing air to the SCBA of disabled or entrapped fire or emergency services personnel. SUBSTANTIATION:COMMITTEE ACTION:AcceptSee Section 6.4 and 7.15.COMMITTEE STATEMENT: During the public comment period on NFPA 1981 ROP, the Committee was asked to reconsider its action on ROP 1981-3 (Log 3). During the actions on Proposals, the Committee rejected ROP 1981-3 (Log 3) due to the emphasis put on “buddy breathing” systems. NIOSH does not permit or certify any “buddy breathing” systems that would allow two users to share a single air source. Since NFPA 1981 requires NIOSH certification as a “prerequisite” to becoming certified as compliant with NFPA 1981, the Committee could not adopt text that would be in violation of NIOSH regulations. The Committee heard from fire service users that felt that this was an important issue and that the submitter, while using the term “buddy breathing,” was also trying to get across the need for being able to supply a depleted SCBA with breathing air while the wearer remains trapped or unable to be removed from the hazardous atmosphere. Many fire departments and hazmat teams refer to such a system as part of their RIC gear (RIC, rapid intervention company or crew; RIT, rapid intervention team; FAST team or crew, etc.) for rescuing trapped or injured fire fighters. The main problem is involves multiple departments at an incident who use different SCBA. The RIC has to carry different connections in order to be able to make a connection to the SCBA and replenish the breathing air supply. The Committee studied the issue and agreed to attempt to develop workable text for NFPA 1981 that would be acceptable to NIOSH. The Committee approached NIOSH and sought their cooperation in addressing this issue. NIOSH was extremely cooperative and assisted the Committee in drafting text that will provide for this RIC universal air connection system. The text in this Committee Comment establishes a single, universal air connection that will be provided on all new SCBA, and existing SCBA could be upgraded to have this connection, that will allow the breathing air cylinder of the SCBA worn by the trapped or injured person to be replenished with breathing air from another breathing air cylinder or by an air line supplying breathing air. This is not taking breathing air from an SCBA being used by a person involved in the operation, but is a source of “rescue” breathing air. The Committee thanks the fire service personnel who took a strong position in this issue and supported the work through the committee process. The Committee also expresses it thanks and gratitude to Richard Metzler, Director of the NIOSH Personal Protection Laboratories in Pittsburgh, PA for the cooperation and assistance that made this new requirement possible.

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(Log #92)1981-21-(2-1.4) : Accept SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: All certification to this standard shall be performed by a certification organization that meets at least the requirements specified in Section 2.2, and that is accredited for personal protective equipment in accordance with ANZI Z34.1, American National Standard for Third Party Certification Programs for Products, Processes, and Services ISO/IEC Guide 65:1996, General Requirements for Bodies Operating Product Certification Systems. SUBSTANTIATION: Revised reference to ISO Guide 65, which is the document now used by ANSI to accredit Third Party Certification Organizations.COMMITTEE ACTION:Accept

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(Log #122)1981-22-(2-1.4.1) : Accept in Principle SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add new text to read as follows: 2.1.4.1 All certification organizations issuing certifications for products conforming to this standard shall have in place a series of procedures which address report(s) of misuse of its registered trademark of conformity or situation(s) in which a certified product is subsequently found to be hazardous. These procedures shall be in accordance with ISO/IEC Guide 27, Guidelines for Corrective Action. If Paragraph 2.1.4.1 is accepted, all of Paragraphs 2.2.10.1 through 2.2.10.11 shall be deleted. In addition, a reference to ISO/IEC Guide 27 shall be added to the “references” section of the standard. SUBSTANTIATION: We are proposing that wording be added to NFPA 1981 which references ISO/IEC Guide 27:1983, Guidelines for Corrective Action, for the handling of recalls of certified products. ISO/IEC Guide 27 is an international consensus document which serves to: “identify a series of procedures which a national certification body (non-governmental) consider in deciding how to respond to: a.) a reported misuse of its registered mark of conformity, or b.) a situation in which a certified product is subsequently found to be hazardous.” The addition of wording into NFPA 1981 which references an internationally accepted consensus document addressing the issues of 1) the misuse of certification marks and 2) certified product which is subsequently found to be hazardous negates the need for the proposed TCC wording as shown in new Paragraphs 2.2.10.1 through 2.2.10.11. Each item anticipated by the proposed TCC wording is addressed by ISO/IEC Guide 27. In fact, ISO/IEC Guide 27 is referenced in ISO/IEC Guide 65, General Requirements for Bodies Operating Product Certification Systems. And since ISO/IEC Guide 65 is replacing the current reference in NFPA 1981 requiring that certification organizations be accredited to ANSI Z34.1, a system of certification organization accountability× for recalls is introduced. As currently written, there is no method for certification organization accountability with respect to recalls and the enforcement of the TCC’s proposed Paragraphs 2.2.10.1 through 2.2.10.11 into NFPA 1981. However, with the addition of new Paragraph 2.1.4.1 (and the subsequent removal of Paragraphs 2.2.10.1 through 2.2.10.11) the certification organization’s program is strengthened since accreditation bodies (i.e. ANSI) shall be reviewing the certification organization’s documentation relating to the handling of instances of misuse of certification marks and hazard reports. If there is ever a situation where a member of the public does not believe an accredited certification program is operating in compliance with ISO Guide 65, a complaint may be filed with the accreditation body. The complaint would trigger an investigation by the accreditation body. This investigation could ultimately lead to suspension or termination of the certification organization’s accreditation if (per ANSI’s Manual of Operations for Accreditation of Certification Programs): “6) The certification body fails to take corrective actions with respect to deficiencies in its program that have been requested by ANSI.” In summary, the issues of misuse and hazards associated with certified products is not unique to the NFPA, and these issues have already been addressed in an Internationally accepted document. The wording Proposed by the TCC is unnecessary, given the fact that ISO/IEC Guide 27 exists. In the end, the real reason for adding the proposed recall wording is to keep hazardous products out of service...and ISO/IEC Guide 27 serves this purpose.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See action taken on Comment 1981-10 (Log #210).

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(Log #8)1981-23-(2-1.8) : Reject SUBMITTER: Robert Sell, David Hodson, Draeger Safety, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Remove the entire paragraph. SUBSTANTIATION: This paragraph does not pertain to NFPA 1981.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: See action taken on Comment 1981-25 (Log #190).

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NFPA 1981 — May 2002 ROC— Copyright, NFPA(Log #41)

1981-24-(2-1.8) : Reject SUBMITTER: K. R. Ethridge, Texas Commission on Fire ProtectionCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Delete the following and renumber: 2.1.8 The certification organization shall not certify any structural protective ensembles or individual elements of the structural protective ensemble to the 1997 edition of NFPA 1971, Standard on Protective Ensemble for Structural Fire Fighting, on or after September 1, 2000. SUBSTANTIATION: I believe this section was inadvertently added to this standard when other boilerplate text was pasted into this standard in an attempt to standardize standards in this project. This wording pertains to protective clothing and is not appropriate in this standard.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: See action taken on 1981-25 (Log #190).

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(Log #190)1981-25-(2-1.8) : Accept in Principle SUBMITTER: Robert W. O’Gorman, Intertek Testing Services/ETL SEMKOCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Change Section 2.1.8 to read: “This certification organization shall not certify any Open-Circuit Self-contained Breathing Apparatus to the 1997 edition of NFPA 1981 standard on Open-Circuit Self-Contained Breathing Apparatus for Fire and Emergency Services on or after 1 September 1 2002.” SUBSTANTIATION: Section 2.1.8 refers to NFPA 1971 not NFPA 1981 as was intended.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See 4.1 in ROC preprint.

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(Log #152)1981-26-(2-1.11) : Reject SUBMITTER: Vance Kochenderfer, CairnsAir, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add the following at end of section: “This requirement shall not apply to SCBA which are in the possession of the manufacturer but do not belong to the manufacturer or its representatives.” SUBSTANTIATION: The existing wording could be interpreted that SCBA which have been returned to the manufacturer by a customer for service or other reasons are ‘under the control” of the manufacturer and must have the product or certification label removed. I believe this is not the intent of the Technical Committee.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The committee will use the boilerplate text provided for all TC in this Project as shown in the ROP.

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(Log #29)1981-27-(2-2.10) : Accept in Principle SUBMITTER: W. Lee Birch, Luxfer Gas CylindersCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Give the current wording a new 2.2.x number. SUBSTANTIATION: TCC proposal is to reword 2.2.10 with the proposed text. Thus, all the current 2.2.10 and 2.2.10.x text is removed/deleted from the standard. Is not the current 2.2.10 and some 2.2.10.x text still the required activity of the certification organization? The intent of the proposal above is to keep the current text, but to renumber it in the document, rather than replace or delete it.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See action taken on Comment 1981-28 (Log #54).

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(Log #54)1981-28-(2-2.10) : Accept SUBMITTER: Bill Grilliot, Morning Pride Mfg Co.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: The TCC notes to revise 2-2.10 really relate to 2-2.11 in the ROP. SUBSTANTIATION: Editorial—-2.2.10 should remain as in ROP and revisions made to 2-2.11.COMMITTEE ACTION:AcceptCOMMITTEE STATEMENT: Now 4.2.10, 4.6, 4.7, and 4.8 in ROC preprint.

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(Log #55)1981-29-(2-2.10) : Reject SUBMITTER: Bill Grilliot, Morning Pride Mfg Co.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Change “field report” to “written, signed complaint.”

SUBSTANTIATION: This change would make the document more consistent.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The Technical Committee believes that any complaint received should be heard by the certification organizations and the certification organizations can inform the reporter what the reporter have to provide so that the investigation can begin. A telephone call or e-mail may be the first tip-off to a legitimate problem and should not be ignored at that point. The certification organization can require the reporter to send a written, signed complain or other means that sets for the known or perceived problems.

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(Log #71)1981-30-(2-2.10) : Accept in Principle SUBMITTER: Ross Cochran, Securitex Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: “The certification organization shall have a program for investigating field reports alleging malperformance or failure of manufacturing or design or defects in listed compliant products.” SUBSTANTIATION: a) Neither the Oxford English Dictionary nor Webster’s Dictionary recognize or define the word ‘malperformance’. This committee should not be asked to coin and define new words. b) Since all things eventually fail - and since 1.3.2 of this standard says “This standard shall apply to the design, manufacturing, and certification of new open-circuit SCBA - the word ‘failure’ is inappropriate. I believe that what we want to do is provide for the taking of appropriate measures when it is discovered that a product had a defect at the time of its certification - i.e. when it was new - that poses a probable safety hazard. ‘Manufacturing defect’ and ‘design defect’ are words and concepts that are widely used and understood in the realm of manufacturers’ responsibility and liability. And by using the concept of a manufacturing or design defect at the time of certification, one does not actually have to wait for an instance of malperformance or failure before instituting the appropriate warning or recall. The use of the words “manufacturing or design defect” also avoids the problem of the NFPA and the certification organization being accused of hypocrisy or negligence. For instance, if is determined that an SCBA fails to consistently provide positive pressure, this failure is clearly the result of a manufacturing or design defect in the SCBA at the time of its certification to the current standard. A safety warning or product recall could then be issued without affecting the status of SCBA made to previous revisions of the standard. If, on the other hand, one retains the concept of malperformance or failure, and one says that such a malperformance - in this example, failure to consistently provide positive pressure - constitutes a safety hazard for which the SCBA must be recalled, the certification organization must logically order the recall of all SCBA not providing consistent positive pressure. Such a recall therefore would have to include all negative pressure SCBA still in use. To do otherwise would imply that the safety of a firefighter using a newer positive pressure SCBA was more important than the safety of a firefighter using an older negative pressure SCBA. It was surely not the intention of the Technical Committee of NFPA 1981, or the wish of the fire service in general, to create such a circumstance. (Had the language of Log CP#2 existed in the previous edition of NFPA 1971, a similar circumstance could have arisen in the case of Breathe-Tex. It was reported that Breathe-Tex moisture barriers appeared to degrade or fail more quickly than was deemed acceptable. Some parties then said that all Breathe-Tex moisture barriers should be recalled because they might no longer provide protection from blood-borne pathogens and would hence pose a safety hazard to firefighters. However, it was also known that neoprene moisture barriers - certified to previous editions of NFPA 1971 for which blood-borne pathogen protection was not a requirement - were incapable of providing blood-borne pathogen protection even at the time of certification. Had a recall been ordered based on malperformance, rather than on the basis of a manufacturing or design defect, it should have been necessary to recall every turnout suit using neoprene. To do otherwise would have implied that it was acceptable for firefighters using older gear to run the risk of being exposed to blood-borne pathogens but unacceptable for those wearing gear certified to the most recent revision of the standard.)COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See action taken on Comment 1981-10 (Log #210). The term “malperformance” has been deleted and replaced with new text.

————————————————-(Log #140)

1981-31-(2-2.10) : Accept in Principle SUBMITTER: Dennis W. Browner, Scott AviationCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise 2.2.10 to: The certification organization shall have a program for investigating field reports alleging malperformance product nonconformance or failure of listed compliant products to comply with this standard. SUBSTANTIATION: The word malperformance is not defined.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See action taken on Comment 1981-10 (Log #210).

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463

NFPA 1981 — May 2002 ROC— Copyright, NFPA(Log #160)

1981-32-(2-2.10) : Reject SUBMITTER: Denise N. Statham, Southern Mills, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Delete the entire section. SUBSTANTIATION: “Field reports” implies that used or previously issued compliant products will be examined. If so, by what standard will the performance be measured? NFPA standards as written qualify only new products.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The Committee willl not delete the section as investigating product hazards is essential in providing adequate protective equipment. See Section 4.6, 4.7, and 4.8 in the ROC preprint.

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(Log #163)1981-33-(2-2.10) : Accept SUBMITTER: Patricia A. Freeman, Globe Manufacturing Co., Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text as follows: “The certification organization shall have a program for investigating field reports alleging malperformance or failure of listed complaint products.” SUBSTANTIATION: Neither Funk & Wagnalls, nor Webster’s Dictionaries include a definition for malperformance. Although this word has appeared in previous editions of the standard, it is not recognized as a word and has never been defined. Since I do not think any NFPA committee has the authority or experience to invent words, I do not believe this word belongs in a product standard, and removing it does not change the meaning.COMMITTEE ACTION:Accept

————————————————-(Log #204)

1981-34-(2-2.10) : Accept in Principle in Part SUBMITTER: Denise N. Statham, Southern Mills, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: “The certification organization shall have a program for investigating field reports alleging non-compliance malperformance or failure of listed compliant products at the time they were sold.” SUBSTANTIATION: The terms “malperformance” and “failure” are not defined. Malperformance and failure of a product may mean that it is just worn out. A product that is compliant with an NFPA standard must meet the requirements of that standard when it is new, not after field use.COMMITTEE ACTION:Accept in Principle in Part 1. Accept in principle the term “malperformance” has been eliminated. 2. Reject the addition of the text “at the time they were sold” COMMITTEE STATEMENT: 1. See action taken on Comment 1981-10 (Log #210). 2. The definition of complaint adequately cover the term.

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1981-35-(2-2.10, 2.2.11, 2.6 and 2.7) : Reject SUBMITTER: David H. Baker, Thompson Hine & Flory LLPCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Propose that Section 2.2.10, 2.2.11, 2.6, and 2.7 of the proposed document be replaced as follows: Alternative Corrective Action Program For Personal Protective Equipment 1. Definition of Product Defect Newly manufactured Personal Protective Equipment shall be deemed to contain a defect, when because of the pattern of defect, the number of defective products distributed in commerce and the severity of the risk involved, the product creates a substantial risk of injury to the user. Severity of risk is measured by degree of injury; for example, a standard CPSC measure is hospitalization and/or days out of work. 2. Remedies When the analysis performed pursuant to Section 3, infra, reveals a substantial risk of injury to the user, as defined in Section 1, supra, the manufacturer shall undertake one of the three following remedies, in its discretion: (a) Safety alert and/or public education effort (b) Recall and replacement of product (c) Recall and refund of price of product, with reasonable allowance for depreciation. 3. Manufacturer Does Analysis; /Attorney/Client Privileged Upon receipt of credible information of serious injury, the manufacturer, in conjunction with legal counsel, shall conduct an analysis of claims, complaints, or other evidnce of product defect, as defined in Section 1, supra. The manufacturer’s report containing such analysis or any conclusions drawn therefrom is privileged under the attorney-client and/or work product privileges. If the manufacturer concludes that corrective action is required, the manufacturer shall follow one of the remedies listed in 2a, b or c above. 4. Final Remedy is in Courts If any firefighter, firefighter organization, union, or any other person disputes the manufacturer’s action, such person’s recourse, if any, shall be by way of legal action initiated in the courts. 5. Old Product is Grandfathered Fire protective gear manufactured prior to the date of this standard is subject

to existing law. SUBSTANTIATION: The proposed recall standard is overly broad in its definition of a non-compliant product and in addition is inefficient by delegating the enforcement of an NFPA standard to a separate, independent organization for enforcement, which enforcement is in turn subject to an overlay of US law and regulation. In addition, the proposed recall standards will create significant liability problems for manufacturers, resulting in little incentive for the manufacturers to fully cooperate with the requirements of the standard. The proposed language adapts the CPSA recall provisions to an NFPA context. The CPSC recall standard is the most widely used recall standard in the United States and is not only simple, understandable and practical, but also has an existing history of interpretation by the agency and the courts. Committee document 1981-01FM-TCC ROP was brought to my attention by another member of NFPA. As a long time practitioner in safety law, it was somewhat surprising to me that the TCC is proposing an entirely new recall procedure to be monitored by a third party certification organization. By ceding authority to a third party such as UL, manufacturers subject to NFPA 1981 will be giving up certain basic rights provided under normal civil law in the United States. First, the incident reports provided to the third party may lose their attorney-client privilege and create liability problems for manufacturers. Second, there will be little incentive for manufacturers to turn information over to a third party which is both fact-finder and judge. Third, it is Rube Goldberg-like for an organization such as NFPA to draft a standard, then to have another organizations such as UL enforce the standard, and then to have an overlay of U.S. law and regulation. It would be far more practical to have a simple standard based on U.S. law. Fourth the proposed definition on non-compliant product in the document is so overly broad that it includes any claim (warranty, refund or liability), making every product manufactured subject to recall by UL. In my judgment, it is inefficient to create an entirely new set of procedures when there is a much simpler and fairer standard unsure existing federal law. Section 15 of the Consumer Product Safety Act (15 U.S.C. Paragraph 2064) has been sued for recalls of products for the past twenty-nine years. More recalls are conducted under the Consumer Product Safety Act than any other law in the country. Section 15 has the benefit of being simple, understandable, and with substantial precedential value in that it has been interpreted by the agency and courts since 1972. It would seem to bear perfect application to these circumstances. Note: Supporting material available for review upon request at NFPA headquarters.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The committee has referenced international standards that cover these issues and appropriately applied their provisions within NFPA 1981. The issues of product defect, analysis, and remedies are all covered by the revised text in action taken on Comment 1981-10 (Log #210). The legal aspects of the comment are not appropriate for this tandard as they will be part of any legal action that could be brought.

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1981-36-(2-2.10.1) : Reject SUBMITTER: Ross Cochran, Securitex Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: “A recognized third-party investigative body The certification organization shall conduct an investigation when a written, signed complaint is received that alleges specific mal performance or failure of a specific compliant product or component of a compliant product.” SUBSTANTIATION: a) Conflict of Interest The certification organization certifies products and components to the standard and performs periodic assessments of continued compliance of those components and elements. This role places the certification organization in two possible situations of conflict of interest if 2.2.10.1 is accepted. First, because the certification organization certified the product that is the subject of the complaint - and is paid by the manufacturer for the original certification thereof - the argument can be made that the certification organization should have detected the possibility of mal performance or failure at the time of initial certification or retesting. Some persons may therefore feel that for fear of incriminating itself and of offending the manufacturers, on whom it depends for business, the certification organization will hesitate to conclude that a product has malperformed or that it constitutes a safety risk. The second possible conflict of interest arises when, for fear of being held liable for not ordering a recall of a product that creates a “potential” safety hazard, or for fear of being accused of being in the aforementioned conflict of interest, or for fear of being removed by NFPA as the certification organization for failure to act, the certification organization will err on the side of caution and order safety warnings or product recalls when they are not warranted. b) Competence Certification organizations certify whether or not a submitting party’s product passes or fails the performance or design requirements of a standard. Rarely do certification organizations have the experience, the resources of the skills to properly conduct an investigation of the importance being proposed in Log #CP2.

464

NFPA 1981 — May 2002 ROC— Copyright, NFPACOMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The committee does not agree with the conflict of interest argument. The provisions in Section 2-2 address possible conflict of interest issues. The certification organization is the responsible entity. The certification organization is required to be “accredited” in accordance with ISO 65, which in turn requires they have “recall” procedures in accordance with ISO 27. Nothing prevents the certification organization from using an investigative body.

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(Log #144)1981-37-(2-2.10.1) : Accept in Principle in Part SUBMITTER: Daniel Ryan, Underwriters Laboratories Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise as follows: 2.2.10.1 The certification organization shall conduct an investigation when a written, signed complaint is received that alleges a specific malperformance of failure of a specific compliant product or component of a compliant product fails to meet one or more of the requirements contained in the specific standard edition to which the product was certified. SUBSTANTIATION: The requirements contained in the standard to which the product was certified represented the nationally recognized minimum requirements appropriate for the product at the time it was produced. While performance complaints outside the scope of the standard may warrant investigation by the safety community (including manufacturers, users, and certification organizations), requirements for these investigations do not belong in this standard and the investigations should not be the sole responsibility of certification organizations.COMMITTEE ACTION:Accept in Principle in Part 1. Accept in principle. Delete malperformance and failure. 2. Reject.COMMITTEE STATEMENT: The committee feels that complaints must be able to exceed safety issues of a particular standard edition and has revised text to reflect this. The certification organization can include whatever additional resources they feel necessary in order to have a complete investigation. ISO 27 includes procedures for a “producer of a subsequently hazardous product” to be included in product compliant investigations and action as necessary.

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1981-38-(2-2.10.1) : Accept SUBMITTER: Bill Burke, Fire-Dex, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: The certification organization shall conduct an investigation when a written, signed, complaint is received that alleges a specific failure of a specific malperformance or complaint product or component of a complaint product. SUBSTANTIATION: Malperformance is not a word in the dictionary, per Websters latest edition.COMMITTEE ACTION:AcceptCOMMITTEE STATEMENT: See action taken on Comment 1981-10 (Log #210). The term “malperformance” has been deleted.

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1981-39-(2-2.10.1) : Accept in PrincipleSUBMITTER: Patricia A. Freeman, Globe Manufacturing Co., Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Delete text as follows: “The certification organization shall conduct an investigation when a written, signed, complaint is received that alleges a specific malperformance or failure of a specific complaint product or component of a compliant product.” SUBSTANTIATION: Delete reference to malperformance. Neither Funk & Wagnalls, nor Webster’s Dictionaries include a definition for malperforamnce; even my computer program, Microsoft Word 2000 does not recognize this word. although this term has appeared in the previous edition of the standard, it is not recognized as a word and unless NFPA intends to add a definition, it does not belong in a product standard.COMMITTEE ACTION: Accept in PrincipleCOMMITTEE STATEMENT: The term “malperformance” has been deleted. See Section 4.6 in the ROC preprint to see the revised text.

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(Log #175)1981-40-(2-2.10.1) : Accept in Principle in Part SUBMITTER: Joey K. Underwood, Safety Components Fabric, Technologies, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise 2-2.10.1 to read as follows: “The certification organization manufacturer shall conduct an investigation when a written, signed complaint is received that alleges a specific malperformance product failure or failure of a specific compliant product or component of a complaint product.” SUBSTANTIATION: 1. No third party certification organization has the

proper resources, authority, component expertise or product failure analysis to render a qualified root cause analysis for every problem in very certified component. 2. The use of a third party organization for each problem, even when the problem is not valid, is not cost effective. 3. Who is best able to decide if the problem is “just an unhappy customer”.COMMITTEE ACTION:Accept in Principle in Part 1. Accept in principle deletion of the term “malperformance” 2. Reject changing to term “manufacturer.”COMMITTEE STATEMENT: 1. The term has been deleted and new text provided in action taken on Comment 1981-10 (Log #210). 2. The committee disagrees that the responsibility of the manufacturer but that of the certification organization in determining product compliance.

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(Log #24)1981-41-(2-2.10.1 (New) ) : Accept in Principle SUBMITTER: W. Lee Birch, Luxfer Gas CylindersCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add text to read as follows: “The certification organization shall notify the product manufacturer, product component manufacturer, and NIOSH, and shall conduct an investigation when a written...” Add at the end of the paragraph: “The certification organization shall keep informed the product manufacturer, product component manufacturer, and NIOSH through each step of the investigative and reporting processes.” SUBSTANTIATION: This paragraph should include wording which is to notify the product manufacturer, component manufacturer (if one exists), and NIOSH in addition to the other requirements, when an investigation has begun, throughout the course of the investigative and reporting processes.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See action taken on Comment 1981-10 (Log #210).

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(Log #132)1981-42-(2-2.10.1-2.2.10.7) : Accept in Principle SUBMITTER: Janice C. Bradley, International Safety Equipment Association -ISEACOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Insert after Section 2.2.10.7: Where the certification organization’s findings do not conclude the same action as the manufacturers findings, an appeal by the manufacturer to the certification organization will commence that provides the manufacturer the opportunity to support their conclusions and offer any action if appropriate. SUBSTANTIATION: ISEA believes the proposed procedure does not provide a manufacturer adequate “due process” protection with regard to any determination by a certification organization concerning its product, and that the penalties imposed by the proposal are punitive and inhibit trade. Section 2.2.10.1 of the proposal specifies how a certification organization must respond once it receives a complaint alleging a specific malperformance or failure to meet a standard by a product or component of a product. The proposal directs the certification organization to investigate and, using its own judgment, determine whether the claimed malperformance or failure exists and the gravity of the problem (Sections 2.2.10.4-5). Although the procedure requires the manufacturer conduct its own investigation (Section 2.2.10.6), it is silent as to how the certification organization is to deal with the manufacturer’s investigational results before reaching its own “final” determination. Specifically, Section 2.2.10.7 simply directs the certification organization to prepare a report of its findings, including the mandated remedy (e.g., having a manufacturer recall or publish a “ safety alert”). The determination to have a recall or to require a manufacturer to publish a “safety alert” (defined in proposed Section 1.5.X), can have a significant economic impact on a manufacturer. Consequently, acting upon a hasty or a not fully supported conclusion could lead to potential liability for the certification organization and the standards writing organization (which courts have increasingly been likely to find responsible for the consequences of deficient enforcement procedures or negligent standards writing). In other words, all avenues of consideration and appeal should be exhausted before a certification organization has the ability to seek a safety alert or recall. The procedures in the standard from “investigating” to “remedying” a “failure or malperformance” lacks essential protection for all parties in interest: How much time is a manufacturer given to conduct its investigation? In what manner and form shall the manufacturer’s conclusions be submitted to the certification organization? What weight will be given the manufacturer’s report? What appeal procedure exists for a manufacturer whose conclusions are opposite those of the certification organization prior to× the certification organization imposing a remedy under Section 2.2.10.7? Although the proposal attempts to provide a manufacturer with some “due process” rights, it is clearly deficient for failing to address these issues.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See 2.2.11.7 in action taken on Comment 1981-10 (Log #210); and see 2.2.13 in the ROP.

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465

NFPA 1981 — May 2002 ROC— Copyright, NFPA(Log #187)

1981-43-(2-2.10.1, 2.7.2 & Z.2.10.7) : Reject SUBMITTER: Todd Carroll, Kappler Safety GroupCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Delete all proposed text in Proposal 1981-24 (Log #CP2). SUBSTANTIATION: General Comment: NFPA standards are voluntary consensus standards that have received widespread support on the part of end users and manufacturers. The tone of the TC’s comment Log #CP2 puts the certifying organization in the role of an independent regulatory body. Current NFPA “boilerplate” language already requires certifiers to be accredited (para 2-1.2), not to allow partial, conditional, or temporary certification (para. 2-2.4), require the certifier to have a program in place to investigate field reports alleging malperformance or failure (2-2.11), require manufacturers to have a product recall system (para. 2-2.12, and 2-5.2), and require manufactures to be ISO 9001 registered. Imposing the proposed “regulatory” responsibility onto the shoulders of the certifying organizations shifts the burden of product stewardship away from the part having fiscal and legal responsibility (i.e., the manufacturer). I feel that the existing language includes the necessary requirements to ensure that both manufacturer and certifier can achieve the desired mission of NFPA certification. Adoption of the proposed language ultimately begs the question of “Who Certifies The Certifier?”. Para. 2.2.10.2: How does the certification organization determine if malpractice or failure of a compliant product/component constitutes a “safety risk to end users”? Judging compliance to a pass/fail performance criteria is one thing, conducting a risk analysis of a potential product failure is a much more complex and vague undertaking. Safety products are used under an enormous range of complex and adverse conditions that cannot be anticipated or replicated in the laboratory. For this reason, NFPA has defined the limit of applicability of their standards within their existing scope and purpose boilerplate language. Paragraphs 1.1.1, 1.2.1 and 1.2.3 include various statements limiting the applicability of the standard to “minimum requirements”. Paragraph 1.2.3 goes on to state that “...shall not be deemed as establishing performance levels for all situations...” The performance requirements included within 1981 often items are accepted in the absence of any risk analysis data. NFPA 1981 has the complimentary requirements of NIOSH, which developed the original respiratory requirements. Other standards such as NFPA 1999, 1991, 1992, etc. include performance requirements that have been proposed and approved by the respective TCs. For example, NFPA 1991 includes a breakthrough time criteria of 60 minutes for a battery of 21 chemicals. No risk analysis existed to support this minimum criteria. NFPA 1999 includes a puncture propagation tear requirement of 5.5 lbs, no risk analysis was conducted to support this minimum value. Since many of the requirements included in the NFPA standards have been approved in the absence of risk analysis, accepting the proposed language may impart an unfair responsibility on the part of the certifier to conduct “after the fact” analysis on the standards to determine if in fact they represent a reasonable set of criteria for their designed purpose (i.e, determine if they offer the necessary level of “safety” to the user of the certified product). I think it is obvious that responsibility for this task should certainly lie in the hands of the TC and TCC. In paragraph 2.2.10.3 of Log #CP2, the proposed language is very vague yet far reaching, requiring the certifying body to expand their investigations to “determine the scope and nature of the safety risk, the nature of possible injury or other consequences from using the compliant product in question, and possible causes or circumstances that led to the compliant product’s... Failure or malperformance..” Failure analysis is a product liability issue that rests with the manufacturer, compliance to defined performance criteria is a responsibility that lies with the certifying organization. The potential liability imposed on the certifying body if this language is accepted is enormous and would certainly require excessive increases in the already significant certification fees imposed on the manufacturers. A certifying body should not be held to anything outside that which is defined within the applicable NFPA standard. Additionally, a certifying body should not be given any responsibility for products outside their organization which would not be the case if paragraph 2.2.10.4 is accepted. Paragraphs 2.2.10.5, and A.2.2.10.7 are potentially the most vague and legally vulnerable statements which require the certifying organization to “...investigate complaints of malperformance or failure that are not anticipated by the performance requirements...”. It is the responsibility of NFPA, the TCC, and the applicable TCs, to promulgate standards that establish technically sound and reasonable performance requirements that when transformed into a complaint component or product will offer the user a reasonable level of performance. The certifying organization is not a regulatory body, the contractual relationship between certifier and manufacturer is to simply judge performance against a well-defined standard. Product performance or failure outside of that covered by the standard is the responsibility of the manufacturer. If it becomes obvious that the TC did not anticipate other important properties during the normal development cycle of a standard, NFPA has systems in place to include other criteria according to the TIA process.COMMITTEE ACTION:Reject

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(Log #70)1981-44-(2-2.10.2) : Reject SUBMITTER: Ross Cochran, Securitex Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add text to read as follows: The investigation by the certification organization shall include an initial determination of the validity of the complaint and if the compliant product of compliant product component constitutes a potential safety risk to end users, than the certification organization shall undertake a more detailed investigation...component’s failure or mal performance. If the compliant is found to be groundless, either initially or after a detailed investigation, the costs of the investigation shall be borne by the complainant. If the complaint is found to be valid, the costs of the investigation shall be borne by the manufacturer of the product or component that is the subject of the complaint. SUBSTANTIATION: To conduct thorough and proper investigations, both UL the manufacturer will have to commit significant time and money. The system could easily become overloaded if there is no disincentive to the filing of frivolous complaints. Moreover, since there is no financial burden or risk to the complainant, there is a very real possibility that there will be complaints that are commercially motivated, or malicious, or both.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: This document applies to the manufacturers and certification organization. Issues such as who is responsible for costs should be addressed in contractual agreements.

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(Log #72)1981-45-(2-2.10.2) : Accept in Principle SUBMITTER: Ross Cochran, Securitex Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: “The investigation by the certification organization shall include an initial determination of the validity of the complaint and if the compliant product of compliant product component constitutes a potential probable safety risk to...” SUBSTANTIATION: Most everything has the potential to be safety risk; the concern should be with probable safety risks. The determination of probable risk should be done according to accepted actuarial principles and in the context of the firefighting environment.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See action taken on Comment 1981-10 (Log #210).

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(Log #81)1981-46-(2-2.10.2) : Accept in Principle SUBMITTER: Nicholas J. Curtis, Lion Apparel, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise 2.2.10.2 to read as follows: “The investigation by the certification organization shall include an initial determination of the validity of the complaint and if the compliant product or compliant product component constitutes a potential safety risk to end users may pose a substantial product hazard to end users.” SUBSTANTIATION: Differentiates “potential safety risk” from “substantial product hazard”. This is a product issue, and should follow the established Consumer Products Safety Commission triggers for recalls, notifications, replacements, refunds, etc.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See action taken on Comment 1981-10 (Log #210).

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(Log #145)1981-47-(2-2.10.2) : Reject SUBMITTER: Daniel Ryan, Underwriters Laboratories Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise as follows: 2.2.10.2 The investigation by the certification organization shall include an initial determination of the validity of the complaint and if compliant product or compliant product component constitutes a potential safety risk to end users met the requirements of the standard edition to which it was certified at the time it was produced. SUBSTANTIATION: As proposed, the text is vague and subjective with regard to what constitutes a “potential safety risk. The standard edition that the product was certified to represents the national consensus minimum safety requirements deemed to be appropriate for new elements. These standards apply only to new products.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The committee feels that compliants must be able to exceed safety issues of a particular standard edition and has revised text to reflect this. The certification organization can include whatever additional resources they feel necessary in order to have a complete investigation. ISO 27 includes procedures for a “producer of a subsequently hazardous product” to be included in product compliant investigations and action as necessary.

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466

NFPA 1981 — May 2002 ROC— Copyright, NFPA(Log #161)

1981-48-(2-2.10.2) : Reject SUBMITTER: Denise N. Statham, Southern Mills, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Delete the entire section. SUBSTANTIATION: The means by which a certification organization deems a complaint to be valid is not defined. A certification organization is not qualified to determine what constitutes a potential safety risk to the end user.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The committee feels that compliants must be able to exceed safety issues of a particular standard edition and has revised text to reflect this. The certification organization can include whatever additional resources they feel necessary in order to have a complete investigation. ISO 27 includes procedures for a “producer of a subsequently hazardous product” to be included in product compliant investigations and action as necessary.

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(Log #165)1981-49-(2-2.10.2) : Accept in Principle SUBMITTER: Patricia A. Freeman, Globe Manufacturing Co., Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text as follows: “The investigation by the certification organization shall include an initial determination of the validity of the complaint and if the complaint is applicable to new or used product. compliant product or compliant product component constitutes a potential safety risk to end users. SUBSTANTIATION: NFPA standards are written for new product; older products have always been considered to be compliant to the standard to which they were labeled, understanding that older product, although perhaps still serviceable, could not be held to the revised requirements of an updated standard. therefore, it is imperative to determine if the complaint is based on new or used product in order to conduct any investigation. Since the entire series of NFPA standards for fire fighting are considered safety based, it should be assumed that a loss of any performance constitutes a potential safety risk to the end user. To place any organization or body in a position of determining which requirements are safety related and which are not, introduces a different mindset. We have never attempted to prioritize one requirement as being more important than another. If it is not safety related, why is there a requirement int he first place? Do we really want an NFPA standard that, by virtue of the language used int he standard, admits some requirements are more important than others?COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See action taken on Comment 1981-10 (Log #210).

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(Log #176)1981-50-(2-2.10.2) : Reject SUBMITTER: Joey K. Underwood, Safety Components Fabric, Technologies, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise 2-2.10.2 to read as follows: “The investigation by the certification organization manufacturer shall include an initial determination of the validity of the complaint and if compliant product or compliant product component constitutes a potential safety risk to end-users.” SUBSTANTIATION: 1. If the problem is deemed not valid, where does the cost of the third party analysis get charged? Each manufacturer has the capability to study each complaint on it’s own merits. 2. If the problem is deemed invalid, can the cost of the investigation be charged to the source of the complaint?COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The committee feels it is the responsibility of the certification organization and not that of the manufacturers. The certification organization is the one to determine product compliance and the status of certification.

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(Log #26)1981-51-(2-2.10.2 (New) ) : Accept in Principle SUBMITTER: W. Lee Birch, Luxfer Gas CylindersCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add text at the end of paragraph to read as follows: “The certification organization shall conclude its initial investigation within 3 three weeks of receiving the complaint.” SUBSTANTIATION: In the interest of safety, a time limit should be given to the investigating body.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See action taken on Comment 1981-10 (Log #210).

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(Log #82)1981-52-(2-2.10.3) : Accept in Principle SUBMITTER: Nicholas J. Curtis, Lion Apparel, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise 2.2.10.3 to read as follows: “If the certification organization determines the complaint to be valid and determines that the compliant product or compliant product component constitutes a potential safety risk may pose substantial product hazard to end users, then the certification organization shall undertake a more detailed investigation that determines to determine the scope and nature of the potential product hazard safety risk, the nature of possible injury or other consequences from using the compliant product in question, and possible causes or circumstances that led to the failure or malperformance of the compliant product’s or compliant product component’s. SUBSTANTIATION: Focus on product hazard, not risk. Deletes “other” non-safety issues and removes mal-performance which is a non-word.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See new text in action taken on Comment 1981-10 (Log #210).

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(Log #146)1981-53-(2-2.10.3) : Accept in Principle SUBMITTER: Daniel Ryan, Underwriters Laboratories Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise as follows: 2.2.10.3 If the certification organization determines the complaint to be valid and determines that the compliant product or compliant product component constitutes a potential safety risk to end users, then the certification organization shall undertake a more detailed investigation that determines the scope and nature of the safety risk, and the nature of possible injury or other consequences from using the compliant product in question,and possible causes or circumstances that led to the complaint product[s or compliant component’s failure or malperformance. SUBSTANTIATION: While determining the cause of a product failure may be of relevance to the TC in drafting future requirements and to the manufacturer for research/development of an improved product, and certification organizations may contribute to this work at their discretion, this work can not be the sole responsibility of the certification organization.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See new text in action taken on Comment 1981-10 (Log #210).

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(Log #147)1981-54-(2-2.10.3) : Accept in Principle SUBMITTER: Daniel Ryan, Underwriters Laboratories Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise as follows: 2.2.10.3 If the certification organization determines the complaint to be valid and determines that the compliant product or complaint product component did not comply, at the time it was produced, with the standard edition to which the product was certified constitutes a potential safety risk to end users, then the certification organization shall undertake a more detailed investigation that determines the scope and nature of the nonconformity safety risk, the nature of possible injury or other consequences from using the complaint product in question, and possible causes or circumstances that led to the compliant product’s or compliant component’s failure or malperformance. SUBSTANTIATION: The requirements contained in the standard to which the product was certified represented the nationally recognized minimum requirements appropriate for the product at the time it was produced.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: The committee feels that compliants must be able to exceed safety issues of a particular standard edition and has revised text to reflect this. The certification organization can include whatever additional resources they feel necessary in order to have a complete investigation. ISO 27 includes procedures for a “producer of a subsequently hazardous product” to be included in product compliant investigations and action as necessary.

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(Log #166)1981-55-(2-2.10.3) : Reject SUBMITTER: Patricia A. Freeman, Globe Manufacturing Co., Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text as follows: “If the certification organizaiton determines the complaint to be valid and determines that the compliant product or product component constitutes a potential safety risk to end users, did not meet the requirements of the standard at the time it was produced, then the certification organization shall require a product recall. If the certification organization determines that the product did comply at the time of manufacture, but does now constitute a potential health or safety risk, then the certification organization shall undertake a more detailed investigation that determines the scope and nature of the safety risk, and the nature of possible injury or other consequences from using the compliant product in question. Additionally, the third party certification organization shall investigate possible causes or circumstances

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NFPA 1981 — May 2002 ROC— Copyright, NFPAthat led to the compliant product’s or compliant product component’s failure or malperformance deterioration. SUBSTANTIATION: The intent of this change is to identify that a product recall is always mandatory if the product was not compliant at the time it was shipped, even though it contained a third party certification mark. In the case of a product that was compliant, but can no longer meet the requirements of the standard to which it was certified to such a degree that the third party certification organization has concerns that it may cause a health or safety risk, then the organization will undertake a more detailed investigation to determine if a safety alert is required. This allows the certification organization to make an informed decision, taking into consideration product age, use factors, maintenance, and types or frequency of exposure to environments contributing or causing to the product deterioration.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The committee feels that complaints must be able to exceed safety issues of a particular standard edition and has revised text to reflect this. The certification organization can include whatever additional resources they feel necessary in order to have a complete investigation. ISO 27 includes procedures for a “producer of a subsequently hazardous product” to be included in product compliant investigations and action as necessary. Although the committee is rejecting this comment, the committee feels that much of the submitters concerns have been addressed in the action taken on Comment 1981-10 (Log #210). Some of the submitters recommended changes are too restrictive and less stringent remedies could be applied depending on the hazard.

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(Log #177)1981-56-(2-2.10.3) : Reject SUBMITTER: Joey K. Underwood, Safety Components Fabric, Technologies, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: If the certification organization determines the complaint to be valid and determines that the compliant product or compliant product constitutes a potential safety risk to end users, then the certification organization shall undertake a more detailed investigation that determines the scope and nature of the safety risk, the nature of possible injury or other consequences from using the compliant product in question, and possible causes or circumstances that led to the compliant product component’s failure. If the manufacturer determines that the complaint to be valid and determines that the compliant product constitutes a potential safety risk to the end user, then the manufacturer and the component supplier supply chain shall undertake a more detailed investigation that determines the scope and nature of the safety risk, the nature of possible injury or other consequences from using the compliant product in question and possible causes or circumstances that led to the compliant product components failure. SUBSTANTIATION: The only organization that can perform a proper root cause analysis to every problem in every product is the manufacturer and their supply chain partners of the product. Every manufacturer should be ISO certified, have all products tested and certified, and they are all interested in remaining in business. Complaints cannot go answered.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: See actions taken on 1981-40 (Log #175) and 1981-50 (Log #176).

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(Log #207)1981-57-(2-2.10.3 (New) ) : Accept in Principle SUBMITTER: Jeffrey O. Stull, International Personnel Protection, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Change end of Paragraph 2.2.10.3 (proposed in Proposal 1981-24 (Log #CP2) SUBSTANTIATION: The investigation of product failure must include consideration as to the approaches that may be used to correct the problem as the ease of implementing the corrective action will have a bearing in the findings of the certification organization.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See the new text in action taken on 1981-10 (Log #210).

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(Log #28)1981-58-(2-2.10.4) : Accept in Principle SUBMITTER: W. Lee Birch, Luxfer Gas CylindersCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add to the last sentence: “...and specific testing against the requirements of the standard to which the compliant product was certified, and any associated standard as to its selection, care, maintenance and use.” SUBSTANTIATION: It isn’t realistic to separate a complaint’s investigation only taking into account the design standard. Complaints will sometimes involve a combination of factors including: design, selection, care, maintenance and/or use. If a complaint is made on a product, but the malperformance evolved because of misuse, or because of abuse, the certification organization must be able to draw upon other standards to address

the full nature of the complaint. The intent of the above suggested wording is to require the certification organization to include in its investigation consideration, issues on whether the product was used properly, properly selected for the application and, cared and maintained properly.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See new text in action taken on Comment 1981-10 (Log #210).

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(Log #83)1981-59-(2-2.10.4) : Accept in Principle SUBMITTER: Nicholas J. Curtis, Lion Apparel, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: “If the certification organization determines the complaint to be valid and determines that the compliant product or compliant product component may pose a substantial product hazard to the end users, then the The certification organization’s investigation shall include but not be limited to the compliant product for which the complaint(s) was received. The investigation shall be expanded to determine the extent that and scope of the problem, as it might apply to other compliant products or compliant product components manufactured by other manufacturers or certified by other manufacturers or certified by other certification organizations., and specific testing against the requirements of the standard to which the compliant product was certified. SUBSTANTIATION: Clarifies the intent and the full range of the certification organization’s responsibility.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See new text in action taken on Comment 1981-10 (Log #210).

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(Log #167)1981-60-(2-2.10.4) : Accept SUBMITTER: Patricia A. Freeman, Globe Manufacturing Co., Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text as follows: “The certification organization’s investigation shall include but not be limited to the extent and scope of the problem, as it might apply to other compliant product or complaint product components manufactured by other manufacturers or certified by other certification organizations, and specific testing against the requirements of the standard to which the compliant product was certified. SUBSTANTIATION: Since the certification agencies maintain that the certification mark is only applicable to new product, we need to clarify that any investigation launched as a result of field complaints with the intent of recall, need to be based upon new product tested to applicable requirements. No reasonable man would assume that used product, with no consideration given t its age, use factors, maintenance, or types and severity of field exposures, would meet the exact same requirements established for new product.COMMITTEE ACTION:AcceptCOMMITTEE STATEMENT: See new text in action taken on Comment 1981-10 (Log #210).

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(Log #73)1981-61-(2-2.10.5) : Accept in Principle SUBMITTER: Ross Cochran, Securitex Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: “The certification organization shall also investigate complaints of malperformance or failure that are not anticipated by the performance requirements of the relevant standard to determine if the malperformance or failure presents warrants a safety alert or product recall.” SUBSTANTIATION: Malperformance or failure cannot present a safety alert or product recall. They could, however, conceivably warrant either one.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See new text in action taken on Comment 1981-10 (Log #210).

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(Log #74)1981-62-(2-2.10.5) : Reject SUBMITTER: Ross Cochran, Securitex Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Delete the following text: The certification organization shall also investigate complaints of malperformance or failure that are not anticipated by the performance requirements of the relevant standard to determine if the malperformance or failure presents a safety alert or product recall. SUBSTANTIATION: The proposed text is a logical and legal minefield. First, as noted in comments on 2.2.10, the word malperformance is not even a real word. Furthermore, the word failure is not defined. What then, can possibly constitute an unanticipated malperformance or failure? In part, the NFPA standards have evolved in response to new information on, or an increasing awareness of, different risks and hazards. The proposed text would circumvent the NFPA process of proposal, debate and

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NFPA 1981 — May 2002 ROC— Copyright, NFPAvalidation thereby sanctioning the creation of de facto performance or design requirements outside the scrutiny of the NFPA technical committees. The Technical Committee should be very concerned that its responsibility and authority are being usurped. The Technical Committee should also be concerned about the possible legal implications of the proposed text. If the certification organization has found a malperformance or failure heretofore unanticipated and, as a consequence, orders the manufacturer to issue a safety warning or recall a product - and if the manufacturer disagrees with the certification organization’s action or decision - one should anticipate that the manufacturer will instigate legal proceedings against the certification organization. It would be logical for the plaintiff manufacturer to also name the NFPA as codefendant in such proceedings for having sanctioned such language in the first place.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: See new text in action taken on Comment 1981-10 (Log #210). While the indicated text was deleted, new text was added to support ISO 27 provisions to address where product could pose hazards to the user not anticipated by the standard. The committee feels the new text in 2.2.11 (Comment 1981-10, Log #210 action) addresses the reasonable foreseeable action for a certification organization to take in order to prudently respond to claims of product nonconformance and claims of product hazards.

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(Log #84)1981-63-(2-2.10.5) : Accept in Principle SUBMITTER: Nicholas J. Curtis, Lion Apparel, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: “The certification organization shall also investigate respond to compliants of malperformance or regarding compliant products if the alleged failures were that are not anticipated by the design or performance requirements of the relevant standard under which the product was listed as compliant and the compliant product is therefore not subject to recall to determine if the malperformance or failure presents a safety alert or product recall. The certification organization shall provide the reports as required in Section 2.2.10.8. SUBSTANTIATION: To assure responsiveness to field complaints, and provide feedback. To remove the possibility that a compliant product could be recalled for failure to meet requirements which were not included in the NFPA standard to which it was originally manufactured. All NFPA compliant products are “grandfathered” and this should not change because of a product recall requirement.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See new text of 2.2.11.5 in action taken on Comment 1981-10 (Log #210). There are other actions other than recall that can be taken where indicated but recall is still one of the actions to consider.

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(Log #148)1981-64-(2-2.10.5) : Reject SUBMITTER: Daniel Ryan, Underwriters Laboratories Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise as follows: 2.2.10.5 The certification organization shall also investigate complaints of malperformance or failure that are not anticipated by the performance requirements of the relevant standard to determine if the mal performance of failure represents a safety alert or product recall. SUBSTANTIATION: The requirements contained in the standard to which the product was certified represented the nationally recognized minimum requirements appropriate for the product at the time it was produced. To suggest that certification organization be charged with establishing unilateral de-facto “standards” of their own (e.g., covering performance areas “not anticipated by the performance requirements of the relevant standard”) abandons the consensus process essential to establishing product safety requirements. As written, this requirement would also subject certified products to performance requirements contained in later editions of NFPA standards. An SCBA that is certified to the 1997 edition of NFPA 1981 could be held to advanced requirements in later editions should the SCBA be the subject of a complaint.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: See new text in action taken on Comment 1981-10 (Log #210). While the indicated text was deleted, new text was added to support ISO 27 provisions to address where product could pose hazards to the user not anticipated by the standard. The committee feels the new text in 2.2.11 (Comment 1981-10, Log #210 action) addresses the reasonable foreseeable action for a certification organization to take in order to prudently respond to claims of product nonconformance and claims of product hazards.

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(Log #156)1981-65-(2-2.10.5) : Reject SUBMITTER: Bill Burke, Fire-Dex, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Delete entire paragraph. SUBSTANTIATION: The standard is for new products only.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: See new text in action taken on Comment 1981-10 (Log #210). While the indicated text was deleted, new text was added to support ISO 27 provisions to address where product could pose hazards to the user not anticipated by the standard. The committee feels the new text in 2.2.11 (Comment 1981-10, Log #210 action) addresses the reasonable foreseeable action for a certification organization to take in order to prudently respond to claims of product nonconformance and claims of product hazards.

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(Log #159)1981-66-(2-2.10.5) : Reject SUBMITTER: Denise N. Statham, Southern Mills, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Delete entire section. SUBSTANTIATION: A certification organization cannot possibly be expected to recognize unanticipated performance problems with a certified product. The NFPA Technical Committees should bear at least part of this responsibility.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: See new text in action taken on Comment 1981-10 (Log #210). While the indicated text was deleted, new text was added to support ISO 27 provisions to address where product could pose hazards to the user not anticipated by the standard. The committee feels the new text in 2.2.11 (Comment 1981-10, Log #210 action) addresses the reasonable foreseeable action for a certification organization to take in order to prudently respond to claims of product nonconformance and claims of product hazards.

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(Log #168)1981-67-(2-2.10.5) : Reject SUBMITTER: Patricia A. Freeman, Globe Manufacturing Co., Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Delete entire paragraph. SUBSTANTIATION: Delete entire paragraph. There is simply no way that a certified, compliant product can be held to performance requirements not in the initial certification process. Further, this requirement would require NFPA to adopt a policy of automatically declaring that any product built to an earlier edition of the standard must be rendered obsolete and immediately removed from service upon adoption of a revised standard if that standard contains new requirements not anticipated by the relevant standard.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: See new text in action taken on Comment 1981-10 (Log #210). While the indicated text was deleted, new text was added to support ISO 27 provisions to address where product could pose hazards to the user not anticipated by the standard. The committee feels the new text in 2.2.11 (Comment 1981-10, Log #210 action) addresses the reasonable foreseeable action for a certification organization to take in order to prudently respond to claims of product nonconformance and claims of product hazards.

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(Log #178)1981-68-(2-2.10.5) : Reject SUBMITTER: Joey K. Underwood, Safety Components Fabric, Technologies, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add text to read as follows: The certification organization shall also investigate complains of malperformance or failure that are not anticipated by the performance requirements of the relevant standard to determine if the malpeformance or failure presents a safety alert or product recall. The manufacturer shall also investigate complaints of product failure that are not anticipated. A detailed investigation and root cause analysis shall be performed and a corrective action shall be determined and initiated to correct the unanticipated problem. If the manufacturer determines that a problem involves a safety risk to the end user, then the manufacturer shall determine the scope of the problem and initiate a product recall or product safety alert of the product that is within the specific product production sequence that may cause a product failure. The manufacturer shall prepare a report with the findings of its investigation and shall conclude a specific course of action 1. that no action is required 2. that the manufacturer shall issue a safety alert 3. that the manufacturer shall conduct a recall of the affected product.

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NFPA 1981 — May 2002 ROC— Copyright, NFPASUBSTANTIATION: 1. The manufacturer can perform this function. All components are UL listed and certified. Any unforeseen problem can be corrected without unqualified third party investigations. A procedure can be determined for product failure that involves a safety risk.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: See actions taken on Comment 1981-40 (Log #175) and Comment 1981-50 (Log #176).

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(Log #179)1981-69-(2-2.10.6) : Reject SUBMITTER: Joey K. Underwood, Safety Components Fabric, Technologies, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: None. SUBSTANTIATION: This is handled in prior statements.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: See action taken on Comment 1981-40 (Log #175) and 1981-50 (Log #176).

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(Log #27)1981-70-(2-2.10.6 (New) ) : Reject SUBMITTER: W. Lee Birch, Luxfer Gas CylindersCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add at the end of the paragraph: “The certification organization shall use nationally recognized test facilities with proficiencies to test specific product characteristics, when testing is beyond the certification organization’s expertise. The certification organization shall consult with experts on technical matters if it is not proficient or capable to address.” SUBSTANTIATION: The certification organization may not have the expertise to test products issues such as plastics, metals, valves, connectors, etc. which will require expert testing, expert advice, or expertise. It is the intent of the above suggested wording to make sure the certification organization seeks competent support, advice, and testing in areas it is not knowledgeable to render to perform.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The term “nationally recognized.” The new text in action taken on Comment 1981-10 (Log #210) provides the requirements for the provisions of ISO 27. The certification organization is required to conform to ISO 25 and ISO 65.

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(Log #57)1981-71-(2-2.10.7) : Reject SUBMITTER: Bill Grilliot, Morning Pride Mfg Co.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Change (1) to read: “(1) that the written, signed complaint was without merit and no action is required on the part of the certification organization. SUBSTANTIATION: Better outlines the outcome actions of the investigation.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: See action taken on Comment 1981-29 (Log #55).

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(Log #58)1981-72-(2-2.10.7) : Reject SUBMITTER: Bill Grilliot, Morning Pride Mfg Co.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add a new “(2)” to read: “(2) that the labeling on the compliant product, the User Information supplied with each product, NFPA 1981, NFPA 1852, or NFPA 1500 addressed the issue of the investigation and therefore fulfilled the need of a Safety Alert and no further action is required on the part of the certification organization.” SUBSTANTIATION: The Warning Label, User Information Guides, and the NFPA standards are within themselves a Safety Alert and no additional information or alert should be required. This would apply to Safety Alerts ONLY and does not affect any Recall actions.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The safety alert is a viable corrective action to a product hazard investigation determination.

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(Log #169)1981-73-(2-2.10.7) : Accept in Principle SUBMITTER: Patricia A. Freeman, Globe Manufacturing Co., Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text as follows: “The certification organization shall prepare a report with the findings of its investigation. The report shall provide one of three conclusions: (1) that no action is required on the part of the certification organization

(2) that the manufacturer shall issue a safety alert, or (3) that the product did not meet requirements at the time it was produced and the manufacturer shall conduct a recall of the affected product. SUBSTANTIATION: This comment is intended to clarify requirement.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See new text in action taken on Comment 1981-10 (Log #210).

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(Log #180)1981-74-(2-2.10.7) : Reject SUBMITTER: Joey K. Underwood, Safety Components Fabric, Technologies, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: (The certification organization) should be changed to the manufacturer. SUBSTANTIATION:COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: See action taken on Comment 1981-40 (Log #175).

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(Log #56)1981-75-(2-2.10.7 (New) ) : Reject SUBMITTER: Bill Grilliot, Morning Pride Mfg Co.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add a new “(number)” read: “(?) that the investigation related to an isolated incidence, was not a trend, nor reflective of the compliant product or component, and no action is required on the part of the certification organization.” SUBSTANTIATION: A complaint about an isolated case should not trigger Safety Alerts or Recalls when the product or component is found to be serviceable.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The committee feels the provisions in the new text (2-2.11.10) in action taken on Comment 1981- (Log #210) adequately covers the corrective actions.

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(Log #32)1981-76-(2-2.10.8) : Accept in Principle SUBMITTER: W. Lee Birch, Luxfer Gas CylindersCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: “The report shall provide one of three conclusions recommendations given to NIOSH, the product and component manufacturer(s): (1) that no action is required needed on the part of the certification organization, (2) that the manufacturer shall should issue a safety alert, or (3) that the manufacturer shall is recommended to conduct a recall of the affected product. SUBSTANTIATION: NIOSH regulates (is the regulatory authority) and approves SCBAs. Although this statement is obvious, what this means is that NIOSH regulates and controls SCBAs. Legally (from NIOSH and legal counsel discussions), the NFPA cannot direct another entity or take on the functions of the regulatory authority. In this case, regarding SCBA units, the functions of NIOSH is to specify how and under what conditions a product recall or alert can be performed. The NFPA cannot delegate NIOSH authority to any other entity. The certification organization (CO) cannot be directed in 1981 to issue an alert or recall, nor is the CO entitled to punish or take action against a manufacturer (delisting or canceling certifications) who doesn’t ‘cooperate’ in the CO alert or recall efforts. If a product (e.g., SCBA units, SCBA DOT cylinders, etc.), is regulated by a national regulatory authority (e.g., NIOSH, DOT, FDA, etc.) only that regulatory authority can issue a recall or alert regarding the regulated product. If the CO tries to enforce NFPA specifications where a regulatory authority has jurisdiction, legal counsel assures us that the CO will be involved in an onerous and probably costly legal defense, which it will ultimately loose. The TCC proposals should thus be re-written such that the CO is to give recommendations for alerts and recalls. An alternative, would be to delete the TCC proposals on alert and recall. A manufacturer of a regulated (or non-regulated) product always has the option to perform a product recall or issue an alert, based upon their own findings, or the recommendation of the CO. Thus, the wording proposed is with the intent to change the TCC proposal regarding SCBAs, such that the CO will give recommendations, rather than require, alerts and recalls of nationally regulated products.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See action taken on Comment 1981-10 (Log #210).

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NFPA 1981 — May 2002 ROC— Copyright, NFPA(Log #33)

1981-77-(2-2.10.8) : Accept in Principle SUBMITTER: W. Lee Birch, Luxfer Gas CylindersCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise second sentence to read as follows: “Where the report’s findings involve recommend issuing a safety alert or conducting a product recall...” SUBSTANTIATION: The certification organization may only recommend the alert or recall.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See action taken on Comment 1981-10 (Log #210).

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1981-78-(2-2.10.8) : Accept in Principle SUBMITTER: Bill Grilliot, Morning Pride Mfg Co.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add to the end of last sentence in this section, so it reads: “... , the certification organization shall also provide the report to the NFPA.” “...and provide a written, signed complaint to all other certification organizations found during the investigation to be certifying the affected product or component.” SUBSTANTIATION: Need a vehicle to notify other certifying organizations of a problem in such a way that the other certifying organizations will have to initiate the process found within the standard.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See action taken on Comment 1981-10 (Log #210).

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1981-79-(2-2.10.8) : Accept in Principle SUBMITTER: Ross Cochran, Securitex Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: The certification organization shall provide the report to the organization or individual submitting the complaint and the manufacturer of the compliant product or complaint product component. The certification organization shall first provide the report to the manufacturer of the compliant product or compliant product component. The manufacturer will have 14 days from receipt thereof to appeal the findings and conclusions of the report. If the manufacturer accepts the findings and conclusion of the report the certification organizations shall provide the report to the organization of individual submitting the compliant. If the manufacturer contests the findings and conclusions of the report, it will have a further 60 days to present its arguments to the certification organization. If the manufacturer and the certification organization fail to reach agreement on the findings and conclusions of the report, the dispute shall be submitted to binding arbitration. In the case where the manufacturer contests the finding and conclusions of the certification organization, a final report shall be provided only after the appeal and arbitration process is completed. SUBSTANTIATION: The absence of an appeal process is a disincentive for the certification organization to be as thorough as it should be. Furthermore, the proposed text gives the certification organization immense financial power over any manufacturer in fact, 2.2.10.8 gives it the power to put a company out of business. A proper appeal process is necessary to reduce the risk that the certification organization abuses this power.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: The basic provisions for the appeal process is in 2.2.13 and 2.2.11.7 of the new text in the action taken on Comment 1981-10 (Log #210).

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(Log #86)1981-80-(2-2.10.8) : Reject SUBMITTER: Nicholas J. Curtis, Lion Apparel, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Delete the following text: Where the report’s findings involve issuing a safety alert or product recall, the certification organization shall also provide the report to the NFPA. SUBSTANTIATION: The “NFPA” is a vague term, and neither the NFPA nor any department or body sanctioned by the NFPA has any authority, responsibility or other utility regarding products, other than to write standards for their intended safe use and performance. In the event a recall or product alert is required by a certifying organization, the appropriate notifications (other than to the manufacturer of the product and the appropriate components) are to organizations or individuals impacted by the product, or others who may be nominated in the manufacturer’s compliant product recall plan.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The new text for 2.2.11.11 in action taken on Comment 1981-10 (Log #210) covers sending information to the technical committee responsible for the standard.

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(Log #181)1981-81-(2-2.10.8) : Reject SUBMITTER: Joey K. Underwood, Safety Components Fabric, Technologies, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: “The certification organization manufacturer shall provide the report to the organization or individual submitting the compliant and to the manufacturer of the compliant product or compliant product component. Where the report’s findings involve issuing a safety alert or conducting a product recall, the certification organization shall also provide the report to the NFPA.” SUBSTANTIATION: The manufacturer shall control the process of analyzing the problem and handling the reported quality issue.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: See action taken on Comment 1981-40 (Log #175).

————————————————-(Log #34)

1981-82-(2-2.10.9) : Accept in Principle SUBMITTER: W. Lee Birch, Luxfer Gas CylindersCOMMENT ON PROPOSAL NO:1981-244RECOMMENDATION: Revise text to read as follows: “Where the certification organization’s recommendation that a recall... be conducted by the product manufacturer, and the manufacturer is proceeding to recall the product, the certification organizations shall suspend...” SUBSTANTIATION: If there is a voluntary recall, the certification organization can take such action. Until such time that NIOSH requires the recall, the certification organization should not take any such action they do not have regulatory jurisdiction for, which would make them liable to legal action. NIOSH regulates (is the regulatory authority) and approves SCBAs. Although this statement is obvious, what this means is that NIOSH regulates and controls SCBAs. Legally (from NIOSH and legal counsel discussions), the NFPA cannot direct another entity or take on the functions of the regulatory authority. In this case, regarding SCBA units, the functions of NIOSH is to specify how and under what conditions a product recall or alert can be performed. The NFPA cannot delegate NIOSH authority to any other entity. The certification organization (CO) cannot be directed in 1981 to issue an alert or recall, nor is the CO entitled to punish or take action against a manufacturer (delisting or canceling certifications) who doesn’t ‘cooperate’ in the CO alert or recall efforts. If a product (e.g., SCBA units, SCBA DOT cylinders, etc.), is regulated by a national regulatory authority (e.g., NIOSH, DOT, FDA, etc.) only that regulatory authority can issue a recall or alert regarding the regulated product. If the CO tries to enforce NFPA specifications where a regulatory authority has jurisdiction, legal counsel assures us that the CO will be involved in an onerous and probably costly legal defense, which it will ultimately loose. The TCC proposals should thus be re-written such that the CO is to give recommendations× for alerts and recalls. An alternative, would be to delete the TCC proposals on alert and recall. A manufacturer of a regulated (or non-regulated) product always has the option to perform a product recall or issue an alert, based upon their own findings, or the recommendation of the CO. Thus, the wording proposed is with the intent to change the TCC proposal regarding SCBAs, such that the CO will give recommendations, rather than require, alerts and recalls of nationally regulated products.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See new text in action taken on Comment 1981-10 (Log #210).

————————————————-(Log #60)

1981-83-(2-2.10.9) : Accept in Principle SUBMITTER: Bill Grilliot, Morning Pride Mfg Co.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add the word “by” as follows: “Where the certification organization’s findings conclude that a recall of the affected compliant product will be conducted by....” SUBSTANTIATION: Editorial.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See new text in the action taken on Comment 1981-10 (Log #210).

————————————————-(Log #87)

1981-84-(2-2.10.9) : Accept in Principle SUBMITTER: Nicholas J. Curtis, Lion Apparel, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: “Where the certification organization’s findings conclude that a recall of the affected compliant product will be conducted by the product manufacturer, the certification organization shall suspend or terminate the product manufacturer’s listing of the affected compliant product unless, or until such time as, any critical defects and major A defects have been corrected and the compliant product has been successfully retested. SUBSTANTIATION: Provides a mechanism for returning a corrected product, component or design to the marketplace.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See new text in the action taken on Comment 1981-10 (Log #210).

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471

NFPA 1981 — May 2002 ROC— Copyright, NFPA(Log #133)

1981-85-(2-2.10.9) : Accept in Principle SUBMITTER: Janice C. Bradley, International Safety Equipment Association -ISEACOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: New text for Section 2.2.10.9: Where the certification organization’s finding conclude that a compliant product is the basis for recall, the certification organization can suspend or terminate only that product from certification. SUBSTANTIATION: Under this section, if a manufacturer does not comply with the certification organization’s findings (findings that may not be supported fully by the facts or subject to a good faith dispute with the manufacturer), “the certification organization shall be obligated to terminate all of the product listings of compliance with this standard by the certification organization for that product manufacturer.” The restraint of trade implications are clear if a certification organization denies a manufacturer access to marketplaces for good products as a result of the alleged failure of another one of its products. Further, the liability potential for this situation is exacerbated when you consider the fact that the “failed” product may be the subject of a good faith dispute that ultimately results in a finding that it is a “good” product.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See new text in the action taken on Comment 1981-10 (Log #210).

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(Log #170)1981-86-(2-2.10.9) : Accept in Principle SUBMITTER: Patricia A. Freeman, Globe Manufacturing Co., Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text as follows: “Where the certification organization’s findings conclude that a recall of the affected compliant product will be conducted the product manufacturer, the certification organization shall suspend or terminate the product manufacturer’s listing of the affected compliant product, if said product is still being produced in the same manner, or with the same manner, or with the same components that led to the recall.” SUBSTANTIATION: It appears that the text to be deleted does not belong in this sentence; it certainly does not make sense. The additional text is to clarify that termination of listing for product still being manufactured is only applicable if the product remains unchanged. For example, a snap tab could be found to have been produced out of material that was not flame resistant; that same tab could still be in use, but the manufacturer discovered the disparity and had changed the material to be flame resistant. The recall would only be applicable to product produced from the failing material.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See new text in the action taken on Comment 1981-10 (Log #210).

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(Log #182)1981-87-(2-2.10.9) : Reject SUBMITTER: Joey K. Underwood, Safety Components Fabric, Technologies, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Delete the following text: Where the certification organization’s findings conclude that a recall of the affected compliant product will be conducted the product manufacturer, the certification organization shall suspend or terminate the product manufacturer’s listing of the affected compliant product. SUBSTANTIATION: This statement assumes that all production from a problem component has been out of compliance. If a manufacturer has initiated an investigation, identified a specific and defined production lot sequence, and initiated a recall, then there is no valid reason to pull the certification of a component. This also assumes a third party organization has total control and authority to suspend a manufacturer’s certification...neither of which I accept.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The certification has the control over the label and mark and has the responsibility for conforming compliance.

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(Log #35)1981-88-(2-2.10.10) : Accept in Principle SUBMITTER: W. Lee Birch, Luxfer Gas CylindersCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: “Where the certification organizations report concludes that a component of a compliant product is the basis for the recommended recall, and the component manufacturer or regulatory authority of the component performs a recall, or in the event there is no regulatory authority over the component, the certification organization shall suspend or...” SUBSTANTIATION: NIOSH or another regulatory authority can regulate a component. If the component is not regulated by any regulatory authority, the certification body may proceed without any other guidance or approval. But where a regulatory authority does exist over a component, such as a cylinder (by the DOT) the certification organization cannot force a recall,

nor take any action against the manufacturer without incurring much legal difficulty. NIOSH regulates (is the regulatory authority) and approves SCBAs. Although this statement is obvious, what this means is that NIOSH regulates and controls SCBAs. Legally (from NIOSH and legal counsel discussions), the NFPA cannot direct another entity or take on the functions of the regulatory authority. In this case, regarding SCBA units, the functions of NIOSH is to specify how and under what conditions a product recall or alert can be performed. The NFPA cannot delegate NIOSH authority to any other entity. The certification organization (CO) cannot be directed in 1981 to issue an alert or recall, nor is the CO entitled to punish or take action against a manufacturer (delisting or canceling certifications) who doesn’t ‘cooperate’ in the CO alert or recall efforts. If a national regulatory authority (e.g., NIOSH, DOT FDA, etc.) regulates a product (e.g., SCBA units, SCBA DOT cylinders, etc.), only that regulatory authority can issue a recall or alert regarding the regulated product. If the CO tries to enforce NFPA specifications where a regulatory authority has jurisdiction, legal counsel assures us that the CO will be involved in an onerous and probably costly legal defense, which it will ultimately loose. The TCC proposals should thus be re-written such that the CO is to give recommendations× for alerts and recalls. An alternative, would be to delete the TCC proposals on alert and recall. A manufacturer of a regulated (or non-regulated) product always has the option to perform a product recall or issue an alert, based upon their own findings, or the recommendation of the CO. Thus, the wording proposed is with the intent to change the TCC proposal regarding SCBAs, such that the CO will give recommendations, rather than require, alerts and recalls of nationally regulated products.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See new text in the action taken on Comment 1981-10 (Log #210).

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(Log #61)1981-89-(2-2.10.10) : Accept SUBMITTER: Bill Grilliot, Morning Pride Mfg Co.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add an “a” to first sentence to read: “Where the certification organization’s findings conclude that a component of a compliant...” SUBSTANTIATION: Editorial.COMMITTEE ACTION:AcceptCOMMITTEE STATEMENT: Now 4.2.10, 4.6, 4.7, and 4.8 in ROC preprint.

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(Log #62)1981-90-(2-2.10.10) : Reject SUBMITTER: Bill Grilliot, Morning Pride Mfg Co.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Change the word “specific” to “affected” at the two locations where it appears within this section. SUBSTANTIATION: Editorial—-more consistent with rest of standard’s section.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The revised text in the action taken on Comment 1981-10 (Log #210) has entirely rewritten the text to which the submitter is referring.

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(Log #88)1981-91-(2-2.10.10) : Accept in Principle SUBMITTER: Nicholas J. Curtis, Lion Apparel, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: “Where the certifications organization’s findings conclude that a component of the compliant product is the basis for recall or product alert, the certification organization shall suspend or terminate the compliant product manufacturer’s loisting for all complaint products from that particular manufacturer which incorporate the specific component, and investigate the use of the specific component in other compliant products by that manufacturer and by other manufacturers.” SUBSTANTIATION: Expands action to include product alerts, and prevents Certification organization from “condemning” components which may have problems which are limited to particular lots, or particular applications within compliant products. Suspension of listing is already covered in 2.2.10.9.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See new text in action taken on Comment 1981-10 (Log #210).

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(Log #137)1981-92-(2-2.10.10) : Reject SUBMITTER: Dennis W. Browner, Scott AviationCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Delete the following: and shall investigate the use of the specific component by other manufacturers.

472

NFPA 1981 — May 2002 ROC— Copyright, NFPASUBSTANTIATION: Other than cylinders this does not apply due to varying applications of unique raw materials, processes and designs of complex components used on SCBA.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: See new text 2.2.11.4 in action taken on Comment 1981-10 (Log #210).

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(Log #183)1981-93-(2-2.10.10) : Reject SUBMITTER: Joey K. Underwood, Safety Components Fabric, Technologies, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Delete the following text: Where the certification organization’s findings conclude that a component of compliant product is the basis for recall, the certification organization shall suspend or terminate the compliant product manufacturer’s listing for all compliant products from that particular manufacturer which incorporate the specific component, and shall investigate the use of the specific component by other +- SUBSTANTIATION: This assumes that, based on one problem, all components from a manufacturer are invalid. Does the DOT suspend all production of automobiles from Ford when they recall a lot of production. This also assumes that a third party has total authority over the manufacturer, which I do not accept.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The affected text has been revised in action taken on Comment 1981-10 (Log #210). See also action taken on Comment 1981- 87 (Log #182).

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(Log #134)1981-94-(2-2.10.10 Component) : Accept in Principle SUBMITTER: Janice C. Bradley, International Safety Equipment Association -ISEACOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: New text for Section 2.2.10.10 Define Component Where the certification organization’s findings conclude that a component of compliant product is the basis for recall, the certification organization can suspend or terminate only those products effected by the failed component from certification. All obligations and liabilities for failure of a component part are clearly those of the component manufacturer. SUBSTANTIATION: The restraint of trade implications are clear if a certification organization denies a manufacturer access to marketplaces for good products as a result of the alleged failure of another one of its projects. Further, the liability potential for this situation is exacerbated when you consider the fact that the “failed” product may be the subject of a good faith dispute that ultimately results in a finding that it is a “good” product. If NFPA, after due consideration, concludes that this proposal should apply to products as well as× product components, a clear, understandable definition should be included as to what constitutes a “component”.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: There is an existing definition for component. See the ROP definitions. See the new text (2.2.11.6) in the action taken on Comment 1981-10 (Log #210).

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(Log #36)1981-95-(2-2.10.11) : Accept in Principle SUBMITTER: W. Lee Birch, Luxfer Gas CylindersCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Delete the appendix or make the following changes: “This annex is provided to give guidance to the certification organization on how to determine what to recommend to the product and product component manufacturer, NIOSH, and NFPA, in terms of an alert or recall. The determination of the recommendation appropriate action for the certification organization to make undertake in the event that a specific...” Revise the last paragraph to read as follows: “The following findings actions for and recommendations for handling substantiated product defects or product malperformance are as follows recommended: Critical defect: recommend a product recall. Major A defect: recommend a product recall or safety alert depending on the nature of the specific defect. Major B defect: recommend a safety alert or offer no recommendation, depending on the nature of the specific defect. Minor defect: Offer no recommendation no action.” More changes should be made in the text if it is kept, to make it clear that the annex is for informational purposes only to help the certification organization to come to their recommendation. SUBSTANTIATION: It is the jurisdiction of the regulatory authority to determine what qualifies as criteria for an alert or a regulated product recall. This appendix is neither quantitative, statistical, nor objective, which is the basis for issuing an alert and product recall. It is therefore recommended that this appendix be given for informational purposes only, as a way for the certification organization to form a basis for its recommendation. It by no

means qualifies as a statistical, quantitative, objective means to satisfy just cause for a product recall. NIOSH regulates (is the regulatory authority) and approves SCBAs. Although this statement is obvious, what this means is that NIOSH regulates and controls SCBAs. Legally (from NIOSH and legal counsel discussions), the NFPA cannot direct another entity or take on the functions of the regulatory authority. In this case, regarding SCBA units, the functions of NIOSH is to specify how and under what conditions a product recall or alert can be performed. The NFPA cannot delegate NIOSH authority to any other entity. The certification organization (CO) cannot be directed in 1981 to issue an alert or recall, nor is the CO entitled to punish or take action against a manufacturer (delisting or canceling certifications) who doesn’t ‘cooperate’ in the CO alert or recall efforts. If a national regulatory authority (e.g., NIOSH, DOT FDA, etc.) regulates a product (e.g., SCBA units, SCBA DOT cylinders, etc.), only that regulatory authority can issue a recall or alert regarding the regulated product. If the CO tries to enforce NFPA specifications where a regulatory authority has jurisdiction, legal counsel assures us that the CO will be involved in an onerous and probably costly legal defense, which it will ultimately loose. The TCC proposals should thus be re-written such that the CO is to give recommendations for alerts and recalls. An alternative, would be to delete the TCC proposals on alert and recall. A manufacturer of a regulated (or non-regulated) product always has the option to perform a product recall or issue an alert, based upon their own findings, or the recommendation of the CO. Thus, the wording proposed is with the intent to change the TCC proposal regarding SCBAs, such that the CO will give recommendations, rather than require, alerts and recalls of nationally regulated products.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See action taken on Comment 1981-10 (Log #210).

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(Log #64)1981-96-(2-2.10.11) : Reject SUBMITTER: Bill Grilliot, Morning Pride Mfg Co.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Change first sentence to read: “Where the manufacturer of the compliant product does not comply with the actions outlined within 2.2 of this standard, then the...” SUBSTANTIATION: Editorial. Must comply with standard and not findings of certification organization.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: Section entirely revised; see action taken on Comment 1981-10 (Log #210).

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(Log #76)1981-97-(2-2.10.11) : Accept in Principle SUBMITTER: Ross Cochran, Securitex Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Delete the following text: Where the manufacturer of the compliant product does not comply with the certification organization’s findings, then the certification organization shall be obligated to terminate all of the product listing of compliance with this standard for that product manufacturer. SUBSTANTIATION: Although the desire to give more clout to the certification organization’s findings is understandable, the powers of punishment being contemplated by the above language will probably not stand up to legal challenge. Furthermore, invoking of this power may constitute restraint of trade to which the manufacturer could respond with civil action against both the certification organization and NFPA.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See new text in action taken on Comment 1981-10 (Log #210).

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(Log #141)1981-98-(2-2.10.11) : Accept in Principle SUBMITTER: Dennis W. Browner, Scott AviationCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Remove entire paragraph. SUBSTANTIATION: Paragraph 2.2.10.10 already includes all listings incorporating the specific component.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See new text in action taken on Comment 1981-10 (Log #210).

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(Log #158)1981-99-(2-2.10.11) : Accept in Principle SUBMITTER: Denise N. Statham, Southern Mills, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Delete entire paragraph.

473

NFPA 1981 — May 2002 ROC— Copyright, NFPASUBSTANTIATION: No system of checks and balances exist in the recall process as written. All the power is in the hands of the certification organization. In a case where the results of an investigation are in dispute, the certification organization can wield the ultimate punishment by terminating the listing of all compliant products made by the manufacturer.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See new text in action taken on Comment 1981-10 (Log #210).

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(Log #184)1981-100-(2-2.10.11) : Reject SUBMITTER: Joey K. Underwood, Safety Components Fabric, Technologies, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: FFRED RESCUE SYSTEM COAT Shell: Add CMO715 Requires SPEC-CUT Radio pockets must be set lower than the standard location with this unit. If coat has pockets on the hem, the radio pocket must either replace one pocket on the hem or go on the sleeve. CLASS II LIFE SAFETY HARNESS PANT Shell: Add PMO710 Cannot put pockets on rear hip Take-up straps must be deleted COAT Shell: Add CMO710 MP710 SUBSTANTIATION: None.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The submitter recommendation does not appear to NFPA 1981.

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(Log #89)1981-101-(2-2.10.12 (New) ) : Accept in Principle SUBMITTER: Nicholas J. Curtis, Lion Apparel, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add new paragraph to read as follows: 2.2.10.12 A recall or further safety alerts shall be terminated only when the certifying organization determines that all reasonable efforts and required steps have been made to remove or otherwise correct the substantial product hazard. Written notification that a recall or safety alert can be terminated will be issued to the recalling manufacturer. SUBSTANTIATION: As is a precedent with all established notification, repair, replacement or refund based recall programs, a mechanism for ending the actions must exist.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: The provisions of ISO 27 (8 and 9.1) cover these issues.

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(Log #63)1981-102-(2-2.11) : Accept SUBMITTER: Bill Grilliot, Morning Pride Mfg Co.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: The TCC notes to revise 2-2.11 really relate to 2-2.12 in the ROP. SUBSTANTIATION: Editorial 2.2.11 should remain as in ROP and revisions made to 2-2.12.COMMITTEE ACTION:AcceptCOMMITTEE STATEMENT: See 4.2 in ROC preprint.

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(Log #135)1981-103-(2-2.11) : Reject SUBMITTER: Janice C. Bradley, International Safety Equipment Association -ISEACOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Delete Section 2.2.11 SUBSTANTIATION: Any disputes between the manufacturer and the certification organization will be handled in the appeals process.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: A revised 2.2.11 is in the actions taken on Comment 1981-10 (Log #210). The proposed revision to 2.2.11 of the TCC note on 1981-24 is actually to 2.2.12 (See Comment 1981-102 (Log #63))

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(Log #94)1981-104-(2-3.2) : Accept SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: “All inspections, evaluations, conditioning, and testing for certification shall be conducted by the certification organization or a facility accredited by the certification organization for inspections, evaluations, conditioning, and testing in accordance with all requirements pertaining to testing laboratories in ISO Guide 25 ISO/IEC 17025, General Requirements for the Competence of Calibration Testing and Testing Calibration Laboratories.” SUBSTANTIATION: Revise reference to the updated version of what was ISO Guide 25, which is now a standard, ISO/IEC 17025:1999.COMMITTEE ACTION:Accept

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(Log #193)1981-105-(2-3.2) : Accept SUBMITTER: Robert W. O’Gorman, Intertek Testing Services/ETL SEMKOCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise Section 2.3.2 to read: “ISO Guide 17025 General Requirements for the Competence of Testing and Calibration Laboratories.” SUBSTANTIATION: ISO Guide 25 has been superseded by ISO Guide 17025.COMMITTEE ACTION:Accept

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(Log #95)1981-106-(2-3.3) : Accept SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: “All inspections, evaluations, conditioning, and testing conducted by a product manufacturer shall not be used in the certification or recitifaction process unless the facility for inspections, evaluations, conditioning, or testing has been accredited by the certification organization in accordance with all requirements pertaining to testing laboratories in ISO Guide 25 ISO/IEC 17025, General Requirements for the Competence of Calibration Testing and Testing Calibration Laboratories.” SUBSTANTIATION: Revise reference to the updated version of what was ISO Guide 25, which is now a standard, ISO/IEC 17025:1999.COMMITTEE ACTION:Accept

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(Log #192)1981-107-(2-3.3) : Accept SUBMITTER: Robert W. O’Gorman, Intertek Testing Services/ETL SEMKOCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise Section 2.3.3 to read: “ISO Guide 17025 General Requirements for the Competence of Testing and Calibration Laboratories.” SUBSTANTIATION: ISO Guide 25 has been superseded by ISO Guide 17025.COMMITTEE ACTION:Accept

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(Log #93)1981-108-(Table 2-3.5) : Accept in Principle SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise series table,Table 2.3.1 as follows:

474

NFPA 1981 — May 2002 ROC— Copyright, NFPA

SUBSTANTIATION: Test Series Table, Table 2.3.1 was revised to reflect the addition of several new tests (i.e., HUD performance, EOSTI performance, Facepiece Carbon Dioxide Content, etc.).COMMITTEE ACTION:Accept in Principle Add new text: 2.3.5.2 At least one SCBA shall be subjected to the tests listed in Category G but additional SCBA shall be permitted where necessary to conduct all of the Category G tests.COMMITTEE STATEMENT: See 4.3.5 and associated table and text in the ROC preprint.

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(Log #39)1981-109-(Table 2-3.5, Section 5.12 Section 6.12 and Section 6.14) : Accept in Principle SUBMITTER: K. R. Ethridge, Texas Commission on Fire ProtectionCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION:

A. Amend Table 2.3.5 to add Categories F and G as follows:

TestOrder

Category F(SCBA # 5--EOSTI#1 blocked)

Category G(SCBA #6--EOSTI #2 blocked)

1 EOSTI IndependentActivationSection 6.12

EOSTà IndependentActivationSection 6.12

2 EOSTI Recognition]Section 6.14

EOSTI RecognitionSection 6.14

B. Revise Section 5.12 as follows (as discussed at February 2001 meeting): 5.12 End of Service Time Indicator Performance 5.12.1 Each End of Service Time Indicator (EOSTI) shall be tested as specified in 6.12, End of Service Time Indicator Independent Activation Test and shall demonstrate that neither EOSTI alarm signal operation is dependent on the other EOSTI. 5.12.2 After activation of the unblocked EOSTI, the alarm shall remain active at least until the cylinder pressure drops below 17.0 bar (250 psi). 5.12.3 Each EOSTI shall be tested as specified in Section 6.14, End of Service Time Indicator Recognition Test, and shall demonstrate recognition within 10 seconds. C. Revise Section 6.12 as follows (to be congruent with the rest of the document and to incorporate items discussed at February 2001 meeting): 6.12 End of Service Time Indictor Independent Activation Test 6.12.1 Application. This test method shall apply to complete SCBA. 6.12.2 Specimens. Each specimen to be tested shall be an SCBA having one of the EOSTI sensors blocked as specified in 2.3.1. 6.12.3 Sample Preparation. 6.12.3.1 Prior to testing, specimens shall be conditioned for a minimum of 4 hours and tested at an ambient temperature of 22°C + 3°C (72°F + 5°F), with a RH of 50 percent +25 percent. 6.12.3.2 Specimens for conditioning shall be complete SCBA. 6.12.4 Apparatus. Testing shall be performed using a calibrated 0-340 bar (0-5000 psi) full scale pressure gauge and a bleed valve capable of meeting the requirements of 6.12.5.2. 6.12.5 Procedure. 6.12.5.1 Prior to testing, a special adapter connecting the calibrated pressure gauge and bleed valve shall be installed at the breathing air cylinder connection on the SCBA specimen. 6.12.5.2 After pressurizing the apparatus to greater than 30 percent of full cylinder capacity, the pressure shall be bled to ambient pressure at a rate of not greater than 200 bar (2940 psi) per minute. 6.12.5.3 The alarm signal from the unblocked EOSTI shall be as specified in 5.12.1 and 5.12.2.2.

Table 2.3.1 Test Series

TestOrder

Category A

(SCBA #1)

Category B

(SCBA #2)

Category C

(SCBA #3)

Category D

(SCBA #4)

Category E

(SCBA #5)

Category F

(ComponentTests)

1. Air Flow

Section 6.1

Air Flow

Section 6.1

Air Flow

Section 6.1

Air Flow

Section 6.1

Visibility/HUDPerformance

Section 6.X

Fabric FlameResistance

Section 6.4

2. FacepieceCarbon DioxideContent

Section 6.13

AcceleratedCorrosionResistance

Section 6.7

VibrationResistance

Section 6.3

Heat and FlameResistance

Section 6.11

HUD LowBattery VisualAlert SignalTest

Section 6.X

Fabric HeatResistance

Section 6.5

3. CommunicationsPerformance

Section 6.10

Liquid SplashResistance

Section 6.X

Thread HeatResistance

Section 6.6

4. EnvironmentalTemperature

Section 6.2

Immerson/Lea- kage Resistance

Section 6.X

Facepiece LensAbrasionResistance

Section 6.9

5. ParticulateResistance

Section 6.8

RedundantEOSTIPerformance

Section 6.12

6. WirelessConnectionPerformance

Section 6.X

7. Wiring ConnectionPerformance

Section 6.X

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NFPA 1981 — May 2002 ROC— Copyright, NFPA 6.12.6 Report. The pressure where the alarm signal starts and stops shall be recorded. 6.12.7 Interpretation. Failure of either specimen to perform as specified shall constitute failing performance. D. Add new Section 6.14 as follows: 6.14 End of Service Time Indicator Recognition Test. 6.14.1 Application. This test method shall apply to complete SCBA. 6.14.2 Specimens. Each specimen to be tested shall be an SCBA having one of the EOSTI sensors blocked as specified in 2.3.1. 6.14.3 Sample Preparation. 6.14.3.1 Prior to testing, specimens shall be conditioned for a minimum of 4 hours and tested at an ambient temperature of 22°C +3 (72°F +5°F), with a RH of 50 percent +25 percent. 6.14.3.2 Specimens for conditioning shall be complete SCBA. 6.14.4 Apparatus. 6.14.4.1 Prior to testing, a special adapter that allows the person performing testing to manually switch from a breathing air supply greater than 30 percent of the rated cylinder capacity to a pressure of 17 bar + 1 bar (250 psi + 15 psi) shall be installed at the breathing air cylinder connection on the SCBA specimen. 6.14.4.2 Testing shall be performed separately by two individual test subjects while wearing NFPA approved turnout coat, pants, gloves, hood, and helmets. 6.14.4.3 Testing shall be performed with the test subject walking at 4.8 km/hr + 0.2 km/hr (3.0 mph + 0.1 mph) on a treadmill at 0 percent grade. 6.14.4.4 Testing shall be conducted in a chamber that absorbs a minimum of 90 percent of all sound from 500 Hz to 5000 Hz. 6.14.4.5 The subjects shall have “audio metrically normal” hearing as defined in Section 5.3 of ANSI S3.2, Method for Measuring the Intelligibility of Speech over Communication Systems, in the range of 500 Hz to 3000 Hz and shall have had a physical examination conducted by a physician within the past 12 months of the date of testing. 6.14.4.6 The treadmill shall be positioned in the chamber described in 6.14.4.2 in a location where the conditions for background noise, lighting, and distraction specified in 6.14.4.6, 6.14.4.7, and 6.14.4.8 are met. 6.14.4.7 The test chamber shall be filled with “pink” noise with a tolerance of 6dB per octave band from 400 to 4000 Hz and shall be adjusted to achieve an A-weighted sound level of 85 dB + 2 dB measured at each ear of the test subject when the subject is standing in the walking location on the treadmill. 6.14.4.7.1 The forward axis of the loudspeaker shall be pointed away from the test subject and shall be located as far as possible from the subject so as to create a quasiuniform sound field at the subjects ears. 6.14.4.7.2 More than one loudspeaker shall be permitted to be used to achieve the desired sound level. 6.14.4.8 The area in the test chamber where the subject’s head is positioned when standing in the walking location on the treadmill shall be artificially lighted to achieve the specified lighting requirements. 6.14.4.9 A reading stand containing printed text that has not been previously read by the test subject shall be positioned relative to the treadmill so that (a) the vertical center of the test is in line with the center of the treadmill track within + 10 cm (4 in), (b) the horizontal center of the text is at the same height as the eye level of the test subject when standing in the walking position in the treadmill within + 10 cm (4 in), and (c), the text is at a distance of between 30 cm and 100 cm (12 inches and 39 inch) from the subject that permits it to be read by the subject while walking on the treadmill. 6.14.5 Procedure. 6.14.5.1 A test subject wearing complete turnout gear as specified in 6.14.4.2 shall don the specimen SCBA as specified in 6.14.4.1 and begin walking on a treadmill in the ambient conditions specified in 6.14.3 through 6.14.8. 6.14.5.2 The test subject, while breathing from the apparatus, shall read aloud the printed text as specified in 6.14.4.9. 6.14.5.3 After the subject has been reading aloud while walking for between 30 seconds and 5 minutes, the person performing the testing shall arbitrarily switch from the breathing air supply at greater than 30 percent of full cylinder capacity to the supply at 17 bar + 1 bar (250 psi + 15 psi). 6.14.5.4 The test subject shall acknowledge recognition of the alarm immediately upon becoming aware of it by a gesture that has been predetermined between the subject and tester. 6.14.5.5 The test subject shall signal recognition of the alarm within the time specified in 5.12.3. 6.14.5.4 This test shall be repeated by the second test subject and shall be repeated using the SCBA specimen EOSTI blocked. 6.14.6 Report. The time elapsed between the switch to low supply pressure and acknowledgement by the test subject shall be recorded. 6.14.7 Interpretation. Failure of either subject to acknowledge recognition of the alarm within the specified time period on either SCBA specimen shall constitute failing performance.SUBSTANTIATION: It seems only practical that each manufacturer will provide a specially prepared SCBA having one of the EOSTI sensors block instead of having ther certification organization block the EOSTI sensor on one of the other SCBA samples in order to perform this test (as currently stated in 6.12. Therefore, Table 2.3.5 is revises below to add two more categories having an alternate EOSTI blocked. (This table must be revises to include the EOSTI and HUD testing, regardless.) Also Sections 5.12 and 6.12 must be revised to reflect the change and a new 6.14 added to describe the process. Note: Supporting material is available for review at NFPA headquarters.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See ROC preprint for revised text, Sections 4.3, 6.2, 6.3, and 7.13.

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(Log #11)1981-110-(2-3.6) : Accept in Principle SUBMITTER: Robert Sell, David Hodson, Draeger Safety, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text as follows: “SCBA shall be initailly tested certification and shall meet...” SUBSTANTIATION: Statement does not have meaning, the modified text would read the same as Paragraph 2-3.2 from NFPA 1981, 1997 edition.COMMITTEE ACTION:Accept in Principle Revise to read: “SCBA shall be initially tested for certification and shall meet...”COMMITTEE STATEMENT: The Committee corrected the missing word.

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(Log #96)1981-111-(2-3.9.3 (New) ) : Accept in Principle SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add text to read as follows: “SCBA components shall be tested and meet the performance requirements of one test series of Category E, as specified in Table 2.3.1, every fifth year from the date of initial certification testing specified in 2.3.6.” SUBSTANTIATION: It appears as if this requirement was inadvertently left out of the ROP document. This wording was included in NFPA 1981-1997 as Paragraph 2-3.4.2. It is needed to cover the Category E components in the fifth year of certification.COMMITTEE ACTION:Accept in Principle Add to 2.3.9 and 2.3.9.2 and new 2.3.9.3.COMMITTEE STATEMENT: See 4.3.4 and associated table and text in the Roc preprint.

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(Log #171)1981-112-(2-6.2) : Reject SUBMITTER: Patricia A. Freeman, Globe Manufacturing Co., Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text as follows: “Manufacturer records of returns and complaints related to safety issues shall be retained for at least 5 years, providing such returns and complaints have been validated and are clearly not the result of improper wear, care, use, or maintenance. SUBSTANTIATION: We need to quantify the requirement. There are customers who insist, and rightly so, that the Pbi shell affected by UV degradation is a safety issue. However, this same shell if properly cared for would have no problems. Similarly, we have customers who have been exposed to enough heat to cause a Nomex shell to char, which they claim is the proof of “defective” material. Under the proposed wording, these complaints would have to be kept for five years. Additionally, this comment implies that protective equipment has a five year life, which has never been established. Since the lifespan of any protective equipment is dependent upon factors outside of the manufacturers control, we should set a realistic number that takes into account the type of abuse to which this equipment is subjected. Although most manufacturers do keep records of returns for much longer periods of time, this is a minimum standard setting a minimum requirement.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The Committee used the text for all documents in this project. See 4.2.10, 4.6, 4.7, and 4.8 in ROC preprint.

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(Log #123)1981-113-(2-6.3) : Reject SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: 2.6.3 Where the manufacturer, during the review of specific returns or complaints, discovers that a compliant product or compliant product component can constitute a potential safety risk to end users hazard that is possibly subject to a safety alert or product recall, then the manufacturer shall immediately contact the certification organization and provide all information about their review to assist the certification organization with their investigation. SUBSTANTIATION: Revised wording to be consistent with the proposed addition of new Paragraph 2.1.4.1.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The Committee used the text applicable to all documents in the project. See 4.7 in the ROC preprint.

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(Log #142)1981-114-(2-6.3) : Reject SUBMITTER: Dennis W. Browner, Scott AviationCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Paragraph 2.6.3 change “immediately” to “within 5 days.”

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NFPA 1981 — May 2002 ROC— Copyright, NFPASUBSTANTIATION: Immediately is not defined.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The term “immediately” is the term in ISO 27 and is continued in this text for consistency.

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(Log #90)1981-115-(2-6.4 (New) ) : Reject SUBMITTER: Nicholas J. Curtis, Lion Apparel, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add 2.6.4 to read as follows: The reporting of information by a manufacturer shall not constitute an admission of: (1) an unreasonable risk of injury, (2) a defect in the product which was the subject of the report, (3) a substantial product hazard, (4) an imminent hazard, (5) any other admission of liability under any statute or under common law. SUBSTANTIATION: Standard Consumer Product Safety Act language which will serve to protect the rights of manufacturers and facilitate full disclosure to the public and the certifying organization.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: This is a legal issue that would be decided in the legal system and not appropriate for a standard to determine if there is liability or not, or to attempt to insulate against responsibility.

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(Log #37)1981-116-(2-7.1) : Accept in Principle SUBMITTER: W. Lee Birch, Luxfer Gas CylindersCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: “...the procedures it will use in the event that it decides will conduct a product recall or issue a safe or is notified directed by the certification organization to either issue a safety alert or conduct a product recall.” SUBSTANTIATION: The certification organization “notifies” but does not “direct.” in this case.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See 4.8 in ROC preprint.

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(Log #172)1981-117-(2-7.2) : Reject SUBMITTER: Patricia A. Freeman, Globe Manufacturing Co., Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text as follows: The manufacturer’s safety alert and product recall system shall provide: (1) the establishment of a coordinator and the coordinator’s responsibilities y the manufacturerb for the handling of safely alerts and product recalls: (2) a method of notifying dealers, distributors, purchasers, and end users , and the NFPA about the safety alert or product recall that can be initiated within a one week period following the manufacturer’s decision to issue a safety alert or to conduct a product recall, or after the manufacturer has been directed notified by the certification organization to issue a safety alert or conduct a product recall; (3) techniques for communicating accurately and understandably the nature of the safety alert or product recall, in particular the specific hazard or safety issue found to exit; (4) procedures for removing product that is recalled and for documenting the effectiveness of the product recall; and (5) procedures for either repairing, replacing, or compensating purchasers as appropriate for returned product. SUBSTANTIATION: This is intended to clarify requirement. It is not always possible to identify the purchaser or end user of a product and since records may be stored off site,m the time frame needs to be reasonable. Also, the requirement as written could be interpreted to mean that purchasers will always be compensated for returned product, when indeed some returned product is simply beyond redemption but has provided a full and useful life. To use an example I am familiar with (clothing), it is not unusual to have 5 year old product returned to have a warranty repair, such as restitching trim, performed. When we inform the customer that the wristlets are stretched out, the self material reinforcements are worn through, the trim is no longer reflective, and the shell is stained with a oily, tar like substance, we are told “just repair the trim”. under the proposed wording, the user would assume some compensation for this garment if it were returned as a result of a safety alert concerning the trim stitching, even when it was deemed that the entire coat is simply no longer serviceable.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The Committee used the text for all documents in this project. See 4.2.10, 4.6, 4.7, and 4.8 in ROC preprint.

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(Log #65)1981-118-(2-7.2(2)) : Accept in Principle SUBMITTER: Bill Grilliot, Morning Pride Mfg Co.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add “known” so it reads: “(2) a method of notifying all known dealers,...” SUBSTANTIATION: Editorial. Can only act upon those known.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See revised text in action taken on Comment 1981-117 (Log #172)

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(Log #66)1981-119-(2-7.2(2)) : Accept in Principle SUBMITTER: Bill Grilliot, Morning Pride Mfg Co.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add “of the affected product” so it reads: “(2) a method of notifying all known dealers, distributors, purchasers, and end users of the affected product or component, and the...” SUBSTANTIATION: Editorial.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: The revised text in action taken on Comment 1981-117 (Log #172) does not prevent this but there will be occasions where all the concerned parties are not known and a general and public notice must be made.

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(Log #77)1981-120-(2-7.2(2)) : Reject SUBMITTER: Ross Cochran, Securitex Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: “A method of notifying all dealers, distributors, purchasers...that can be initiated implemented within a one week 60 day period following...” SUBSTANTIATION: A manufacturer can initiate the method within 24 hours by simply giving the appropriate instructions to the coordinator, it could then be another 12 months before the notification is actually given. We should be more concerned with the actual implementation of the notification - e.g. instructions to trade magazines to run notification; placing notification on various websites; faxing of notices to clients, etc. - as opposed to simply taking the first step towards notification. Sixty (60) days is a reasonable time frame to do this.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: See action taken on Comment 1981-117 (Log #172).

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1981-121-(2-7.2(i)) : Reject SUBMITTER: Dennis W. Browner, Scott AviationCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add to 2.7.2(i): “in addition to the development of a recall strategy consisting of warning distribution and effectiveness” then change 2, 3, 4 and 5 to a, b, c, and d. SUBSTANTIATION: Summarize the requirements of paragraph 2,3, 4 and 5 under paragraph 2.7.2(i) into an overall strategy made up of, but not limited to paragraphs 2 through 5.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: See action taken on Comment 1981-117 (Log #172).

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1981-122-(2-8 & 2.8.1 (New) ) : Reject SUBMITTER: Dennis W. Browner, Scott AviationCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add new text to read as follows: 2.8 The certification organization shall establish an appeal board made up of qualified individuals to review certification matters. 2.8.1 The manufacturer shall have the right to appeal all decisions by the certification organization regarding testing, certification and recall. SUBSTANTIATION: Currently there is no appeals process for the certification agency and the manufacturer formation of an appeals board would provide a means for settling a dispute.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: These provisions are addressed in 2.2.13 (ROP text).

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1981-123-(3-2) : Accept SUBMITTER: K. R. Ethridge, Texas Commission on Fire ProtectionCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add new subsection to 3.2 pertaining to User Information. 3.2.10 The service life of all components for which the manufacturer has established a service life and shall be included at least in the maintenance information provided to users.

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NFPA 1981 — May 2002 ROC— Copyright, NFPASUBSTANTIATION: Section 3.2 pertaining to User Information requires the manufacturer to provide the user with sufficient information so that the user can develop a program for proper use, care, maintenance, and retirement of the SCBA. It is essential then that the manufacturer provide service life information on those components that the manufacturer has established a service life so the user can insure that such components are repaired, replaced or retired as appropriate.COMMITTEE ACTION:Accept

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(Log #154)1981-124-(3-2.7) : Accept SUBMITTER: Vance Kochenderfer, CairnsAir, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise section as follows: “...(4) Methods of repair, where applicable (5) Low battery signals and battery replacement, where applicable. SUBSTANTIATION: Instructions should be provided to the user on how to interpret low battery signals and replace the batteries.COMMITTEE ACTION:Accept

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(Log #211)1981-125-(3-2.9) : Accept SUBMITTER: Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment, COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: The TCC directs the TC to add a new paragraph 3.2.9 to read: “3.2.9 The manufacturer shall provide the manufacturers’ specified component service life for composite breathing air cylinders and for all elastomeric components of the SCBA. This data shall be included at least in the maintenance information provided to the users.” SUBSTANTIATION: This new paragraph needs to be added, as an appropriate cross reference, to assure the information that NFPA 1852 requires the maintenance personnel to use is provided by the manufacturers.COMMITTEE ACTION:Accept

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(Log #10)1981-126-(4-1.3) : Accept SUBMITTER: Robert Sell, David Hodson, Draeger Safety, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Delete the entire paragraph concerning references to facepiece sizes. SUBSTANTIATION: SCBA’s are to be NIOSH approved IAW Section 2.1.1 of NFPA 1981, Nov. 2001 ROP. NIOSH currently addresses the minimum requirements for facepieces/sizes in 42 CFR, Part 84, Section 84.75. OSHA also addresses facepiece sizes and fit in 29 CFR, 1910.134COMMITTEE ACTION:Accept

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(Log #97)1981-127-(4-1.4) : Accept SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: “All electric circuits integral to an SCBA, or to any SCBA accessories, shall meet be certified to the requirements for Class I, Division I hazardous locations specified in ANSI/UL 913, Standard for Intrinsically Safe Apparatus and Associated Apparatus for Use in Class I, II, and III Division I Hazardous Locations.” SUBSTANTIATION: The revised wording clarifies that UL 913 investigations shall result in certifications, not documentation which only shows that a particular component complies with the requirements of UL 913. Full certification to UL 913 shall be interpreted to include follow-up service as well.COMMITTEE ACTION:Accept

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(Log #212)1981-128-(4-2, 4.3, and 4.4) : Accept in Principle SUBMITTER: Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment, COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: The TCC directs the TC to review all design criteria in Sections 4.2, 4.3, and 4.4 and revise the text to assure the design requirements have definitive specifications without ambiguity that can be effectively evaluated by the certification organization. SUBSTANTIATION: The TCC strongly believes these components – EOSTI, HUD, Emergency Air Flow – are important components of the SCBA. The vague design criteria given in Sections 4.2, 4.3, and 4.4 and the lack of performance requirements causes NFPA 1981 to be inconsistent with

other documents of the Project and the TC must remedy this situation during the ROC. The clear and unambiguous evaluation of these components to properly perform during SCBA use is essential to the safety of the SCBA users. If the design requirements cannot be addressed, then the TC is directed to withdraw these items and do whatever work is required for incorporation into a future ROP.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: The Committee agreed with the Technical Correlating Committee and revised the text. See the revised text in Chapter 6 of the applicable sections in the ROC preprint.

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(Log #42)1981-129-(4-2.4) : Accept in Principle SUBMITTER: K. R. Ethridge, Texas Commission on Fire ProtectionCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise 4.2.4 to require independent signaling devices. 4.2.4 Each EOSTI shall at least consist of an independent sensing mechanism and an independent signaling device.SUBSTANTIATION: I think it was the original intent to require that each EOSTI be totally independent of each other and not use any of the same components.COMMITTEE ACTION:Accept in Principle Revise 4.2.4 to read: Each EOSTI shall consent of at least: (a) a sensing mechanism, and (b) a signaling device Add new 4.2.4.1 to read: (renumber existing 4.2.4.1 through 4.2.4.4) 4.2.4.1 (now 6.2.4.1) At least one of the two required EOSTI shall be independent of any other EOSTI.COMMITTEE STATEMENT: See revised text in Chapter 6 of the ROC preprint.

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(Log #43)1981-130-(4-2.4.4) : Accept SUBMITTER: K. R. Ethridge, Texas Commission on Fire ProtectionCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise 4.2.4.4. to clarify that at least two senses must be stimulated but not limited to two. 4.2.4.4. each of the two EOSTI specified in 4.2.1 shall have a signaling devise that stimulates a different human sense than is stimulated by the other signaling device. Where one EOSTI stimulates only one human sense, the other EOSTI shall stimulate at least one different human sense. SUBSTANTIATION: The current wording would not allow the second EOSTI to stimulate the same human sense as the first EOSTI even if the first EOSTI stimulated more than one sense. I think the intent is to require at least two senses to be stimulated while not limiting either EOSTI to stimulating only one sense.COMMITTEE ACTION:Accept

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(Log #209)1981-131-(4-3) : Accept in Principle SUBMITTER: Jimmy Don Dutton, Dallas Fire DepartmentCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise Section 4.3 to read as follows: 4.3 Head-Up Display 4.3.1 All SCBA shall be equipped with at least one head-up display that is visible by the wearer. 4.3.2 HUD shall be activated with no further procedures than those required to activate the SCBA breathing systems. 4.3.3 HUD shall at least provide a visual display of information and visual alert signals 4.3.4 All visual displays of information shall be visible for a minimum of ten consecutive seconds. 4.3.5 All visual alert signals shall be visible for a minimum of twenty consecutiveseconds. 4.3.6 Where the visual display of info is not constantly visible, or is not visible for at least ten consecutive seconds every 60 seconds, the HUD shall be provided with a manual activation of the display. The manual activation shall cause the visual display to be visible for at least ten consecutive seconds for each activation. 4.3.7 Visual alert signals shall provide indication of conditions specified in this section and shall be permitted to indicate when other noteworthy status or conditions have occurred. 4.3.8 Each time the SCBA breathing system is activated, HUD shall provide a visual indication, for a minimum of consecutive twenty seconds, that the HUD has been activated. 4.3.9 HUD shall be visible to the SCBA wearer regardless of wearer’s head movement. 4.3.10 The HUD shall not use color as the only means of differentiating display information and visual alert signals. 4.3.11 While the SCBA is activated, HUD information shall be visible to the wearer in darkness, smoke, and bright sunlight without manual adjustment.

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NFPA 1981 — May 2002 ROC— Copyright, NFPA 4.3.12 Each visual alert signals shall be identifiable, by the SCBA wearer, from any other visual alert signal(s) or other information provided on HUD or on the SCBA. 4.3.13 The HUD shall show information and visual alert signals at least for cylinder pressure and shall show at least low battery visual alert in accordance with 4.3.16. *4.3.14 The cylinder pressure display shall indicate, as a minimum, four equal increments of the cylinder total rated service pressure from full to a quarter. A display only in units of pressure shall not be permitted. 4.3.15 HUD shall show a visual alert signal when the breathing air in the SCBA cylinder has reduced to 50 percent of rated service pressure. This visual alert signal shall visablyflash at a frequency of not less than one per second. 4.3.16 Where batteries are necessary for the HUD to comply with the requirements of this standard, a visual alert signal that indicates at least a minimum of two hours of operation at maximum electrical draw shall be provided. SUBSTANTIATION: This language provides clearer direction as to the type of HUD that should be included in the SCBA.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See Section 6.3 in the ROC preprint.

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(Log #214)1981-132-(4-3.6) : Accept in Principle SUBMITTER: Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment, COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: On the Head-Up Display issue, the TCC directs the TC to review the HUD requirement in 4.3.6 for use in bright sunlight is questioned. We know from experiences on other products, that an LED in the facepiece creates problems for SCBA wearers, particularly in low light or darkness conditions. LEDs can be blinding when the SCBA wearer’s pupils are dilated from trying to see in a low/no light environment. SUBSTANTIATION: The TCC is concerned whether other display technologies, where vision correction is required to be able to focus at a close range, have been fully considered and evaluated. The TCC is concerned that ambiguous evaluation criteria, combined with these new requirements for inclusion of a facepiece HUD, will result in equipment not ready for the fire or emergency services. Additionally, the TCC is concerned with how these criteria were established and whether patent considerations were evaluated (where a company holds patents on facepiece type displays, potentially locking others out of the market).

COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See action taken on comment 1981-143 (Log #208), in 5.14.15 and 5.14.17.

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(Log #143)1981-133-(4-3.8) : Accept in Part SUBMITTER: K. R. Ethridge, Texas Commission on Fire ProtectionCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise Section 4.3.8 to add a requirement for user acknowledgment that cylinder is depleted to half capacity. 4.3.8 The head-up display shall show a visual alter signal when the breathing air in the SCBA cylinder has reduced to 50 percent of the full cylinder capacity. The initial 50 percent visual alert signal shall be different from the normal head-up display and shall require acknowledgment from the user that the user is aware that the cylinder is at 50 percent of full capacity. SUBSTANTIATION: Because fire fighters may not routinely keep a close watch on their remaining air supply and instead rely on the EOSTI to warn them when their air is depleted, it is apparent that the need exists to warn the fire fighter earlier than is accomplished by the EOSTI. That fire fighters often ignore the fact that half or more of their air has been depleted in getting them where they currently are, they also ignore that they may need all of their remaining air just to get out. This makes the 50 percent visual alert signal extremely important. So important that I think acknowledgment of the warning is justified.COMMITTEE ACTION:Accept in Part Accept the 50 percent visual alert signal is provided for in 4.3.1.5. Reject the “acknowledgment” issue as there are other means to provide more information for the user. Acknowledgment can be part of purchaser specifications.COMMITTEE STATEMENT: The committee rejects the “acknowledgment” issue.

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(Log #120a)1981-134-(4-3.10.5) : Accept SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: 4.3.10.5 Where batteries are necessary for the HUD to comply with the requirements of this standard, a visual alert signal that indicates at least a minimum of two hours of operation at maximum electrical draw shall be provided.

SUBSTANTIATION: Need to add low battery visual signal alert performance requirements and test method for HUD to NFPA 1981, per TCC request.COMMITTEE ACTION:AcceptCOMMITTEE STATEMENT: See 6.3.8.6 in the ROC preprint.

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(Log #155)1981-135-(4-3.11) : Accept in Principle SUBMITTER: Vance Kochenderfer, CairnsAir, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Make the following changes: “4.3.11 Where the heads-up display is operated by battery power, a visual alert signal to indicate low battery condition shall show on the heads-up display. This signal shall be either a battery depletion warning signal or a battery replacement warning signal. 4.3.11.1 A battery depletion warning signal shall be a visual alert signal which is displayed when the battery voltage is depleted to the level that will allow the heads-up display to meet the performance requirements of 5.X for at least 1 hour of usage time. 4.3.11.1.1 The battery depletion warning signal shall be displayed at all times when the heads-up display is visible and the battery voltage is below the level specified in 4.3.11.1. 4.3.11.1.2 A battery depletion warning signal shall be independent from and physically segregated from the cylinder pressure display. 4.3.11.2 A battery replacement warning signal shall be an informational signal which is displayed when the battery voltage is depleted to the level that will allow the heads-up display to meet the performance requirements of 5.X for at least 5 hours of usage time. 4.3.11.2.1 The battery replacement warning signal shall be displayed when the heads-up display is initially activated as specified in 4.3.2 and the battery voltage is below the level specified in 4.3.11.2. The signal may also be displayed at other times but shall not interfere with any other required display. 4.3.11.2.2 The battery replacement warning signal may be incorporated with other elements of the heads-up display; however, the signal shall be easily distinguishable by the SCBA wearer from any other signals provided on the heads-up dispaly.” SUBSTANTIATION: Language which has been previously proposed only envisions one type of low battery signal. Provision should be made to allow manufacturers flexibility in providing a signal which gives the user adequate notice of impending battery exhaustion. Two approaches to this goal are described. The battery depletion warning signal is designed to provide immediate notification of impending battery exhaustion. This is similar to the warning currently required for PASS under NFPA 1982. The purpose of this signal is to inform the user that the batteries are failing and that he must act immediately to put himself in a position where he will not be endangered by loss of the heads-up display. The battery replacement warning signal is designed to provide a longer advance notice (5 hours instead of 1) of battery exhaustion. The purpose of this signal is to inform the user that the batteries are nearing the end of their useful life and should be replaced as soon as is practicable. The signal would be shown at each initial activation of the heads-up display either during routine inspection or before the wearer has entered a hazardous area. It would not necessarily be useful to show this signal while engaged in firefighting activities because the user will not be in a position to replace the batteries. The 5-hour requirement is several times longer than the maximum service time of the SCBA cylinder; therefore, the user will have multiple opportunities to see the signal and perform the battery replacement, ensuring that the batteries will not drop below the level required to sustain display. This type of signal need not be physically segregated from the cylinder pressure display because the user will not be relying on the pressure display at the time the signal is shown.COMMITTEE ACTION:Accept in Principle 4.3.11 accept in principle. 4.3.11.2 reject.COMMITTEE STATEMENT: 4.3.11 See action taken on Comment 1981-134 (Log #120a) 4.3.11.2 This option can be provided or specivied by the purchaser above the minimum requirements of the standard.

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(Log #188)1981-136-(4-4) : Accept SUBMITTER: Vance Kochenderfer, CairnsAir, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Remove Section 4.4, Emergency Air Flow System, in its entirety.SUBSTANTIATION: To date, no test data, field reports, or other supporting documents have been presented to the Technical Committee to justify requiring a manual bypass. Provision for controlling air flow in the event of an SCBA malfunction is already made in 42 CFR 84.84(e). It has not been demonstrated that these regulations are inadequate or that there are circumstances unique to fire and emergency services which demand a new design requirement. The safety of fail-open regulators is proven. They have been designed by engineers with decades of experience in breathing apparatus. The independent respirator experts at NIOSH have thoroughly tested and analyzed

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NFPA 1981 — May 2002 ROC— Copyright, NFPAthese regulators and approved them without a manual bypass. If a failure mode existed where the flow of air would be cut off, NIOSH would require a manual bypass. Finally, over 10 years of field use, most of it in the fire service, have demonstrated the safety and reliability of these designs. Forcing SCBA to move from an automatic, fail-open regulator to one with a manual bypass would be a step backward. It would shift the responsibility for providing air flow in the event of a failure away from the SCBA and place it back on the user.COMMITTEE ACTION:Accept

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(Log #215)1981-137-(4-4) : Accept in Principle SUBMITTER: Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment, COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: On the Emergency Air Flow System issue, the TCC directs the TC to review and revise the design criteria of Section 4.4. The current text is too vague and evaluation of the criteria is not possible. The TCC directs the TC to evaluate the NIOSH requirements for such devices and the design requirements used by NIOSH to evaluate the basis of failure modes and effects analyses criteria that NIOSH applies. NIOSH certification applies as a prerequisite to all SCBA that will be tested for compliance with NFPA 1981.SUBSTANTIATION: The basis for the requirements of Section 4.4 is nebulous. Why were only regulators that operate at or below 520 psig required to be equipped with an emergency air flow system? Why must all hose withstand full cylinder pressure? This requirement would seem to require that all hose and regulators be capable of withstanding 4500 psi. The TCC believes this would add weight and stiffness to the system, possibly compromising safety of the SCBA user. Currently these hose and regulators are not capable of withstanding the high pressure, but are protected from failure with a relief valve. The relief valve solution creates a safe, time proven, system while maintaining a user-friendly configuration. The clear and unambiguous evaluation of this component to properly perform during SCBA use is essential to the safety of the SCBA users. If the design requirements cannot be addressed, then the TC is directed to withdraw these items and do whatever work is required for incorporation into a future ROP.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See action taken on comment 1981-138 (Log #217).

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(Log #217)1981-138-(4-4) : Accept SUBMITTER: Eric Beck, Mine Safety Appliances Co.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Delete entire 4.4 paragraph. SUBSTANTIATION: The Technical Committee voted to delete this paragraph at the San Diego meeting held in December 2000. It was felt the designs required to provide this type of bypass had a complexit and risk that exceeded the benefit received based on the relative infrequency of field incidents.COMMITTEE ACTION:Accept

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(Log #150)1981-139-(4-4.5) : Reject SUBMITTER: Eric Beck, Mine Safety Appliances Co.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise as follows: All hose and connections leading to the SCBA regulator shall withstand be protected from the pressure of the SCBA’s fully charged breathing air cylinder without leakage or failure if any other upstream regulators fail in the open mode. SUBSTANTIATION: The TC agreed at the San Diego meeting to allow the use of other protective mechanisms such as pressure relief valves to protect such systems.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: See action taken on Comment 1981-136 (Log #188) and Comment 1981-138 (Log #217). Section 4.4 has been deleted.

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(Log #119)1981-140-( Chapter 5 and 6 (New)) : Accept in Principle SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add text to read as follows: (new) 5.X Wiring Connection Performance. 5.X.1 All wiring connections for SCBA facepieces with HUD and any associated assemblies with interconnecting wiring shall be tested for wiring connection performance as specified in 6.X. 5.X.2 Specimen SCBA facepieces with HUD and any associated assemblies

with interconnecting wiring which are tested in accordance with 6.X shall be observed for the movement of wiring. Wiring shall not move a distance greater than 13 mm (1/2 in.) from the wiring entrance/exit of the specimen under test. (new) 6.X Wiring Connection Strength Test. 6.X.1 Application. This test method shall apply to SCBA facepieces with HUD and any associated assemblies with interconnecting wiring. 6.X.2 Specimens. Each specimen tested shall be as specified in 2.3.5. 6.X.3 Sample Preparation. 6.X.3.1 Specimens for conditioning shall be SCBA facepieces with HUD and any associated assemblies with interconnecting wiring. 6.X.3.2 Prior to testing, samples shall be conditioned for a minimum of 4 hours and tested at an ambient temperature of 22OC, ±3OC (72OF, +5OF), RH of 50 percent, ±25 percent. 6.X.4 Apparatus. A mass of known weight with the means for attachment to wiring. 6.X.5 Procedure. A force of 156 N, ±9 N (35 lbs. ±2 lbs. force) shall be applied gradually, in an axial direction, to the wiring of the specimen being tested.. 6.X.6 Report. Observations of the movement of wiring from the entrance/exit of the specimen under test shall be recorded in mm (in.). 6.X.7 Interpretation. Observation of the movement of wiring which results in the application of stress on internal connections of the specimen shall be used to determine pass or fail performance. SUBSTANTIATION: Need to add wiring connection performance requirements and test method for HUD to NFPA 1981, per TCC request.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See 7.14 and 8.15 in the ROC preprint.

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(Log #120)1981-141-(Chapter 5 and 6) : Accept in Principle SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add text to read as follows: 5.X HUD Low Battery Visual Alert Signal Performance 5.X.1 HUD requiring batteries shall be tested as specified in Section 6.X, HUD Low Battery Visual Alert Signal Test, and the battery supply shall provide power to operate the HUD properly for at least one hour. 5.X.2 The testing shall encompass all components of the HUD which require battery power for proper operation. This shall include all sensor devices and indicators. 6.X HUD Low Battery Visual Alert Signal Test 6.X.1 Application. This test method shall apply to all HUD Low Battery Visual Alert Signal devices required by Section 4.3.10.5. 6.X.2 Specimens. Each specimen tested shall be specified in 2.3.5. 6.X.3 Sample Preparation. 6.X.3.1 Specimens shall be conditioned for a minimum of 4 hours and tested at an ambient of 22OC, ± 3OC (72OF, + 5°F), RH of 50 percent, ±25 percent. 6.X.3.2 Specimens for testing may be complete SCBA, partial SCBA, or components of SCBA necessary for proper indication and operation for this test as determined by the testing organization and the manufacturer. 6.X.4 Procedure. 6.X.4.1 Each HUD manufacturer shall electrically characterize the device with regard to voltage and current at all operating conditions, and shall provide the certification organization with a list of voltages that cause the Low Battery Visual Alert Signal to activate, the HUD to cease proper operation , as well as the current draw of the HUD in its worst-case operating mode. This list shall encompass all manufacturing tolerances and shall take into consideration these tolerances to provide the certification organization with the worst-case condition. SUBSTANTIATION: Need to add low battery visual signal alert performance requirements and test method for HUD to NFPA 1981, per TCC request.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See 7.14.2 and 8.16 in ROC preprint.

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(Log #118)1981-142-( Chapter 5 and 6 (New)) : Accept in Principle SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add text to read as follows: (new) 5.X Liquid Splash Resistance. 5.X.1 Specimen SCBA facepieces with HUD and any associated electronic assemblies (including but not limited to battery pack(s), sensing mechanism(s), etc.) shall be tested for resistance to liquid splash as specified in Section 6.X, Liquid Splash Resistance Test. 5.X.2 SCBA facepiece with HUD and any associated electronic assemblies tested in accordance with 6.X. shall be evaluated for proper functioning as specified in 5.1.2 and shall have no water inside any battery compartment(s). (new) 6.X Liquid Splash Resistance Test. 6.X.1 Application. This test method shall apply to complete SCBA. 6.X.2 Specimens. Each specimen tested shall be as specified in 2.3.5.

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NFPA 1981 — May 2002 ROC— Copyright, NFPA 6.X.3 Sample Preparation. 6.X.3.1 Specimens for conditioning shall be complete SCBA. 6.X.3.2 Prior to testing, specimens shall be conditioned for a minimum of 4 hours at an ambient temperature of 22žOC, ±3žOC (72žOF, ±5žOF), RH of 50 percent, ±25 percent. 6.X.4 Apparatus. The apparatus and supplies for testing shall be those specified in ASTM F1359, Standard Practice for Evaluating the Liquid Tight Integrity of Chemical Protective Clothing, with the following modifications: 1.) *The mannequin used in testing shall be fully upright and shall have straight arms and legs with the arms positioned at the mannequin’s side. 2.) The liquid-absorptive inner garment shall be used. 3.) The surface tension of the water used in testing shall be 35 dynes/cm, +5 dynes/cm. 6.X.5 Procedure. 6.X.5.1 The SCBA, with a fully charged breathing gas cylinder, facepiece with HUD assembly, and any associated electronic assemblies shall be placed on the mannequin to simulate its typical wearing position on a fire fighter as specified by the manufacturer. The SCBA facepiece shall be secured to the head of the mannequin in such a manner as to assure a watertight seal. 6.X.5.2 The mannequin shall be mounted upright and placed inside the liquid spray chamber. The mannequin shall then be exposed to the liquid spray for a period of 60 minutes, 15 minutes in each of the four mannequin orientations as specified in ASTM F1359, Standard Practice for Evaluating the Liquid Tight Integrity of Chemical Protective Clothing. 6.X.5.3 The liquid shall be sprayed at a rate of 3.0 ± 0.2 L/min (48 ± 3 gal/hr) through each nozzle simultaneously. 6.X.5.4 At the end of the liquid spray period, excess liquid shall be removed from the surface of the specimen SCBA, facepiece with HUD and any associated electronic assemblies. 6.X.5.5 Specimen SCBA facepiece with HUD and any associated electronic assemblies shall be removed from the liquid spray chamber and testing shall begin within 10 minutes of removal from conditioning. 6.X.5.6 Specimen SCBA facepiece with HUD and any associated electronic assemblies shall be operated in accordance with the manufacturer’s instructions to determine the proper functioning as specified in 5.1.2. 6.X.5.7 The battery compartment(s) of specimen SCBA facepiece with HUD shall be opened, and each battery compartment shall be inspected for water leakage to determine pass/fail. 6.X.6 Report. 6.X.6.1 Observations of proper function for each specimen shall be recorded after the performance procedure. 6.X.6.2 Observations of water inside the battery compartment(s) after the performance procedure shall be recorded. 6.X.7 Interpretation. Pass or fail performance shall be determined for each specimen. One or more specimens failing this test shall constitute failing performance. SUBSTANTIATION: Need to add liquid splash resistance requirements and test method for HUD to NFPA 1981, per TCC request.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See Sections 7.14 and 8.17 in the ROC preprint.

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1981-143-(Chapter 5) : Accept in Principle SUBMITTER: Jimmy Don Dutton, Dallas Fire DepartmentCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise performance requirements in Chapter 5 to read as follows: 5.1.2 When the SCBA is tested as specified in 6.1.1, the SCBA HUD shall display the cylinder pressure as specified in 4.3.14, and shall display the visual alert signal at 50 percent of rated service pressure. 5.2.2 SCBA HUD shall be tested for environmental temperature performance as specified in Section 6.2, Environmental Temperature Tests. 5.2.2.1 When the SCBA is tested as specified in 6.2.5.2, the SCBA HUD shall display the cylinder pressure as specified in 4.3.14, and shall display the visual alert signal at 50 percent of rated service pressure. 5.2.2.2 When the SCBA is tested as specified in 6.2.5.3, the SCBA HUD shall display the cylinder pressure as specified in 4.3.14, and shall display the visual alert signal at 50 percent of rated service pressure. 5.2.2.3 When the SCBA is tested as specified in 6.2.5.4, the SCBA HUD shall display the cylinder pressure as specified in 4.3.14, and shall display the visual alert signal at 50 percent of rated service pressure. 5.2.2.4 When the SCBA is tested as specified in 6.2.5.5, the SCBA HUD shall display the cylinder pressure as specified in 4.3.14, and shall display the visual alert signal at 50 percent of rated service pressure. 5.3.2 When the SCBA is tested as specified in 6.3.1, the SCBA HUD shall display the cylinder pressure as specified in 4.3.14, and shall display the visual alert signal at 50 percent of rated service pressure. 5.7.2 When the SCBA is tested as specified in 5.7.1, the SCBA HUD shall display the cylinder pressure as specified in 4.3.14, and shall display the visual alert signal at 50 percent of rated service pressure. 5.8.2. When the SCBA is tested as specified in 5.8.1, the SCBA HUD shall display the cylinder pressure as specified in 4.3.14, and shall display the visual alert signal at 50 percent of rated service pressure. SUBSTANTIATION: Performance criteria should be included for the HUD as well as appropriate tests to verify this performance.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See Chapter 7 in the ROC preprint for text including the HUD performance into the existing requirement.

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(Log #117)1981-144-( Chapter 5 and 6 (New)) : Reject SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add text to read as follows: (new) 5.X Immersion/Leakage Resistance. 5.X.1 Specimen SCBA facepieces with HUD shall be tested for resistance to leakage as specified in Section 6.X, Immersion/Leakage Resistance Test, Test Procedure 1. 5.X.2 Specimen SCBA facepieces with HUD which are tested in accordance with Section 6.X, Test Procedure 1, shall be evaluated for proper functioning as specified in 5.1.2. 5.X.3 Specimen SCBA facepieces with HUD that contain batteries as part of the SCBA facepiece shall be tested for resistance to leakage as specified in Section 6.X, Immersion/Leakage Resistance Test, Test Procedures 1 and 2. 5.X.4 Specimen SCBA facepieces with HUD which are tested in accordance with Section 6.X, Test Procedures 1 & 2, shall be evaluated for proper functioning as specified in 5.1.2 following Test Procedure 1 and shall have no water inside any battery compartment(s) following Test Procedure 1 and shall have no water inside any electronic compartment(s) following Test Procedure 2. (new) 6.X Immersion/Leakage Resistance Test. 6.X.1 Application. This test method shall apply to SCBA facepieces with HUD. 6.X.2 Specimens. Each specimen tested shall be as specified in 2.3.5. 6.X.3 Sample Preparation. 6.X.3.1 Specimens for conditioning shall be SCBA facepieces with HUD. 6.X.3.2 Prior to testing, specimens shall be conditioned for a minimum of 4 hours at an ambient temperature of 22OC, ±3OC (72OF, ±5OF), RH of 50 percent, ±25 percent. 6..X.4 Apparatus. 6.X.4.1 The test water container shall be capable of covering the uppermost point of the specimen SCBA facepiece with HUD with a depth of 1 m (3.3 FT.) of water and shall maintain the SCBA facepiece with HUD at that depth. 6.X.4.2 The water temperature shall be 18OC, ±10OC (64OF, ± 18OF) and the water temperature shall not change more than 3OC (5OF) for the duration of the test. 6.X.5 Test Procedure 1. 6.X.5.1 Specimen SCBA facepiece with HUD shall be immersed in the test water container for 2 hours. After 2 hours, the specimen SCBA facepiece with HUD shall be removed from the test water container and shall be wiped dry. 6.X.5.2 Specimen SCBA facepiece with HUD shall be tested for proper functioning within 60 seconds of removal from the test water. 6.X.5.3 Specimen SCBA facepiece with HUD shall be operated in accordance with the manufacturer’s instructions to determine the proper functioning as specified in 5.1.2. 6.X.5.4 If the SCBA facepiece with HUD is provided with batteries, the battery compartment(s) shall be inspected for water leakage within 5 minutes of removal from the test water 6.X.5.5 The battery compartment(s) of the specimen SCBA facepiece with HUD shall be opened, and each battery compartment shall be inspected for water leakage to determine pass/fail. 6.X.6 Test Procedure 2. 6.X.6.1 After completion of Test Procedure 1, the specimen SCBA facepiece with HUD shall be reimmersed in the test water container for an additional 5 minutes. The battery compartment(s) shall be open and the battery(ies) shall not be installed. 6.X.6.2 After the 5 minute immersion, the specimen SCBA facepiece with HUD shall be removed from the test water container and shall be wiped dry. 6.X.6.3 The electronic compartment(s) of the specimen SCBA facepiece with HUD shall be opened within 60 seconds of removal from the test water, and inspected for water leakage to determine pass/fail. 6.X.7 Report. 6.X.7.1 Observations of proper function for each specimen shall be recorded after the performance for Test Procedure 1. 6.X.7.2 Observations of water inside the battery compartment(s) after the performance of Test Procedure 1 and inside the electronics compartment(s) after the performance of Test Procedure 2 shall be recorded. 6.X.8 Interpretation. Pass or fail performance shall be determined for each specimen. One or more specimens failing this test shall constitute failing performance. SUBSTANTIATION: Need to add immersion/leakage requirements and test method for HUD to NFPA 1981, per TCC request.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The committee has chosen a water spray test to test for water tightness. See action taken on comment 1981-142 (Log #118).

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(Log #213)1981-145-(5-1, 5.2, 5.3, 5.7, 5.8, and 5.11) : Accept in Principle SUBMITTER: Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment, COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: On the End-of-Service-Time Indicator (EOSTI) and the Head-Up Display (HUD) issues, the TCC directs the TC to modify the performance requirements of Sections 5.1, 5.2, 5.3, 5.7, 5.8 and 5.11

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NFPA 1981 — May 2002 ROC— Copyright, NFPAto include pass/fail requirements for EOSTI and HUD as part of the requirements. Further, the TC is directed to modify the associated test methods to include testing of the EOSTI and HUD (after conditioning and environmental testing) with procedures, reporting, and interpretation criteria, as necessary.SUBSTANTIATION: SCBA with these components must be tested for full and proper functioning following the exposures specified in the above noted performance requirements. The standards of this Project are based, to the greatest extent possible, on performance requirements and associated test methods by which the performance can be determined. The clear and unambiguous testing of these components to properly perform during SCBA use is essential to the safety of the SCBA users. If the performance requirements cannot be addressed, then the TC is directed to withdraw these items and do whatever work is required for incorporation into a future ROP.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: For HUD see action taken on comment 1981-143 (Log #208), Section 5.14.

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(Log #216)1981-146-(5-1, 5.2, 5.3, 5.7, 5.8, and 5.11) : Accept in Principle SUBMITTER: Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment, COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: On the Emergency Air Flow System issue, the TCC directs the TC to review the performance requirements of Sections 5.1, 5.2, 5.3, 5.7, 5.8, and 5.11 to determine if any or all will be included as performance requirements for the emergency air flow system. The TC is directed to include pass/fail requirements to each of the applicable performance requirements for the emergency air flow system. Further, the TC is directed to modify the associated test methods to include testing of the emergency air flow system (after conditioning and environmental testing) with procedures, reporting, and interpretation criteria, as necessary.SUBSTANTIATION: SCBA with this component must be tested for full and proper functioning following the exposures specified in the above noted performance requirements. The standards of this Project are based, to the greatest extent possible, on performance requirements and associated test methods by which the performance can be determined. The clear and unambiguous testing of this component to properly perform during SCBA use is essential to the safety of the SCBA users. If the performance requirements cannot be addressed, then the TC is directed to withdraw this item and do whatever work is required for incorporation into a future ROP.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See action taken on comment 1981-138 (Log #217).

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(Log #51)1981-147-(5-9) : Reject SUBMITTER: Robert Sell, Draeger Safety, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Delete all text and tests that refer to “Lens Abrasion Testing.” SUBSTANTIATION: This requirement has been included from the inception of the NFPA 1981, 1987 Revision in an attempt to cut down on lens replacement after they have been scratched either by a glove or laying on a flat surface. With later revisions, there have been modifications to this requirement in regards to visibility after the heat and flame test has been conducted in order for the fire fighter to retain some amount of vision after exposure to a flashover for egress. The most field problems/complaints that have been experienced relate to the coated lenses crazing after heat/flame exposure that limits the visibity of the fire fighter to effectively egress after this has occurred. The crazing occurs on the coated lens and the most occurrences so far have happened after training evolution in flashover trainers. There has been an extensive effort to source coatings for the lens internationally and domestically that meet both the Abrasion and Heat/Flame requirements but with little sucess. Uncoated lenses pass the heat and flame test and with little damage to the lens but do not successfully meet the Lens Abrasion test. In the interest of Fire Fighter safety, this requirement should be removed.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The reduction of lens scratching is considered important in enhancing vision and the Committee will retain lens abrasion testing.

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(Log #44)1981-148-(5-12.2) : Accept SUBMITTER: K. R. Ethridge, Texas Commission on Fire ProtectionCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise 5.12.2 to require activation down to 17 BAR (250 psi). 5.12.2 After actuation of the unblocked and of service time indicator, the indicator activation, each EOSTI shall remain activated for a minimum of 30 cycles of the breathing machine and until the cylinder pressure drops below 17 BAR (250 psi).

SUBSTANTIATION: This wording is needed to insure that the EOSTI will continue to operate as long as there is useable air in the cylinder.COMMITTEE ACTION:AcceptCOMMITTEE STATEMENT: See action taken on Comment 1981-109 (Log #39).

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(Log #45)1981-149-(5-12.3) : Accept SUBMITTER: K. R. Ethridge, Texas Commission on Fire ProtectionCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add new 5.12.3 to require testing of the EOSTI for recognition. 5.12.3 Each EOSTI shall be tested for recognition as specified in Section 6.14, End of Service Time Indicator Recognition Test, and shall demonstrate recognition within 10 seconds. SUBSTANTIATION: This wording is needed to require the EOSTI to be tested to insure that it will get the wearers attention.COMMITTEE ACTION:AcceptCOMMITTEE STATEMENT: See new 5.14 in the ROC preprint.

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(Log #153)1981-150-(6-1.3) : Reject SUBMITTER: Vance Kochenderfer, CairnsAir, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add new subsection under the “specimens” section of the proposed wiring test as follows: “Specimens shall be tested while mounted to the SCBA in the ‘as used’ configuration.” SUBSTANTIATION: It is likely that many implementations of the HUD will have wiring paired with a hose line. Other designs may likewise use other structural components to reinforce the wiring. Specimens should be tested while attached to these reinforcements to accurately gauge their strength in the same configuration that users will see.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The wire is tested where it enters or exits any component.

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(Log #186)1981-151-(6-1.4) : Reject SUBMITTER: Bruce A. Hefner, International Safety InstrumentsCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise Sections 6.1.4.1 through 6.1.4.13.15 and replace with Sections 6-1.1 through 6-1.16 of the 1997 Edition of NFPA 1981. Also replace associated annex material A.6.1.14 with Sections A-6-1.1 through A-6-1.14 of NFPA 1981, 97 Edition. SUBSTANTIATION: 1. No round robin testing of SCBA’s from all manufacturers of complete environmental and heat and flame tests. 2. No proof that Section 6.1.4.13.13 can be met. 3. Configuration of machine to facilitate calibration and remote testing is not shown. 4. Official NFPA machine needs to incorporate a strip chart recorder. Our concerns have to do with the selection of the Posi Check as the new NFPA breathing machine. Our concerns were brought up in a telephone meeting several months ago with the group that is working not he change and the concerns were not totally addressed. But before I go into these concerns let me first say that we have nothing against the Posi Chek machine - we have seven Posi Chek III’s and have been using Posi Chek machines for about 10 years. We think enough of the Posi Chek machines that we use them to test our demand valves by removing the head form and connecting the machine to a test box that the demand valve is plugged into. But anytime there is a question about the performance of a demand valve or the final unit I personally test it using the NFPA breathing machine. Also, I never use the Posi Chek for development work or to test a problem unit. During the telephone meeting I complained that NFPA was not following its past protocol of doing round robin testing of equipment from all manufacturers. I also complained that the heat/flame and environmental tests had not been conducted using a Posi Chek to see if the machine would hold up to the tests. I understand that ITS did conduct one heat and flame test and some environmental testing for the committee in June, 2000 and at least one unit failed. I also understand that the Posi Chek machine failed during one test. Where is the report? The questions are “How durable is the Posi Chek, especially when you run one test after another?” Can it run for several hours in a row? Can it continue to operate under these temperature extremes? Since the bellows is located next to the electronics one must assume that the temperature of the electronics will increase or decrease. Does that change the calibration of the machine? The temperature range of the Posi Chek transducer, according to Paragraph 6.1.4.7(b), is 41°F - 113°F - will range be exceeded during the environmental test? And again, when will round robin tests be conducted? The Posi Chek machine is great for short duration tests where you don’t care about the actual profile of the breathing trace but a detailed trace is required for certification and development work. Yes, the Posi Chek will give you 3 very detailed traces in a 6 second time span or 6 traces in a 12 second time span, neither of which match the current NFPA trace, but that is it. I was

482

NFPA 1981 — May 2002 ROC— Copyright, NFPAtold during the meeting that I must not have the lab software to go with the machine but I am not sure what that will change. When you get through, as I understand it, you will print out a report with a trace that is 1 1/2 in. tall and 3 1/2 in. long. If the report is for a 30 minute test it will look like someone took a 1 in. wide brush and painted a stripe across the report area. I have worked on the development of demand valves at ISI for the past 8 years during which I have run several thousand tests, some are for 30 seconds, some for one minute and some for the entire duration of the cylinder. The long duration tests are usually at -25°F or 175°F. To do this work and to understand and correct problems I must have good detail of the breathing trace. With the current set up I can expand the trace at will to get that detail or compress the data to save ink and paper if all I need is the max and min points. Some say that the max and min points are all that is needed for the NFPA testing but this is not true. The manufacturer cannot duplicate some of the NFPA tests such as heat and flame so we must rely on Intertek’s test results for the detail that we need to correct problems. If the report says that the trace went to -0.1 in. of water pressure you must be able to see this point and what happened before and after. If you have just failed a test that will cost $5000 to repeat you want to know exactly what happened. Maybe the failure was due to something that happened during the test such as a door opened or closed. A strip chart recorder allows you to see the change soon after it happens so that the chart can be marked and that trace ignored. I believe that it needs to be done with the official NFPA machine at the test lab. I am also the person who usually goes ton Intertek for the annual and five-year testing (heat and flame and vibration). I have watched them calibrate the machine before each test. How will they calibrate this machine? Is it not necessary to calibrate or at least check to see that it is giving the correct pressure and air volume? If it is not necessary then when does it become necessary. We send our machines in once a year. We have no idea whether they adjust them or not. Do they go bad on the 364th day or do they go bad a year later or 6 months earlier? How will the lab know? Why hasn’t Intertek been supplied with a Posi Chek machine in the correct configuration for the testing so they can do more testing? They need to be comfortable with the machine and its ability to do all of the required testing. Years ago, before I was in this business, the experts determined that the breathing trace of a human is best represented by a cam driven machine. The official NIOSH machine is cam driven. Does the Posi Chek duplicate this trace? If yes, I would like to see the proof. If not, why not? If there is no way to turn this situation around until all the proper testing is done and all the questions are answered then I would propose that the standard include both machines and a sixth category of testing. I propose that the Posi Chek be used for the initial breathing test for each unit and that the rest of the testing continue as is until the industry and ITS has some experience with the newly configured machine (2 or 5 years from now).COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: See action taken on Comment 1981-152 (Log #189).

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(Log #189)1981-152-(6-1.4) : Reject SUBMITTER: Robert W. O’Gorman, Intertek Testing Services/ETL SEMKOCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Replace currently proposed supporting sections with the current 1997 edition wording. SUBSTANTIATION: The historical development of NFPA 1981 has been founded upon documented scientific and engineering based decision making that was driven to ensure continual advances for those on the front lines within the fire service. NFPA 1981-92 Edition, for example, introduced the current machine for airflow performance only after a considerable investment by the manufacturers and the NFPA foundation. Even after this, organizations like ITS and Lawrence Livermore National Laboratories, spent hundreds of hours and thousands of dollars to perform round robin airflow performance testing while the document was still not complete. This was done in order to ensure correlation between the labs and the manufacturers. As of this comment, I am only aware of 2 small projects performed on the new device for this committee. In one of these projects, during a total of three evaluations for Heat and Flame testing, the test station provided, was required to be shutdown and reprogrammed to move from 40L/m to 100 L/m. While the current 1997 edition H/F test requires a 3/4 diameter hose, these series of tests were performed with the Posi-check III utilizing a larger diameter hose; this effected the pressure measurements (2 of 3 units failed the airflow test). The June 2000 environmental “hot” test performed for the committee, demonstrated a “system lock up” during the airflow performance test. This presented a final number for “pass/fail” but no graphical data. Knowing that this data must have been shared with the committee, why have we proceeded without follow-up testing and documented corrective action to ensure this is no longer a problem. As a committee, we have been told that changes, and a “lab machine”, will be presented to address necessary modifications. Current documentation of the machine lacks detail and depth when compared to the work that this committee presented in the current document. The lack of a working on-site calibration procedure for the proposed machine should also be addressed and is evidence that the work to support this change is not yet complete. In trying to accept the Posi-check system and in attempting to document a machine that is not design or patent restrictive, it appears we have been too broad in our approach and have left considerable room for future Formal Interpretations that will not be able to be answered without performing the work that this committee has traditionally done earlier in the process.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The information presented to the committee does not support remaining with the former testing machine and did not bear compelling arguments against the capability of the proposed testing machine from the SCBA manufacturers.

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1981-153-(6-1.4.1) : Accept SUBMITTER: Jack Burt, BiosystemsCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add metric dimensions to test headform in Figure 6.1.4.1.

Figure 6.1.4.1

483

NFPA 1981 — May 2002 ROC— Copyright, NFPASUBSTANTIATION: None given.COMMITTEE ACTION:Accept

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(Log #197)1981-154-(6-1.4.1) : Accept in Principle SUBMITTER: Dale W. Soos, Intertek Testing/ETL SemkoCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Dimensional units for figure are not specified. Include metric as primary units and english units as secondary. SUBSTANTIATION: Dimensions indicated on figure appear to be in inches. These are not identified but should list metric as primary, english as secondary.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See action taken on Comment 1981-153 (Log #129).

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(Log #2)1981-155-(6-1.4.6) : Accept SUBMITTER: Robert Sell, David Hodson, Draeger Safety, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: “A length of tubing, including connections, of 1.5 m ±50 mm (5 ft +/-2”) length and with a nominal...” SUBSTANTIATION: Length of tubing will make a slight difference in the breathing resistance and a standardized length should be specified.COMMITTEE ACTION:Accept

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(Log #3)1981-156-(6-1.4.9) : Accept in Principle SUBMITTER: Robert Sell, David Hodson, Draeger Safety, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add to end of paragraph:” ... For strip chart recorders the pen speed will be 750 mm/sec +/-25 mm/sec.” SUBSTANTIATION: Identify pen speed.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See action taken on Comment 1981-158 (Log #130).

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(Log #38)1981-157-(6-1.4.9) : Accept in Principle SUBMITTER: David Hodson, Draeger Ltd.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: “...equivalent to a low pass 4 pole Bessel filter with a 3dB corner frequency of 5 hz. All components to construct the filter will have a tolerance of ± 1 percent. SUBSTANTIATION: Four pole Bessel filter will give a closer duplication of a pen recorder. Note: Supporting material available for review upon request at NFPA headquarters.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See action taken on Comment 1981-158 (Log #130). (See 8.1.4 in ROC preprint).

————————————————-(Log #130)

1981-158-(6-1.4.9) : Accept SUBMITTER: Jack Burt, BiosystemsCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: 6.1.4.9 “The differential pressure transducer shall be appropriately connected to a strip chart recorder having the following characteristics: (a) A chart width of 10 in. (250 mm) (b) A pen speed of at least 29.5 in./sec (750 mm/sec) (30 in. (sec)(0.333 sec FS) (c) An accuracy of + 0.25 percent FS (d) An input voltage range of 1 V FS (e) A span set at 1 in. 25 mm of chart per 25.4 mm (1 in.) water column SUBSTANTIATION: If a digital recording system is used to acquire mask pressure data during breathing performance testing, the suggested filter specifications will yield the same pass/fail correlation as the present NFPA pressure recording system. Ref: round-robin testing conducted at ETL labs in March of 1997COMMITTEE ACTION:Accept

————————————————-(Log #98)

1981-159-(Figure 6-1.4.13) : Accept SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise Figure 6.1.4.13 to show location of vibration dampener, as required by Paragraph 6.1.4.13.5.

SUBSTANTIATION: The location of the vibration dampener should be shown on the figure, in the same manner as all of the other components.COMMITTEE ACTION:Accept

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(Log #131)1981-160-(6-1.4.13.6.1) : Accept SUBMITTER: Jack Burt, BiosystemsCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: The tubing shall have an inner diameter of 200 mm ±0.05 ±5mm (8 in. ±0.2 in.) and an outer diameter of 250 mm ±0.05 ±5mm (10 in. ±0.2 in.). SUBSTANTIATION: Corrected metric conversion.COMMITTEE ACTION:Accept

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(Log #128)1981-161-(6-1.4.13.6.2) : Accept SUBMITTER: Jack Burt, BiosystemsCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: The nominal wall thickness of the tubing shall be 0.014 1.4 mm, ±0.14 mm (0.055 in. ±0.005 in.). SUBSTANTIATION: Corrected metric conversion.COMMITTEE ACTION:Accept

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(Log #14)1981-162-(6-1.5.1) : Accept in Principle SUBMITTER: Robert Sell, David Hodson, Draeger Safety, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Section indicates that there is Annex material available, but there is no text in the Annex for this section. SUBSTANTIATION: Obtain text.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See action taken on Comment 1981-216 (Log #127).

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(Log #194)1981-163-(6-2.3.2) : Accept SUBMITTER: Robert W. O’Gorman, Intertek Testing Services/ETL SEMKOCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Change first word “Afterto the words “Prior to“. SUBSTANTIATION: Sample preparation (conditioning) happens prior to subjecting the specimen SCBA to each environmental temperature condition.COMMITTEE ACTION:Accept

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(Log #99)1981-164-(6-2.5.2.3) : Accept SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Delete Paragraph 6.2.5.2.3 in its entirety. SUBSTANTIATION: This paragraph should be deleted since the Environmental Temperature Test, Test 1, is performed while the SCBA is in a chamber at the specified cold temperature.COMMITTEE ACTION:Accept

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(Log #199)1981-165-(6-2.5.2.3) : Accept SUBMITTER: Dale W. Soos, Intertek Testing/ETL SemkoCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Entire clause to be deleted. SUBSTANTIATION: This clause is not intended to support the hot or cold tests but rather the hot soak 6.2.5.4 and the cold soak 6.2.5.5 tests.COMMITTEE ACTION:Accept

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(Log #100)1981-166-(6-2.5.3.3) : Accept SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Delete Paragraph 6.2.5.3.3 in its entirety. SUBSTANTIATION: This paragraph should be deleted since the Environmental Temperature Test, Test 2, is performed while the SCBA is in a chamber at the specified hot temperature.COMMITTEE ACTION:Accept

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484

NFPA 1981 — May 2002 ROC— Copyright, NFPA(Log #198)

1981-167-(6-2.5.3.3) : Accept SUBMITTER: Dale W. Soos, Intertek Testing/ETL SemkoCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Entire clause to be deleted. SUBSTANTIATION: This clause is not intended to support the hot or cold tests but rather the hot soak 6.2.5.4 and the cold soak 6.2.5.5 tests.COMMITTEE ACTION:Accept

————————————————-(Log #78)

1981-168-(6-3) : Reject SUBMITTER: Eric Beck, Mine Safety Appliances Co.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Delete all requirements for stainless enclosure. Revert back to plywood enclosure as specified in 1997 edition of the standard. SUBSTANTIATION: Qualifications tests have never been run with the stainless enclosure. The effect of this change is therefore unknown.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The Committee has reviewed testing data that has confirmed the performance with stainless steel.

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(Log #196)1981-169-(6-3.4.1) : Reject SUBMITTER: Dale W. Soos, Intertek Testing/ETL SemkoCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Sumbit the following Figure 6.3.4.1:(See Figure 6.3.4.1 on the following page.)SUBSTANTIATION: ROP has no figure submitted.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: ROP does contain the appropriate figures as Figures 6.3.4.2(a) and 6.3.4.2(b).

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(Log #22)1981-170-(Figure 6-3.4.2(a)) : Accept SUBMITTER: Karen Strumlock, Lion ApparelCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Change the dimensions as follows and convert to metric values: 370 mm ± 6 mm X 370 mm ± 6 mm (14 1/2 in. ± 1/4 X 14 1/2 in. ± 1/4 in.) 735 mm ± 13 mm X 740 mm ± 13 mm (29 in ± 1/2 X 29 in. ± 1/2 in.) SUBSTANTIATION: The values should be presented in metric.COMMITTEE ACTION:Accept

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(Log #23)1981-171-(6-3.4.2(b)) : Accept SUBMITTER: Karen Strumlock, Lion ApparelCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Change the dimensions as follows and convert to metric values: 370 mm ± 6 mm X 460 mm ± 13 mm (14 1/2 in. ± 1/4 in. X 24 18 in. ±1/2 in.) 735 mm ± 12.5 mm X 460 mm ± 13 mm (29 in ± 1/2 in. X 24 18 in. in. ± 1/2 in.) SUBSTANTIATION: The values should be presented in metric. The height of the vibration container does not need to be 24 in., 18 in. would be sufficient to contain the unit.COMMITTEE ACTION:Accept

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(Log #6)1981-172-(6-3.4.2.1) : Accept in Principle SUBMITTER: Robert Sell, David Hodson, Draeger Safety, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text as follows: “The sides and base of the compartments shall be constructed of 6 mm (1/4”) stainless steel, the bottom of the compartments shall be the surface of the vibration table, and the top of the compartments shall remain open.” SUBSTANTIATION: The surface will wear and become an inconsistent factor during the vibration test.COMMITTEE ACTION:Accept in Principle Revise to read: “The sides and base of the compartments shall be constructed of nominal 6 mm (1/4”) stainless steel, the bottom of the compartments shall be the surface of the vibration table, and the top of the compartments shall remain open.”COMMITTEE STATEMENT: The Committee agrees with the submitter but added “nominal” to accommodate trade size and stainless steel specifications.

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(Log #200)1981-173-(6-3.4.2.1) : Accept in Principle SUBMITTER: Dale W. Soos, Intertek Testing/ETL SemkoCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise as follows: The sides and bottom of the compartment shall... the bottom of the compartments shall be the surface of the vibration table, and the top of the compartments shall remain open. SUBSTANTIATION: The description of the compartment bottom does not promote repeatability, or simulate real world conditions and it is not consistent with the committee’s desire to move away from wood.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See action taken on Comment 1981-172 (Log #6).

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(Log #4)1981-174-(6-3.5.2) : Reject SUBMITTER: Robert Sell, David Hodson, Draeger Safety, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise paragraph to read: “No special tie down shall be allowed to be made to the SCBA other than those identified by the manufacturer that is indicated int he user instructions.” SUBSTANTIATION: This will allow methods of restraints that are specific to a manufacturer’s SCBA are permitted for use.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: See action taken on Comment 1981-175 (Log #201).

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(Log #201)1981-175-(6-3.5.2) : Accept SUBMITTER: Dale W. Soos, Intertek Testing/ETL SemkoCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: No tie downs shall be allowed to be made to the SCBA. SUBSTANTIATION: Tie down cannot be allowed.COMMITTEE ACTION:Accept

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(Log #5)1981-176-(6-3.5.3) : Accept SUBMITTER: Robert Sell, David Hodson, Draeger Safety, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Change synchronous mode from 300 rpm to 250 rpm. SUBSTANTIATION: 300 rpm is not demonstrative of the previous test since the test unit is no longer restrained by the 25 mm (1Y) gap that was used. 250 rpm gives a realistic representation of the previous test method.COMMITTEE ACTION:AcceptCOMMITTEE STATEMENT: See action taken on Comment 1981-177 (Log #21).

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(Log #21)1981-177-(6-3.5.3) : Accept SUBMITTER: Karen Strumlock, Lion ApparelCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: The basic movement of the bed of the test table shall be a 25 mm (1 in.) orbital path 5 Hz, such as can be obtained on a standard package tester operating in synchronous mode at 300 250 rpm, ±5 rpm. SUBSTANTIATION: After conducting limited testing using this revised test method, 250 rpm is a more suitable speed to conduct this test at. The 300 rpm was rather severe and would probably induce the types of problems that were the reason for changing the vibration test method.COMMITTEE ACTION:Accept

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(Log #20)1981-178-(6-4.4.2, 6.4.4.3, 6.4.4.4) : Accept in Principle SUBMITTER: Karen Strumlock, Lion ApparelCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Delete paragraphs 6.4.4.2, 6.4.4.3 and 6.4.4.4. SUBSTANTIATION: The information in these sections does not belong under apparatus and the information in these sections are contained in the report and interpretation paragraphs of this section.COMMITTEE ACTION:Accept in Principle Move the paragraphs to 6.4.5 and renumber as 6.4.5.2, 6.4.5.3, and 6.4.5.4.COMMITTEE STATEMENT: The 3 paragraphs were placed in the wrong subsection and are the action instructions for the procedure.

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485

NFPA 1981 — May 2002 ROC— Copyright, NFPA

Figure 6.3.4.1

486

NFPA 1981 — May 2002 ROC— Copyright, NFPA(Log #16)

1981-179-(6-4.8) : Accept in Principle SUBMITTER: Karen Strumlock, Lion ApparelCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: 6.4.8 Specific Requirements for Testing Fabrics Less than 75 mm (3 in.) Wide. 6.4.8.1 If the fabric components are not available in the width specified in 6.4.2.1, the width of the test specimen shall be the width as used on the SCBA, but shall be a minimum of 305 mm (12 in.) long. 6.8.4.2 The test frame in Figure 6.4.8.2 shall be utilized to hold samples not available in the width specified in 6.4.2.1. 6.4.8.3 The test frame shall be constructed using the sample holder specified in ASTM D6413 with the following modifications: (a) There shall be thirteen drilled and tapped holes on each of the four legs of the test frame. The first hole shall start 6.25 mm (1/4 in.) from the bottom of each leg. Each of the remaining 12 holes shall be on 25 mm (1 in.) centers going up from the first hole. The center of each hole shall be 4 mm (0.15 in.) from the inside of the frame’s leg. (b) The threads of the screws shall not extend past the thickness of the legs. When taping the threads, the tap shall stop short of taping completely through. (c) With the cap screws in place, a bare nickel chromium (BNC) 30 gauge wire with a nominal diameter of 0.25 mm (0.01 in.) shall be wrapped around the exposed thread on the first cap screw 10 times. The wire shall then be wrapped from the screw around the outside of the leg of the frame, back around the inside of the leg and across the opening between the legs, around the other leg, and to the screw on the opposite side. The wire shall be wrapped around the exposed threads of the cap screw 10 times. (d) Step (c) shall be repeated for each set of cap screws. SUBSTANTIATION: The additions to this section further explain the use and construction of the modified vertical flame sample holder for narrow fabrics.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: The committee agreed with the submitter’s recommendation with the noted change to (c) to specify the BNC wire.

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(Log #17)1981-180-(Figure 6-4.8.2) : Accept SUBMITTER: Karen Strumlock, Lion ApparelCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise Figure 6-4.8.2 (now in Chapter 8) as follows:

SUBSTANTIATION: There is additional information required regarding the test frame and it’s construction.COMMITTEE ACTION:Accept

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(Log #101)1981-181-(6-5.1.2) : Accept SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: Modifications for testing fabrics less than 380 mm (15 in.) wide shall be specified in 6.5.8. SUBSTANTIATION: Need to include SI dimension for the 15 in. width requirement.COMMITTEE ACTION:Accept

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(Log #102)1981-182-(6-5.1.3) : Accept SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: Modifications for testing fabrics less than 380 mm (15 in.) long shall be specified in 6.5.9. SUBSTANTIATION: Need to include SI dimension for the 15 in. length requirement.COMMITTEE ACTION:Accept

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(Log #103)1981-183-(6-5.4.1) : Accept SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: “The test oven shall be a horizontal flow circulating over oven with minimum interior dimensions so that the specimens can be suspended and are at least 50 mm (2 in.) from any interior oven surface or other test specimen.” SUBSTANTIATION: Editorial comment.COMMITTEE ACTION:Accept

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(Log #104)1981-184-(6-6) : Accept SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: Thread Melting Heat Test. SUBSTANTIATION: Title of test should be revised to agree with Paragraph 5.6.COMMITTEE ACTION:Accept

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(Log #105)1981-185-(6-6.5.5) : Accept SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: “The temperature of the stage shall be raised to 245°C (473°F) and thereafter at a rate of 3°C to 4°C (5°F to 8°F) per minute until 260°C (500°F) is reached.” SUBSTANTIATION: Need to add Inch-Pound equivalent for 245°C temperature.COMMITTEE ACTION:Accept

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(Log #106)1981-186-(6-10.5.2.4) : Accept SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: “Training shall include the use of background noise as defined in 6.10.4.7 6.10.4.11.” SUBSTANTIATION: Reference to background noise was correct.COMMITTEE ACTION:Accept

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487

NFPA 1981 — May 2002 ROC— Copyright, NFPA(Log #19)

1981-187-(6-10.5.6.2) : Accept SUBMITTER: Karen Strumlock, Lion ApparelCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Change the equation to the following:

s.d.=

X( )2

2

1

X

NN

SUBSTANTIATION: This modification was accepted in Log #19 of the ROP, however equation was not properly modified in the text to the standard presented within the ROP.COMMITTEE ACTION:Accept

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(Log #107)1981-188-(6-10.5.6.3) : Accept SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: “Where the calculated sample standard deviation of the text score values >10.0, the test shall be invalidated, and the procedures of 6.10.5.2 through 6.10.5.12 6.10.5.6.6 shall be repeated.” SUBSTANTIATION: Reference needs to be corrected, since Paragraph 6.10.5.12 does not exist.COMMITTEE ACTION:Accept

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1981-189-(6-11.4.2) : Accept SUBMITTER: Karen Strumlock, Lion ApparelCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise 6.11.4.2 to read as follows: 6.11.4.2* The test mannequin shall have a protective covering that shall be designed and constructed as follows: 6.11.4.2.1 The assembled protective covering shall consist consisting of at least an outer,shell moisture barrier, and thermal liner and shall have an average thermal protective performance (TPP) of not less than 35.0 when tested in accordance with 5.1.1 of NFPA 1971, Standard on Protective Ensemble for Structural Fire Fighting. 6.11.4.2.2 The outer shell shall be one of the following options: (1) 40 percent PBI®/60 percent Technora ® ripstop weave, weighing nominally 225g/m2 (7.5 oz/yd2 in a natural and undyed color. (2) 40 percent PBI®/60 Technora ® plain weave, weighing nominally 225g/m2 (7.5 oz/yd2 in a natural and undyed color. 611.4.2.3 The thermal liner shall be constructed of a 102 g/m2 (3.0 oz/yd2) ripstop pajama check or plain weave Nomex® III face cloth quilt stitched to 100 percent Nomex® III batting of approximately 204 g/m2 (6.5 oz/yd2). 6.111.2.4 The moisture barrier shall be constructed of nominally 76 g/m 2 (3 oz/yd2) polyester/cotton fabric that is coated with nominally 221 g/m2 (6.5 oz/yd2) of flame resistance neoprene. 6.11.4.2.5 The moisture barrier shall be completely sewn to the thermal liner at its perimeter with the cloth side outward from the thermal liner and with all edges sewn together. 6.11.4.2.6 The liner shall be no more than 75 mm (3 in.) from the coat hem. 6.11.4.2.7 The liner shall be completely detachable from the outer shell. ***Is this important*** 6.11.4.2.8 The protective covering shall be stitched with Kevlar® thread using a minimum of 6.8 6-8 stitches per 25 mm (1 in.). 6.11.4.2.9 All major seams shall be double stitched and felled locked with all inside seams to be finished with Kevlar® thread. 6.11.4.2.10 All stress points shall be reinforced. All reinforcements shall be constructed of the outer shell fabric used in 6.11.4.2.2. 6.11.4.2.11 No metal shall pass from the outside of the protective covering through the liner to cause the transfer of heat to the mannequin when the protective covering is completely assembled. 6.11.4.2.12 The protective covering, including the front closure, shall be constructed in a manner that provided secure and complete moisture and thermal protection. 6.11.4.2.13 If non-positive fasteners, such as snaps or hook-and-pile tape, are utilized in garment closures, a positive locking fastener, such as hooks and dees or zippers, shall also be utilized. 6.11.4.2.14 Pockets and fluorescent retroreflective trim shall not be installed. 6.11.4.2.15 The collar shall be made of four piece the same construction consisting of outer shell material on both the back, or outside, and next to the mannequin neck as the body of the protective covering. In addition, there shall be outer shell material on both the back, or outside, and next to the mannequin neck. 6.11.4.2.15.1 The two inner layers shall consist of a thermal liner and moisture barrier.

6.11.4.2.15.2 No throat strap shall be attached to the covering. 6.11.4.2.16 Sleeve outside seams shall be felled while inside seams shall be lock stitched. 6.11.4.2.17 All protective covers shall measure 890 mm (35 in.) long when measured from the center of the back collar seam to the hem. 6.11.4.2.18 The protective cover size shall be 1120 mm (44 in.) chest, 865 mm (34 in.) sleeve. 6.11.4.2.19 The complete protective covering shall be discarded and shall not be used after three flame exposures of the flame and heat test. SUBSTANTIATION: The current language for the heat and flame mannequin’s protective covering requires the use of a moisture barrier. Since there is no moisture presented during this test, there is no need to require this as it just results in extra cost to the testing laboratories.COMMITTEE ACTION:Accept

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(Log #108)1981-190-(6-11.4.4) : Accept SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: The test headform shall be attached to the breathing machine specified in Figures 6.1.4.13(a), (b), and (c) Figure 6.1.4.13 with the modification that a 19 mm (3/4 in.) I.D. breathing hose, not longer than 7.6 m (25 ft), shall be attached to the tee in the breathing machine and the throat tube of the test mannequin headform. SUBSTANTIATION: Need to revise references since Figures 6.1.4 13 (a), (b), and (c) do not exist.COMMITTEE ACTION:AcceptCOMMITTEE STATEMENT: See action taken on Comment 1981-191 (Log #125).

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(Log #125)1981-191-(6-11.4.4) : Accept SUBMITTER: Jack Burt, BiosystemsCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: The test headform shall be attached to the breathing machine specified in Figures 6.1.4.13, with the modification that a 19 mm (3/4 in.) 32mm (1 1/4.) I.D. breathing hose, not longer than 7.6 m (25 ft), shall be attached to the tee in interconnected between the breathing machine and the throat tube of the test mannequin headform. SUBSTANTIATION: Laboratory testing shows that 25 feet of 3/4 in. ID hose creates internal bellows pressures in excess of +/-20 inches water column at 103 L minute volumes, causing bellows collapse on a breathing machine with a flexible lung. Increasing ID of hose to 1.25 in. reduces internal pressures to acceptable levels and has no measurable effect on test protocol as indicated by testing conducted at ETL labs in June of 2000. The phrase “attached to the tee in the breathing machine” is not generic in nature. COMMITTEE ACTION:Accept

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(Log #109)1981-192-(6-11.5.6) : Accept SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: The air flow performance test shall be conducted as specified in 6.1.5, with modifications to the ventilation rate specified in 6.11.5.8 and 6.11.5.9 with test temperatures specified in 6.11.5.4 and 6.11.5.8 6.11.5.9. SUBSTANTIATION: Need to correct references to coincide with ventilation rate and temperature requirements.COMMITTEE ACTION:Accept

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(Log #110)1981-193-(6-11.5.7) : Accept SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: The air flow performance test shall continue through the drop test as specified in 6.11.5.18 6.11.5.16. SUBSTANTIATION: Need to correct reference to the drop test requirements called out in Paragraph 6.11.5.16.COMMITTEE ACTION:Accept

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(Log #126)1981-194-(6-11.5.18) : Accept in Principle SUBMITTER: Jack Burt, BiosystemsCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Section 6-11.14.1 from NFPA 1981 1997 edition should be added back in following new Section 6.11.5.7:

488

NFPA 1981 — May 2002 ROC— Copyright, NFPA “The variation in pressure extremes caused by the flame and heat test mannequin configuration shall be determined in the following manner. The air flow performance test as specified in Section 6-1 shall be carried out at a ventilation rate of 103 L/min, ±3 L/min, and 40 L/min, ±2L/min. A second air flow performance test shall be carried out using the configuration specified in 6-11.4 at the same ventilation rates. The difference in pressure between the two tests shall be calculated by subtracting the values obtained using the configuration defined in 6-11.4 from the values obtained using the configuration specified in Section 6-1.”. Revise text to read as follows: 6.11.5.18 The facepiece pressure during the entire test shall be read from the strip chart recorder and corrected by adding the value of the difference in pressure calculated in 6.11.5.8 (refer to above new section) to determine pass/fail as specified in 5.11.1. SUBSTANTIATION: The effect of the 25 ft. hose interconnecting the test head mannequin with the breathing machine needs to be accounted for during the heat and flame test, with a procedure similar to that of the previous edition of this standard.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See 8.11 in the ROC preprint for revised text.

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(Log #46)1981-195-(6-12) : Accept SUBMITTER: K. R. Ethridge, Texas Commission on Fire ProtectionCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise 6.12 so that it more accurately reflects the purpose of the section. 6.12 Redundant End of Service Time Indicator Test EOSTI Independent Activation Test SUBSTANTIATION: The current wording seems to imply that the purpose is only to test for activation of each EOSTI rather than insuring that they are totally independent.COMMITTEE ACTION:AcceptCOMMITTEE STATEMENT: See action taken on Comment 1981-109 (Log #39)

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1981-196-(6-12.4.3) : Accept in Principle SUBMITTER: K. R. Ethridge, Texas Commission on Fire ProtectionCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise 6.12.4.2 to clarify test procedure for each EOSTI. 6.12.4.2 With the sensing mechanism blocked as indicated in Section 6.12.5.1 6.12.4.1, the air flow test specified in Section 6.1 shall be performed until the cylinder pressure drops below 17 BAR (250 PSI). SUBSTANTIATION: This wording is needed to require the EOSTI to be tested to insure that it will continue to function as long as there is usable air.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See 8.13 in ROC preprint.

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(Log #48)1981-197-(6-12.5.1) : Accept in Principle SUBMITTER: K. R. Ethridge, Texas Commission on Fire ProtectionCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add new 6.12.5.1 to specify activation requirements for this test. 6.12.5.1 Each EOSTI shall demonstrate independent activation meeting the requirements specified in 4.2.3 and remain active as specified in 5.12.2. SUBSTANTIATION: This wording is necessary to specify activation requirements for this test.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See new text for 5.1.2.1 and 6.1.5.6 that covers these issues.

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(Log #49)1981-198-(6-12.6) : Accept in Principle SUBMITTER: K. R. Ethridge, Texas Commission on Fire ProtectionCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise 6.12.6 to include duration of the EOSTI as part of the pass/fail criteria. 6.12.6 Interpretation. The peak inhalation, peak exhalation, and proper activation and proper duration of the EOSTI shall be used to determine pass or fail performance. One or more specimens failing this test shall constitute failing performance. SUBSTANTIATION: Duration is a critical part of EOSTI performance and must be considered when testing.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See new 7.1.1 in ROC preprint in action taken on Comment 1981-109 (Log #39). This test is not conducted on the breathing machine and the inhalation and exhalation points cannot be recorded.

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(Log #195)1981-199-(6-13) : Reject SUBMITTER: Robert W. O’Gorman, Intertek Testing Services/ETL SEMKOCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Remove the entire section. SUBSTANTIATION: The current NFPA 1981 1997 Edition (section A-2-1.1.2H) and the draft copy (Section A-2.1.1.28) identify that “the full effect of increased dead air space has not been demonstrated. However, scientific work done in this area shows that an increase in CO2 in the inhalation air leads to increased ventilation...” Section 8.14 of the proposed test (EN 136.1998) requires the use of a device that will cost between $50-$80k to determine if dead air CL2 exceeds 1.5 percent by volume as defined in Section 5.13 of the NFPA 1981 proposed. Since I personally am not aware of any new scientific evidence that has been presented since the 1997 standard’s comment was first placed within the appendix, it is hard to accept that we will add this test and the 1.5 percent by volume as a protective measure for fire fighters when Section 7.18 of EN 136.1998 requires that the dead space CO2 not exceed 1 percent.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The submitter was present at the ROC meeting on 27 April 01 and requested that the committee not process this comment.

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(Log #151)1981-200-(6-13.4) : Accept in Principle SUBMITTER: Ian Maxwell, Inter Spiro Europe ABCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: To ensure correct wording from EN136 the correct date reference should also be included: EN136: 1998 SUBSTANTIATION: See above.COMMITTEE ACTION:Accept in Principle Add to Chapter 2: EN Publication (CEN ) European Committee for Standardization Central Secretariat rue de Stassart 36 B 1050 Brussels EN 136, Respiratory Protection Devices-Full Face Masks-Requirements, testing, marking. 1998 edition.COMMITTEE STATEMENT: The committee added the reference and edition to Chapter 2 where such specific edition references are stated.

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(Log #111)1981-201-(7-1.3) : Accept SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: ANSI/UL 913, Standard for Intrinsically Safe Apparatus and Associated Apparatus for Use in Class I, II, and III, Division I Hazardous Locations, 1988 1997. ANSI Z34.1, American National Standard for Third Party Certification Programs for Products, Processes, and Services, 1993. SUBSTANTIATION: ANSI/UL 913 has been revised with a new date of 1997. Also, ANSI Z34.1 has been replaced by ISO/IEC Guide 65.COMMITTEE ACTION:Accept

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(Log #112)1981-202-(7-1.5) : Accept SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: ISO/IEC Guide 25 17025, General Requirements for the Competence of Calibration Testing and Testing Calibration Laboratories, 1999. SUBSTANTIATION: ISO Guide 25 has been revised to a Standard with a new date of 1999. Also, ISO Guide 65 has been added since it replaced ANSI Z34.1.COMMITTEE ACTION:Accept

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(Log #191)1981-203-(7-1.5) : Accept SUBMITTER: Robert W. O’Gorman, Intertek Testing Services/ETL SEMKOCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise Section 7.1.5 to read: “ISO Guide 17025 General Requirements for the Competence of Testing and Calibration Laboratories.” SUBSTANTIATION: ISO Guide 25 has been superseded by ISO Guide 17025.COMMITTEE ACTION:Accept

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489

NFPA 1981 — May 2002 ROC— Copyright, NFPA(Log #50)

1981-204-(7-4.2.1) : Reject SUBMITTER: K. R. Ethridge, Texas Commission on Fire ProtectionCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise the paragraph to use a term consistent with the Section. 7.4.2.1 SCBA EOSTI signaling device(s) shall be measured tested for proper performance in accordance with the manufacturer’s instructions. SUBSTANTIATION: The current wording would require the performance of the EOSTI to be measured which may exceed the capability of the Organization, Testing for proper performance may not require measuring equipment.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: Such issues are not addressed in NFPA 1981. There is/was no 7.4.2.1 in the ROP.

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(Log #113)1981-205-(A-2-2.2.12) : Accept SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: A2.2.2.12 A2.2.10 Such inspections should include, in most instances, witnessing of production tests. With certain products the certification organization inspectors should select samples from the production line and submit them to the main laboratory for countercheck testing. With other products, it might be desirable to purchase samples in the open market for test purposes. For further information and guidance on recall programs, see 21 CFR7, Subpart C. SUBSTANTIATION: Revise Paragraph number to reflect Appendix information for Paragraph 2.1.10. Also, delete sentence on recall guidance, since this Paragraph does not deal with the issue of recalls.COMMITTEE ACTION:Accept

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(Log #12)1981-206-(A-2-2.10) : Accept SUBMITTER: Robert Sell, David Hodson, Draeger Safety, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Annex information is labeled incorrectly as A.2.2.12 and should be renumber as A.2.2.10. Remove last statement from new Annex A.2.2.10; for further information and guidance on recall programs, see 21 CFR 7, Subpart C. SUBSTANTIATION: Correct Annex reference.COMMITTEE ACTION:Accept

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(Log #31)1981-207-(A-2-2.10.7) : Accept in Principle SUBMITTER: W. Lee Birch, Luxfer Gas CylindersCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise the following text to read as follows: “This annex is provided as an informative guide to the certification organization on how to make the determination of what to recommend to the product or product component manufacturer. The determination of what recommendation The appropriate action the certification organization should make to undertake in the event that a specific problem is identified should be taken into consideration...” The last section: “The following evaluation results and recommendations are suggested actions for handling substantiated produce defects or product malperformance are recommended: Critical defect: recommend a product recall. Major A defect: recommend a product recall or safety alert depending on the nature of the specific defect. Major B defect: recommend a safety alert or make no recommendation, depending on the nature of the specific defect Minor defect: no recommendation”. SUBSTANTIATION: This annex should be made clear that it is informative only. The wording here is deficient of a proper criteria for recall or safety alert. The annex is written subjectively and without quantitative, statistical or objective criteria. An alternate would be to delete the annex. NIOSH regulates (is the regulatory authority) and approves SCBAs. Although this statement is obvious, what this means is that NIOSH regulates and controls SCBAs. Legally (from NIOSH and legal counsel discussions), the NFPA cannot direct another entity or take on the functions of the regulatory authority. In this case, regarding SCBA units, the functions of NIOSH is to specify how and under what conditions a product recall or alert can be performed. The NFPA cannot delegate NIOSH authority to any other entity. The certification organization (CO) cannot be directed in 1981 to issue an alert or recall, nor is to CO entitled to punish or take action against a manufacturer (delisting or canceling certifications) who doesn’t ‘cooperate’ in the CO alert or recall efforts. If a national regulatory authority (e.g., NIOSH, DOT, FDA, etc,) regulates a product (e.g., SCBA units, SCBA DOT cylinders, etc.), only that regulatory authority can issue a recall or alert regarding the regulated product. If the CO tries to enforce NFPA

specifications where a regulatory authority has jurisdiction, legal counsel assures us that the CO will be involved in an onerous and probably costly legal defense, which it will ultimately loose. The TCC proposals should thus be re-written such that the CO is to give recommendations× for alerts and recalls. An alternative would be to delete the TCC proposals on alert and recall. A manufacturer of a regulated ( or non-regulated) product always has the option to perform a product recall or issue an alert, based upon their own findings, or the recommendation of the CO. Thus, the wording proposed is with the intent to change the TCC proposal regarding SCBAs, such that the CO will give recommendations, rather than require, alerts and recalls of nationally regulated products. COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See action taken on Comment 1981-10 (Log #210).

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(Log #85)1981-208-(A-2-2.10.7) : Accept in Principle SUBMITTER: Nicholas J. Curtis, Lion Apparel, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: “The findings of the certification organization should be based upon the severity of the risk to the safety and health of end users. Testing of affected product against the requirements of the standard to which it was listed as compliant may be performed to assist in determining the extent of the reported failure(s). It is also recognized that safety alerts and product recalls can be determined to be necessary for problems or circumstances not anticipated by the requirements of this standard or other applicable public safety rules. As with other bases for notifications of repair, replacement of refund issuance of safety alerts and product recalls, the decision to initiate action based on such problems and circumstances should be based upon the specific product hazard to end users. As a guideline for determining whether a safety alert, a product recall, or no action is required as a result of an investigation, findings regarding compliant products or compliant product components should be classified among the following categories: Critical - a defect that judgement, and experience and the requirements of the standard to which the compliant product was listed as compliant indicate is likely to result in a condition immediately hazardous to life or health for individuals using or depending upon the compliant product (in this case, an SCBA). Major A - a defect, other than critical, that is likely to result in failure to a degree that the compliant product will not provide protection (in this case, an SCBA that will not provide respiratory protection), or a defect that severely reduces protection and is not detectable by the end user. Major B - A defect, other than critical or Major A, that is likely to result in reduced protection, and is detectable by the end user. Minor - a defect, other than critical, Major A, or Major B, that is not likely to materially reduce the usability of the compliant product for its intended purpose, or a defect that is a departure from established standards and has little bearing on the effective use or operation of the compliant product. The following actions...specific defect.” SUBSTANTIATION: Clarifies language and reinforces the nature of recalls or alerts as being related to safety issues. Focusses investigative testing against the standard to which a product was certified, and the protective qualities which were intended at the time of manufacturing.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See action taken on Comment 1981-10 (Log #210).

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(Log #124)1981-209-(A-2-2.10.7) : Reject SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Delete all of Paragraph A.2.2.10.7. SUBSTANTIATION: With the proposed addition of new Paragraph 2.1.4.1, Paragraph A.2.2.10.7 is not needed.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: See action taken on Comment 1981-10 (Log #210).

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(Log #173)1981-210-(A-2-2.10.7) : Accept in Principle SUBMITTER: Patricia A. Freeman, Globe Manufacturing Co., Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text as follows: “The determination of the appropriate action for the certification organization to undertake in event that a specific problem is identified should take into consideration product age, type of use and conditions to which it has been exposed, and the care and maintenance that has been provided,. the severity of the problem and its potential consequences to the safety and health of end users. Testing of affected product against the requirements of this standard should may be performed to assist in determining the severity of the problem, at the discretion of the certification organization. Remainder of section to be deleted.

490

NFPA 1981 — May 2002 ROC— Copyright, NFPASUBSTANTIATION: You simply cannot treat used, after market product as new. The third party certification organizations consistently point out that the mark is only good for new product, and is not an indicator that used product will perform to the same level. Consideration must be given to the age of the product, the type of use it has seen, the environments to which it has been exposed, the care and maintenance that has been provided, and any other factors outside of the manufacturer’s control. A mandated product recall can only be applicable to product that did not meet the requirements at the time it was produced, since all existing requirements are based upon testing new product. Under the revised language, complaints based upon used product would be investigated and if it was found that a product did not meet the standard at the time it was produced, then a product recall would be mandated. If the product met all of the requirements of the standard but has become unsafe as a result of use, exposure, neglect, or other conditions outside of the manufacturer’s control, then a safety alert would be appropriate, since not all departments treat equipment the same. To try and prioritize safety attributes for protective equipment is to suggest that some of the requirements in the standard are not as critical as others. If this is true and some requirements are more “safety related” than others, why are these requirements in the standard at all? As a long time participant in, and supporter of the NFPA standards, I do not want to be in a position of now explaining that some requirements are more important than others.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See action on Comment 1981-10 (Log #210). The committee feels that advisory guidance for evaluating product hazards and the possible actions to be taken for each level of product hazard important information. The technical committee has revised the text in action taken on Comment 1981-10 (Log #210 )and incorporates some text from the submitter. This annex item is now numbered as A.2.2.11.9. The basis for this annex is based on 42 CFR 84 Suppart E, Section 84.41

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(Log #205)1981-211-(A-2-2.10.7) : Reject SUBMITTER: Denise N. Statham, Southern Mills, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: “... Testing of affected product against the requirements of this standard should may be performed to assist in determining the severity of the problem...”SUBSTANTIATION: NFPA standards as written qualify only new products, those that have never been issued or used. To mandate that used products to tested against an NFPA standard implies otherwise and sets a dangerous precedent. This system would not account for loss of performance due to product use, misuse, improper storage, age, etc.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The term “may” cannot be used in the document.

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(Log #13)1981-212-(A-2-2.12) : Reject SUBMITTER: Robert Sell, David Hodson, Draeger Safety, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Section 2.2.12 indicates Annex material and none is available. Add the following new text: “For further information and guidance on recall programs, see Title 21, Code of Federal Regulations, part 7, Subpart C (21CFR 7, Subpart C). SUBSTANTIATION: Using the same text and reference that was used in NFPA 1981, 1997 ed., A.2-2.9.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: Action taken on Comment 1981-10 (Log #210) has been replaced. The 2.2.12 text and the submitters recommendation is no longer valid.

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(Log #67)1981-213-(A-2-2.12) : Accept SUBMITTER: Bill Grilliot, Morning Pride Mfg Co.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: This appendix item does not seem to refer to 2-2.12 section in body of standard - relates more to 2-2.10.1 in body. SUBSTANTIATION: Editorial.COMMITTEE ACTION:AcceptCOMMITTEE STATEMENT: See action taken on Comment 1981-205 (Log #113).

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(Log #206)1981-214-(A-2-7.2 (New) ) : Accept in Principle SUBMITTER: Jeffrey O. Stull, International Personnel Protection, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Add new Paragraph A.2.7.2:

The manufacturer plan for corrective action may take the form of a replacement part in repair kit - sent to the purchaser then the manufacturer is able to demonstrate to the certification organization that the proposed action eliminates the safety hazard(s).SUBSTANTIATION: One plausible means for conducting a recall could involve the manufacturer’s provision of repair kit in replacement part. This could provide a satisfactory way of correcting the safety hazard as long as considered acceptable to the certification organization.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: The Committee used the text for all documents in this project. See 4.2.10, 4.6, 4.7, and 4.8 in the ROC preprint.

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(Log #15)1981-215-(A-5-10) : Accept SUBMITTER: Robert Sell, David Hodson, Draeger Safety, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: “As The communications test is the only test that requires human subjects, there were variations...” SUBSTANTIATION: Wording to be removed since the end-of-service-time-indicator tests will also require human test subjects.COMMITTEE ACTION:Accept

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(Log #127)1981-216-(A-6-1.1.4) : Accept SUBMITTER: Jack Burt, BiosystemsCOMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: A.6.1.14 The following is the recommended calibration procedure for NFPA Model 327-6 a breathing machine. (a) Set up equipment. 1. Remove plug fitting and open valve at side port of the breathing machine (BM), then close the valve to the test headform. 2. Connect a nonreturn two-way valve to the side port the breathing machine. (See Figure A.6.1.14.)3. 2. Make sure all gas has been expelled from a gas collection bag by rolling the bag up. Connect the bag to the dead-ended gas-collection port of a three-way valve. (See Detail 2 of Figure A.6.1.14) A recommended gas-collection bag is a 120-L meteorological bag or a 150-L Douglas bag. Equivalent or similar collection bags can be substituted. 4. 3. Connect the common port of the three-way valve to the exhalation port of the nonreturn two-way valve. (See Detail 3 of Figure A.6.1.14.) 5. 4. Connect a transducer to a pressure tap on the collection side of the three-way valve. The transducer output goes to the recorder. (b) Collect gas. 1. With the vent port of the three-way valve open, start BM and allow BM to warm up for at least 10 minutes. 2. After the warm-up period, adjust the speed to approximately 30 rpm if the machine has not been calibrated within the last few days. If the machine has recently been calibrated, leave it at its preset adjustment. breathing rate to 3.4 L tidal volume and 30.3 breaths/minute. 3. Set the chart speed on the recorder to 60 cm/min and start the recorder. 4. At the start of an inhalation, turn the three-way valve so that the air exhaled from the BM goes into the collection bag. (See Detail 4 of Figure A.6.1.14.) 5. Each exhalation stroke should produce a positive peak on the strip-chart recording, which can be used as a counter. The operator can use a substitute method to count the exhaled tidal volumes (TV) that go into the bag. 6. After 30 to 35 exhalations, turn the three-way valve at the start of an inhalation so that the gas collection port is closed and the BM vents to atmosphere. Turn off the recorder. (c) Measure the volume (liters) of gas collected (V L). 1. The recommended method to measure the volume of gas in the bag is to transfer the air into a spirometer. Make sure the bag is completely empty by rolling it up. 2. Another method to measure the gas volume in the bag is to slowly empty the bag through a calibrated dry-gas meter. Ensure that a correction factor is applied as required. (d) Calculate minute volume. 1. From the positive peaks on the strip chart recording , count the number of exhalations (NE) that were made into the bag or use your own counting method if you are sure it is correct. 2. Measure the total distance (in centimeters) between the peaks of 30 exhalations, which should be approximately 60 cm at a chart speed of 60 cm/min. (See Detail 5 of Figure A.6.1.14.) If the pressure in the gas-collection port has not been measured, the operator can use another method to accurately measure the breathing machine’s rpm. 3. Calculate rpm. ( no change in equation) 4. Determine the tidal volume (TV). (no change in equation) 5. Determine the minute volume, volume (V M). (no change in equation) NOTE: A record of TV and rpm should be maintained for each machine. As the seals on the pistons wear, the TV for a given rpm might decrease, an indication that the seals should be replaced. (e) Adjust minute volume. 1. If the V M is between 100 L and 106 L, no adjustment is necessary and the BM is ready to perform the NFPA air flow Air Flow Performance Test at the present rpm setting.

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NFPA 1981 — May 2002 ROC— Copyright, NFPA 2. If the V M < 100L, the rpm must be increased and the V M recalculated. 3. If the V M > 106 L, the rpm must be decreased or > 106 L, the breathing rate must be adjusted appropriately and the V M recalculated.SUBSTANTIATION: Breathing machine calibration procedure revised to be generic in nature and not specific to a particular breathing machine design.COMMITTEE ACTION:Accept

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(Log #7)1981-217-(A-6-1.14) : Reject SUBMITTER: Robert Sell, David Hodson, Draeger Safety, Inc.COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Remove this Appendix reference A.6.1.14. SUBSTANTIATION: Appendix reference pertains to the NFPA 1981, 1997 edition and there is no Paragraph or section that is contained in the ROP for this.COMMITTEE ACTION:RejectCOMMITTEE STATEMENT: The appendix was revised with action on Comment 1981-216 (Log #127).

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(Log #114)1981-218-(A-6-1.14) : Accept in Principle SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: A6.1.14 A6.1.5.1 The following is the recommended calibration procedure for NFPA Model 327 6 the breathing machine shown in Figure 6.1.4.13. SUBSTANTIATION: Since it pertains specifically to the Model 327-6 breathing machine, Paragraph A6.1.14 should be reviewed in detail for applicability to the new breathing machine. Also, the Paragraph number should be revised as Appendix informantion to Paragraph A6.1.5.1.COMMITTEE ACTION:Accept in PrincipleCOMMITTEE STATEMENT: See action taken on Comment 1981- 216 (Log #127).

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(Log #115)1981-219-(A-6-3.3(h)) : Accept SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: The ballast rod is machined from ASTM B16 brass, (hard). The machining details are provided in Figure 6.3.3.2 6.3.4.8. Care should be taken to ensure that the rod does not interfere with the cylinder at the valve end. This might require machining a short thread relief at the cylinder valve end of the ballast rod, which is indicated in Figure 6.3.3.2 6.3.4.8. SUBSTANTIATION: Corrected references to the surrogate cylinder Figure.COMMITTEE ACTION:Accept

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(Log #116)1981-220-(A-6-8.4.4) : Accept SUBMITTER: Stephen Sanders, Safety Equipment Institute (SEI)COMMENT ON PROPOSAL NO:1981-24RECOMMENDATION: Revise text to read as follows: A6.8.4.4 A6.8.4.7 Silica flour could present a health hazard. When using silica flour, assure that the chamber is functioning properly and not leaking. SUBSTANTIATION: Corrected Paragraph number to coincide with reference from body of document.COMMITTEE ACTION:Accept

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