october 16 th i. ii. introductions- members and …...paul holzapfel asv / wheeled coach industries,...

Meeting Agenda First Draft Meeting NFPA 1917, Standard for Automotive Ambulances

Technical Committee on Ambulances October 16th-18th, 2013

Indianapolis, IN

I. Welcome and call to order by Chairman Fischler

II. Introductions- members and guests

III. Review and accept minutes from the October 2011 meeting

IV. NFPA update – Ken Holland, Staff Liaison

V. Review of cycle for NFPA 1917 and discussion

VI. Discussion on emerging issues or technologies

VII. Break into task groups

VIII. Public input/first revision development for chapters 1-3

IX. Public input/first revision development for chapters 4 and 5

X. Public input/first revision development for chapter 6

XI. Public input/first revision development for chapters 7 and 8

XII. Public input/first revision development for chapter 9

XIII. Other Business- New and Old

XIV. Next Meeting- SDM for NFPA 1917

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NFPA TECHNICAL COMMITTEE ON AMBULANCES

MEETING MINUTES

October 12, 2011

Holiday Inn Inner Harbor

Baltimore, MD Principal and Voting Alternate Members Attending: David H. Fischler – Chairman Fire Chief’s Council of Suffolk County (NY) Andrew J. Alger Progressive Engineering, Inc. Wesley D. Chestnut Spartan Motors, Inc. David B. Cole Life Line Emergency Vehicles James D. Green National Institute for Occupational Safety & Health Thomas Hillenbrand Underwriters Laboratories, Inc. Paul Holzapfel ASV / Wheeled Coach Industries, Inc. James J. Juneau Juneau, Boll, Stacy & Ucherek, PLLC J. Roger Lackore Oshkosh Corporation Kevin Lyons (Alt.) American Ambulance Association Joseph V. Maruca National Volunteer Fire Council John W. McDonald US General Services Administration Michael T. McEvoy NY State Emergency Medical Services Council Mark D. Meijer American Ambulance Association Robert Neitzel Navistar International Corporation Mark Postma Nat’l Assn of Emergency Medical Technicians Suzanne Prentiss Nat’l Assn. of State EMS Officials Steven Spata Nat’l Truck Equipment Assn. AMD Steven A. Rabine Glatfelter Insurance Group (VFIS) Fred Schimmel (Alt) SJC Industries Corporation Steve Silloway (Alt) American Medical Response, Inc. Kenneth Southard Plano (TX) Fire Department Erik Switzer (Alt) National EMS Management Association William J. Tansey Ballston Lake, NY William Walton, Jr. Delaware State Fire School Stephen Wilde EVT Certification Commission Laurence J. Stewart NFPA Staff Liaison May 11, 2010 0800 Chairman Fischler called the meeting to order. Self-introduction of all attending Committee members, alternates and guests. The proposed minutes of the Committee’s February 8-10, 2011 meeting in Dallas, Texas, were reviewed and discussed, and proposed corrections were suggested.

MOTION by Mr. Southard to accept and approve the minutes of the February 8-10, 2011 Committee meeting (Dallas, TX), as corrected and modified.

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VOTE: MOTION CARRIED 0815 Guest Presentation by Mr. Grant: NFPA Fire Protection Research Foundation research director Casey C. Grant, P.E. spoke to the Committee regarding the NFPA Research Foundation’s final report on Analysis of Ambulance Crash Data. Mr. Grant described the logistics and data collection methodology involved in developing the research upon which the report was based, the various sources from which the reported data was derived, and the potential limitations affecting interpretation of the reported data. Mr. Grant then answered questions from members of the Committee regarding the NFPA report, and the data reporting and collection methodology. Other potential sources of ambulance injury data and alternate data collection methodologies were discussed by the Committee members in an effort to develop more robust data with a much higher level of detail, and thus greater interpretative reliability. 0900 Document Revision Cycle Status - Chairman Fischler reported that the NFPA Standards Council has approved the Committee’s proposal to put the NFPA 1917 standard back into revision cycle immediately after the new standard becomes effective in January, 2013. Mr. Stewart described some changes to the NFPA nomenclature and processes, and explained the typical timetable that would apply to the new standard if it were immediately placed back into the cycle under the NFPAs new timetables. The Report on Comments (ROC) will be published in February, 2012, after which the public can only propose further changes through submission of a Notice of Intent to Make a Motion (NITMAM) to the NFPA Standards Council. NITAM’s must be submitted by April 6, 2012, and would be considered at the NFPA General Membership Meeting in June, 2012. If no NITMAM is submitted, the current document would be submitted for NFPA approval as a “consent document.” In its current cycle, the initial NFPA 1917 document will be effective on January 1, 2013. If the document is placed back in cycle immediately thereafter, the next version of the standard would be expected to become effective in January, 2015. 0910 The Committee was divided into its subject area task groups for preliminary review, discussion and analysis of the 46 public comments which have been submitted for consideration. Mr. Stewart restated basic NFPA procedural instructions for processing of public comments in the task groups. 0915-0930 BREAK 0930-1300 Task Group Meetings - The Committee’s subject-area task groups were convened to separately consider, analyze and discuss each of the 46 submitted public comments, and to thereafter return each task-group’s recommendations to the full Committee for further action. 1300 Full Committee Proceedings - Chairman Fischler reconvened the full Committee to discuss the various subject-area task group recommendations, and to separately consider and vote upon each of the 46 submitted public comments. 1305 NFPA Technical Committee on EMS - The Committee heard from Ken Holland, NFPA Staff Liaison for the NFPA Technical Committee on Emergency Medical Services, who discussed his Committee’s efforts to address EMS related issues and formulate national standards relating to EMS issues, as appropriate. His committee will not address the qualifications for emergency medical personnel, but will address career progression and development, as well as EMS provider occupational safety and health issues.

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1315 Chairman Fischler reviewed the procedures and standards of conduct for the full Committee meeting, after which the full Committee began its consideration of the various public comments by task group subject area, as follows: Administration Task Group – Mr. McDonald MOTION by Mr. McDonald to ACCEPT Logs 7, 8, 32, 37 and 9. MOTION CARRIES Electrical Task Group – Mr. Wilde MOTION by Mr. Wilde to ACCEPT Log 3. MOTION CARRIES MOTION by Mr. Wilde to ACCEPT IN PRINCIPLE Log 28. MOTION CARRIES MOTION by Mr. Wilde to REJECT Log 29 . MOTION CARRIES MOTION by Mr. Wilde to ACCEPT Log 2. MOTION CARRIES

MOTION by Mr. Wilde to MODIFY Log 15 to include language that would permit a single-use override on the proposed generator audible warning, which override would automatically recycle upon each restart of the vehicle engine. MOTION CARRIES MOTION by Mr. Wilde to ACCEPT IN PRINCIPLE, as modified, Log 15.

MOTION CARRIES MOTION by Mr. Wilde to ACCEPT IN PRINCIPLE, as modified, Log 14. MOTION CARRIES MOTION by Mr. Wilde to REJECT Log 30. MOTION CARRIES Body Task Group – Mr. Holzapfel

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MOTION by Mr. Holzapfel to ACCEPT Log 20. MOTION CARRIES MOTION by Mr. Holzapfel to ACCEPT Log 33. MOTION CARRIES

MOTION by Mr. Holzapfel to ACCEPT Logs 10 and 11, along with an added requirement that the AMD 007 carbon monoxide test standard (type certification) be added to section 9.7 of the draft standard.

MOTION CARRIES

MOTION by Mr. Holzapfel to REJECT Log 4. The Committee will propose Annex language that addresses the floor loading height issue.

MOTION CARRIES

MOTION by Mr. Holzapfel to ACCEPT a Committee comment that adds cautionary instruction to the document Annex regarding maximum load height.

MOTION WITHDRAWN until proposed Annex language can be submitted for Committee consideration.

MOTION by Mr. Holzapfel to REJECT Logs 39 and 40. MOTION CARRIES MOTION by Mr. Holzapfel to ACCEPT Log 21. MOTION CARRIES MOTION by Mr. Holzapfel to REJECT Log 22. MOTION CARRIES

MOTION by Mr. Holzapfel to ACCEPT IN PRINCIPLE Log 6. MOTION FAILS MOTION by Mr. Holzapfel to ACCEPT Log 26 . MOTION CARRIES MOTION by Mr. Holzapfel to ACCEPT IN PRINCIPLE Log 1.

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MOTION FAILS MOTION by Mr. Holzapfel to ACCEPT Log 27. MOTION CARRIES

MOTION by Mr. Lackore to remove the AMD 007 carbon monoxide test standard from section 9.7 because the requirement for a CO detector in the patient compartment obviates the need for further CO testing.

MOTION FAILS MOTION by Mr. Schimmel to add the AMD 007 carbon monoxide test standard (type certification) to section 9.7 of the draft standard. MOTION CARRIES

Chassis Task Group – Mr. Lackore MOTION by Mr. Lackore to REJECT Log 5. MOTION CARRIES MOTION by Mr. Lackore to REJECT Log 17. MOTION CARRIES MOTION by Mr. Lackore to REJECT Log 35. MOTION CARRIES MOTION by Mr. Lackore to REJECT Log 18. MOTION CARRIES

MOTION by Mr. Lackore to ACCEPT IN PRINCIPLE Log 19, 34, 36 & 43 by changing section 5.9.1 to allow for easily removable hub caps.

MOTION CARRIES MOTION by Mr. Lackore to REJECT Log 38. MOTION CARRIES

MOTION by Mr. Lackore to ACCEPT IN PRINCIPLE Log 13 with new language in section 5.14.4 to require that side view mirrors extend beyond the outside of the modular body do allow for an unobstructed view of the side of the veicle.

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MOTION CARRIES MOTION by Mr. Lackore to REJECT Log 23. MOTION CARRIES MOTION by Mr. Lackore to REJECT Log 24. MOTION CARRIES

MOTION by Mr. Lackore to add a Committee proposal that reduces the minimum seat back height requirement in section 6.21.7.4 from 36 inches to 32 inches, in compliance with FMVSS 202A, recognizing that taller seatbacks may not currently be available from seat manufacturers .

MOTION CARRIES

MOTION by Mr. Greene to delete from the draft standard sections 6.21.1, 6.21.1.1, 6.21.1.2 and 6.21.1.3 because ongoing NIOSH research to identify the most appropriate crashworthiness testing requirements is still underway, and the listed SAE J2917 crash pulse test requirements now in section 6.21.1 et seq. of the proposed standard should only be adopted as part of a comprehensive testing matrix that is supported by research.

MOTION FAILS MOTION by Mr. Lackore to REJECT Log 25. MOTION CARRIES MOTION by Mr. Lackore to REJECT Log 41. MOTION CARRIES MOTION by Mr. Lackore to REJECT Log 31. MOTION CARRIES

MOTION by Mr. Lackore to ACCEPT IN PRINCIPLE Log 42, with language in section 6.21.8.2 that would require that the primary patient care seat be located within six inches (152 mm) of the midpoint between the cot backrest hinge and the head end of the cot.

MOTION CARRIES

MOTION by Mr. Lackore to ACCEPT IN PRINCIPLE Log 12 requiring some type audible/visual indicator reflecting seat belt/restraint use or non-use. The submitter of this comment, Mr. Tansey, described the rationale supporting the requirement for some type of restraint system warning device requirement. The Committee reworded the proposed comment to provide in section 6.21.10 for a minimum seat belt visual or audible warning requirement.

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MOTION CARRIES MOTION by Mr. Lackore to ACCEPT Log 16. MOTION CARRIES 1825 Chairman Fischler called for further discussion of the floor loading height Annex language that had been previously raised and discussed by the body task group in conjunction with Log 4. Annex language for section A 6.14.2 was proposed as a Committee comment.

MOTION by Mr. Lackore to ACCEPT the proposed Annex 6.14.2 language as a Committee proposal.

MOTION CARRIES 1840 Chairman Fischler congratulated the Committee members on their professionalism and cooperation in working to develop this new standard. Mr. Stewart thanked the Committee for its efforts in developing the new standard, and reviewed with the Committee the anticipated timetable for remaining NFPA procedures and approvals that are necessary before the standard will be released and become effective. A final written ballot will be circulated to Committee members on November 18, 2011, followed by the published Report on Comments on February 24, 2012. The standard would then be reviewed and approved at the NFPA General Membership meeting in June, 2012, and the standard would thereafter be printed in final form around mid-July, 2012. The anticipated effective date of the new NFPA 1917 Standard is January 1, 2013. To the extent that state requirements are dependent upon the NFPA standard, those jurisdictions should be reviewing the proposed standard as soon as possible. 1845 There being no further business to be addressed by the Committee, the meeting was ADJOURNED. ATTEST James J. Juneau Committee Secretary

Public Input No. 138-NFPA 1917-2013 [ Global Input ]

Global change: I did not go through and mark up the entire document for this global change, but the intent is that it will happen.Where in the document the word “oxygen” is used, replace with “medical gas”.

Statement of Problem and Substantiation for Public Input

Substantiation: Critical care ambulance services carry medical gasses in addition to oxygen. As worded the current language suggests it would be prohibited for those other gasses to be stored in the oxygen compartment when that is not the case. The term oxygen is limiting. The replacement of the tem oxygen with medical gas will allow EMS operations to function in the manner they are authorized to by applicable State laws and regulations.

Submitter Information Verification

Submitter Full Name: Ronald ThackeryOrganization: American Medical Response, IncStreet Address: City:State: Zip: Submittal Date: Mon Jul 01 16:22:23 EDT 2013

Copyright Assignment

I, Ronald Thackery, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement ofProblem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am Ronald Thackery, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature

Page 1 of 654National Fire Protection Association Report

7/23/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...


Global change: Anywhere in the document the word “oxygen” is used, replace it with “medical gas”.


Substantiation: Critical care ambulance services carry medical gasses in addition to oxygen. As worded the current language suggests it would be prohibited for those other gasses to be stored in the oxygen compartment when that is not the case. The term oxygen is limiting. The replacement of the tem oxygen with medical gas will allow EMS operations to function in the manner they are authorized to by applicable State laws and regulations.


Submitter Full Name: ELENA SIERRAOrganization: Association of Air Medical Services (AAMS)Affilliation: Association of Air Medical Services (AAMS)Street Address:City: State: Zip:Submittal Date: Wed Jul 03 15:08:10 EDT 2013


I, ELENA SIERRA, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement ofProblem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am ELENA SIERRA, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature




Anywhere in the document the word "oxygen" is used, replace it with "medical gas".

Additional Proposed Changes

File Name Description ApprovedSignature_Page.pdf Signature page


Critical care ambulance services carry medical gasses in addition to oxygen. As worded the current language suggests it would be prohibited for those other gasses to be stored in the oxygen compartment when that is not the case. The term oxygen is limiting. The replacement of the tem oxygen with medical gas will allow EMS operations to function in the manner they are authorized to by applicable State laws and regulations.


Submitter Full Name: Richard SherlockOrganization: Assn. of Air Medical ServStreet Address: City: State:Zip: Submittal Date: Fri Jul 12 11:45:55 EDT 2013


I, Richard Sherlock, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am Richard Sherlock, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature



Public Input No. 64-NFPA 1917-2013 [ New Section after 2.3.7 ]

Testing StandardsAdd new 2.3.7 and renumber accordingly to where the NEW 2.3.7 will list in order the AMD 1-25 standards. (This will also result in the deletion of chapter 9 since the AMD testing standards will be part of the requirements of this standard through their reference in this chapter.)


Substantiation: The technical committee on ambulances should incorporate by reference all AMD testing standards into NFPA 1917. By doing so, the technical committee will not need to update this standard in response to any revisions to testing standards at AMD. AMD is the appropriate body to develop and disseminate those testing standards. The AMD standards have served for many years as a solid basis for testing requirements for the KKK standard upon which much of the NFPA 1917 standard is based. The bylaws and semi-annual meetings of the AMD allow for more nimble adaptation to changes appropriate for the testing standards.








Public Input No. 433-NFPA 1917-2013 [ Section No. 2.3.7 ]

Add new 2.3.7 and renumber accordingly to where the NEW 2.3.7 will list in order the AMD 1-25 standards. (This will also result in the deletion of chapter 9 since the AMD testing standards will be part of the requirements of this standard through their reference in this chapter.)2.3.7 UL Publications.

Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062-2096, www.ul.com.

ANSI/UL 153, Standard for Portable Electric Luminaires, 2002, Revised 2010.

ANSI/UL 498, Standard for Safety Attachment Plugs and Receptacles, 2001, Revised 2010.

ANSI/UL 969, Standard for Marking and Labeling Systems, 1995, Revised 2008.

ANSI/UL 1598, Luminaires, 2008, Revised 2010.

ANSI/UL 2034, Standard for Safety, Single and Multiple Station Carbon Monoxide Alarms, 2008, Revised 2009.


File Name Description ApprovedSignature_Page.pdf Signature Page


The technical committee on ambulances should incorporate by reference all AMD testing standards into NFPA 1917. By doing so, the technical committee will not need to update this standard in response to any revisions to testing standards at AMD. AMD is the appropriate body to develop and disseminate those testing standards. The AMD standards have served for many years as a solid basis for testing requirements for the KKK standard upon which much of the NFPA 1917 standard is based. The bylaws and semi-annual meetings of the AMD allow for more nimble adaptation to changes appropriate for the testing standards.






Public Input No. 315-NFPA 1917-2013 [ Section No. 3.3.3 [Excluding

any Sub-Sections] ]

A vehicle used for out of hospital medical care and patient transport, which provides a driver’s compartment; a patient compartment to accommodate an emergency medical services provider (EMSP) and at least one patient located on the primary cot so positioned that the primary patient can be given emergency care during transit; equipment and supplies for emergency care at the scene as well as during transport; safety, comfort, and avoidance of aggravation of the patient’s injury or illness; two-way radio communication; and audible and visual traffic warning devices.


This allows for the definition of ambulance to contemplate the potential for more than one patient to be transported in the back of the ambulance, and the addition of the phrase precludes an erroneous interpretation that the ambulance can be constructed to transport only one patient. The commas are editorial in nature and to ensure that there is not more than one patient on the primary cot.


Submitter Full Name: Dia GainorOrganization: Nat'l Assn. of State EMS OfficStreet Address:City: State: Zip:Submittal Date: Sun Jul 07 17:01:57 EDT 2013


I, Dia Gainor, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I herebywarrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am Dia Gainor, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature




any Sub-Sections] ]

A vehicle used for out of hospital medical care and patient transport, which provides a driver’s compartment; a patient compartment to accommodate an emergency medical services provider (EMSP) and at least one patient,located on the primary cot, so positioned that the primary patient can be given emergency care during transit; equipment and supplies for emergency care at the scene as well as during transport; safety, comfort, and avoidance of aggravation of the patient’s injury or illness; two-way radio communication; and audible and visual traffic warning devices.




This allows for the definition of ambulance to contemplate the potential for more than one patient to be transported in the back of the ambulance, and the addition of the phrase precludes an erroneous interpretation that the ambulance can be constructed to transport only one patient. The commas are editorial in nature and to ensure that there is not more than one patient on the primary cot.









any Sub-Sections] ]

A vehicle used for out of hospital medical care and patient transport, which provides a driver’s compartment; a patient compartment to accommodate an emergency medical services provider (EMSP) and one patient located on the primary cot so positioned that the primary patient can be given emergency care during transit; equipment and supplies for emergency care at the scene as well as during transport; safety, comfort, and avoidance of aggravation of the patient’s injury or illness; two-way radio communication; and audible and visual traffic warning devices.

Revise this section as follows:

3.3.3 Ambulance. A vehicle used for out of hospital medical care and patient transport, which provides a driver’s compartment; a patient compartment to accommodate an emergency medical services provider (EMSP) and at least one patient , located on the primary cot , so positioned that the primary patient can be given emergency care during transit; equipment and supplies for emergency care at the scene as well as during transport; safety, comfort, and avoidance of aggravation of the patient’s injury or illness; two-way radio communication; and audible and visual traffic warning devices.


Substantiation: This allows for the definition of ambulance to contemplate the potential for more than one patient to be transported in the back of the ambulance, and the addition of the phrase precludes an erroneous interpretation that the ambulance can be constructed to transport only one patient. The commas are editorial in nature and to ensure that there is not more than one patient on the primary cot.








3.3.68Common and critical equipment and supplies refers to equipment and/or supply items that are frequently used and/or essential to providing patient care. The specific list may differ between ambulance stations and/or by the particular needs of the call.


A new requirement item about reachability of the interior storage for critical equipment/supplies is recommended. It is useful to provide a definition of common and critical equipment or supplies.


Submitter Full Name: Jennifer MarshallOrganization: NISTStreet Address: City:State: Zip: Submittal Date: Wed Jul 03 09:37:21 EDT 2013


I, Jennifer Marshall, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. Ihereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am Jennifer Marshall, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature




3.3.67 Wet Location (related to ambulances) .A location on a nonenclosed, exterior surface of an ambulance body or driving and crew compartment or a nonsheltered location inside a compartment with a door or cover that, while open, exposes the enclosure or panelboard to theenvironment.


The concept of wet location is used in multiple connotations, especially with regard to health care occupancies, where it usually refers to operating rooms. NFPA has several other definitions of "wet locations", including the following:

NFPA 1901: A nonsheltered location inside a compartment with a door or cover that, while open, exposes the electrical enclosure or panelboard to the same environmental conditions as the exterior of the fire apparatus. A location on a nonenclosed, exterior surface of a fire apparatus body or driving and crew compartment where the enclosure or panel is exposed to the environment.

NFPA 1906: A location on fire apparatus subject to saturation with water or other liquids and in unprotected locations exposed to the weather.

NFPA 79: Installations underground or in concrete slabs or masonry in direct contact with the earth; and in locations subject to saturation with water or other liquids, such as vehicle washing areas; and in unprotected locations exposed to weather.

I understand that this committee may want a unique definition for their use but, as the chair of the Technical Advisory Committee on the Glossary of Terminology, it is my responsibility to recommend that definitions of NFPA terms be unique.


Submitter Full Name: Marcelo HirschlerOrganization: GBH InternationalStreet Address: City:State: Zip: Submittal Date: Thu Jul 04 14:51:31 EDT 2013


I, Marcelo Hirschler, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. Ihereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.



By checking this box I affirm that I am Marcelo Hirschler, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature



Public Input No. 369-NFPA 1917-2013 [ Section No. 4.1 ]

4.1 General.All ambulances shall comply with reference Chapters 1 through 9.


File Name Description Approved1917_Hanson_various.pdf Cover Sheet


The word (comply) does not allow for exceptions of deviations for customer needs or requirements.


Submitter Full Name: Randy HansonOrganization: ASV/American Emergency VehicleStreet Address:City: State: Zip:Submittal Date: Wed Jul 10 07:33:37 EDT 2013


I, Randy Hanson, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement ofProblem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am Randy Hanson, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature




4.2.3After acceptance of the ambulance, the purchaser shall be responsible for ongoing training of personnel to develop and maintain proficiency regarding the proper and safe use of the ambulance and the associated equipment.


This is an unenforceable construction requirement and should be deleted or moved to the annex. A design/construction standard should not include operational parameters. The requirement for driver training is the responsibility of the ambulance operator and if deemed necessary by the regulating body can be required by State law or regulation.









4.2.3After acceptance of the ambulance, the purchaser shall be responsible for ongoing training of personnel to develop and maintain proficiency regarding the proper and safe use of the ambulance and the associated equipment.




This is an unenforceable construction requirement and should be deleted or moved to the annex. A design/construction standard should not include operational parameters. The requirement for driver training is the responsibility of the ambulance operator and if deemed necessary by the regulating body can be required by State law or regulation.









4.2.3After acceptance of the ambulance, the purchaser shall be responsible for

ongoing training of personnel to develop and maintain proficiency regarding the proper and safe use of the ambulance and the associated equipment.


4.2.3 After acceptance of the ambulance, the purchaser shall be responsible for ongoing training of personnel to develop and maintainproficiency regarding the proper and safe use of the ambulance and theassociated equipment.


Substantiation: This is an unenforceable construction requirement and should be deleted or moved to the annex. A design/construction standard should not include operational parameters. The requirement for driver training is the responsibility of the ambulance operator and if deemed necessary by the regulating body can be required by State law or regulation.








Public Input No. 317-NFPA 1917-2013 [ Section No. 4.3.1.2 ]

4.3.1.2The contractor’s detailed description shall include a statement specifically describing each aspect of the delivered ambulance that will not be fully compliant with the requirements of this standard.


This is redundant with 4.17 and the language in 4.17 is superior.









4.3.1.2The contractor’s detailed description shall include a statement specifically describing each aspect of the delivered ambulance that will not be fully compliant with the requirements of this standard.




This is redundant with 4.17 and the language in 4.17 is superior.









4.3.1.2The contractor’s detailed description shall include a statement specifically

describing each aspect of the delivered ambulance that will not be fullycompliant with the requirements of this standard.


4.3.1.2 The contractor’s detailed description shall include a statement specifically describing each aspect of the delivered ambulance that will not be fully compliant with the requirements of this standard.


Substantiation: This is redundant with 4.17 and the language in 4.17 is superior.









4.4.4All bodies, systems, equipment, and interfaces with the chassis not otherwise specified in this standard shall be done in accordance with the Chassis OEM Body Builders Guidelines.




If a second stage manufacture does not comply with the OEM manufactures guidelines the warranty intended for that product could be voided. Compliance to the OEM FMVSS testing (Pass Through Certifications) could also be nulified creating unnecessary problems for the end customer.








Public Input No. 68-NFPA 1917-2013 [ New Section after 4.6 ]

4.6 Third-Party Certification of Test Results. Where t This standard requires the witnessing or performing of tests by an independent third-party organization, that organization shall meet the requirements of this section.4.6.1 Testing shall be witnessed or performed by an organization that is accredited for inspection of ambulances in accordance with ISO/IEC 17020, General Criteria for the Operation of Various Types of Bodies Performing Inspection, or accredited for testing ambulances to this standard in accordance with ISO/IEC 17025, General Requirements for the Competence of Testing and Calibration Laboratories.4.6.2 The certification organization shall not be owned or controlled by the final-stage ambulance manufacturer.4.6.3 The certification organization shall witness all tests and shall refuse to certify any test results for a system if all components of that system requiring testing do not pass the testing required by this standard. [1901: 4.7.4]4.6.4 Conditional, temporary, or partial certification of test results shall not be permitted.4.6.5 Appropriate forms or data sheets shall be provided and used during the testing. [1901: 4.7.6]4.6.6 Programs shall be in place for training, proficiency testing, and performance verification of any staff involved with certification. [1901: 4.7.7]4.6.7 Appeal Process.4.6.7.1 The certification organization's operating procedures shall provide a mechanism for the manufacturer to appeal decisions.4.6.7.2 The procedures shall include provisions for the presentation of information from representatives of both sides of a controversy to a designated appeals panel.4.6.8 The third party that certifies any test results shall supply the following information on the certification organization letterhead:(1) Company or business for which the results are certified(2) Date of certification(3) Ambulance model, components, or equipment being certified(4) Certification organization and address(5) Date product tested(6) Model number and specification data(7) Applicable specification references and test requirement(8) Summary of the test report(9) A certifying statement with official signature4.6.9* The testing facility for each certification shall supply the followingsupportive verification data and information on letterhead stationery inelectronic format:(1) Name of company or business for whom ambulance product was tested(2) Report date



(3) Name of sample product or device(4) Contractor’s address(5) Serial and model number(s)(6) Specification referral and amendment number(s), and test requirement(s)(7) Test facilities used and location(8) Test equipment used(9) Test procedure(10) Test results(11) Verifying test data(12) Photographs(13) Drawings(14) Test conclusion(s)(15) Witness(es)(16) Authorized signature4.6.1 The initial testing and inspections required for certification shall be performed by one of the following:(1) A Nationally recognized testing laboratory, recognized by OSHA under Appendix A to 29 CFR 1910.7(2) An ISO/IEC 17025 accredited laboratory by an accreditation body that is recognized by the National Cooperation for Laboratory Accreditation (NACLA) or is a signatory to the International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement (MRA).(a) The scope of accreditation shall include AMD tests 1-25. (b) The individual certifications will remain valid for 5 years as long as the type of ambulance tested remains in production.(c) Design changes during the 5 year certification period must be tested at the time of production release.(d) Certifications that appear on the ambulance need not be re-submitted (i.e.; DOT, EPA, etc.).(e) Certification(s) will be acceptable in lieu of actual verification test during inspections providing supporting verifying data complying with 4.6.1 is on file for examination. (f) Certification from OEM and individual equipment manufacturers are acceptable providing they are not part of a system(s) or altered and in accordance with 4.7.4.6.1.1 Type certifications of individual components and equipment products shall be acceptable.4.6.1.2 Each ambulance constructed shall be tested by the FSAM to demonstrate compliance with AMD STDs 5, 9, 10, 15, 21 & 25 in addition to the initial type testing certification required.




Substantiation: This is text from the KKK specification that should be maintained. The NFPA 1917, Standard for Automotive Ambulances significantly weakened this requirement, which compromises safety. The current KKK standard requires independent third party certification and testing. The use of an independent third party for certification and testing removes any possibility of undue influence in this process or the ability to make any modifications to the test. The inconsistency in construct of boxes for patient care compartments has been widely noted in reports of ambulance collisions where boxes have been torn apart. The NFPA technical committee on ambulances should not condone any opportunity to allow undue influence or a degradation of the current standard.









4.6

6 Third-Party Certification of Test Results.

Where

thist T his standard requires the witnessing orperforming of tests by an independent third-party organization, that organization shall meet the requirements of this section.4.6.

1 Testing1 Testing shall be witnessed or performed by an organization that is accredited for inspection of ambulances in accordance with ISO/IEC 17020, GeneralCriteria for the Operation of Various Types of Bodies Performing Inspection, or accredited for testing ambulances to this standard in accordance with ISO/IEC 17025, General Requirements for the Competence of Testing and CalibrationLaboratories .4.6.

2 The2 The certification organization shall not be owned or controlled by the final-stage ambulancemanufacturer.4.6.

3 The3 The certification organization shall witness all tests and shall refuse to certify any test results for a system if all components of that system requiring testing do not pass the testing required by this standard. [ 1901: 4.7.4]4.6.



4 Conditional4 Conditional , temporary, or partial certification of test results shall not be permitted.4.6.

5 Appropriate5 Appropriate forms or data sheets shall be provided and used during the testing. [ 1901:4.7.6]4.6.

6 Programs6 Programs shall be in place for training, proficiency testing, and performance verification of any staff involved with certification. [ 1901: 4.7.7]4.6.

7 7 Appeal Process.4.6.7.

1 The1 The certification organization's operating procedures shall provide a mechanism for themanufacturer to appeal decisions.4.6.7.

2 The2 The procedures shall include provisions for the presentation of information from representatives of both sides of a controversy to a designated appealspanel.4.6.

8 The8 The third party that certifies any test results shall supply the following information on the certification organization letterhead:



(1) Company or business for which the results are certified

(2) Date of certification(3) Ambulance model, components, or equipment

being certified(4) Certification organization and

address(5) Date product tested(6) Model number and specification

data(7) Applicable specification references and test

requirement(8) Summary of the test report(9) A certifying statement with official

signature4.6.9 *

The The testing facility for each certification shall supply the following supportive verification data and information on letterhead stationery in electronicformat:

(1) Name of company or business for whom ambulance product was tested

(2) Report date(3) Name of sample product or

device(4) Contractor’s address(5) Serial and model number(s)(6) Specification referral and amendment number

(s), and test requirement(s)(7) Test facilities used and location(8) Test equipment used(9) Test procedure(10) Test results(11) Verifying test data(12) Photographs(13) Drawings(14) Test conclusion(s)(15) Witness(es)(16) Authorized signature4.6.1 The initial testing and inspections required for

certification shall be performed by one of the following:



(1) A Nationally recognized testing laboratory,recognized by OSHA under Appendix A to 29 CFR 1910.7

(2) An ISO/IEC 17025 accredited laboratory by anaccreditation body that is recognized by the National Cooperation for Laboratory Accreditation (NACLA) or is a signatory to the International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement(MRA).

(a) The scope of accreditation shall include AMD tests 1-25.

(b) The individual certifications will remain valid for5 years as long as the type of ambulance tested remains inproduction.

(c) Design changes during the 5 year certificationperiod must be tested at the time of production release.

(d) Certifications that appear on the ambulance need not be re-submitted (i.e.; DOT, EPA, etc.).

(e) Certification(s) will be acceptable in lieu ofactual verification test during inspections providing supporting verifying data complying with 4.6.1 is on file for examination.

(f) Certification from OEM and individual equipmentmanufacturers are acceptable providing they are not part of a system(s) or altered and in accordance with 4.7.

4.6.1.1 Type certifications of individual components and equipment products shall be acceptable.

4.6.1.2 Each ambulance constructed shall be tested by the FSAM to demonstrate compliance with AMD STDs 5, 9, 10, 15, 21 & 25 in addition to the initial type testing certification required.






Submitter Full Name: Ronald ThackeryOrganization: American Medical Response, IncStreet Address: City: State:Zip: Submittal Date: Tue Jul 02 10:09:51 EDT 2013


I, Ronald Thackery, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.





4.6 Third-Party Certification of Test Results.Where this This standard requires the witnessing or performing of tests by an independent third-party organization, that organization shall meet the requirements of this section.4.6.1

Testing The initial testing and inspections required for certification shallbe witnessed or performed by an organization that is accredited for inspection of ambulances in accordance with ISO/IEC 17020, General Criteria for the Operation of Various Types of Bodies Performing Inspection, or accredited for testing ambulances to this standard in accordance with ISO/IEC 17025, General Requirements for the Competence of Testing andCalibration Laboratories .

4.6.2The certification organization shall not be owned or controlled by the final-stage ambulance manufacturer.

4.6.3The certification organization shall witness all tests and shall refuse to certify any test results for a system if all components of that system requiring testing do not pass the testing required by this standard. [ 1901: 4.7.4]

4.6.4Conditional, temporary, or partial certification of test results shall not be permitted.

4.6.5Appropriate forms or data sheets shall be provided and used during the testing. [ 1901: 4.7.6]

4.6.6Programs shall be in place for training, proficiency testing, and performance verification of any staff involved with certification. [ 1901: 4.7.7]4.6.7 Appeal Process.

4.6.7.1The certification organization's operating procedures shall provide a mechanism for the manufacturer to appeal decisions.

4.6.7.2The procedures shall include provisions for the presentation of information from representatives of both sides of a controversy to a designated appeals panel.

4.6.8The third party that certifies any test results shall supply the following information on the certification organization letterhead:


(2) Date of certification

(3) Ambulance model, components, or equipment being certified



(4) Certification organization and address

(5) Date product tested

(6) Model number and specification data

(7) Applicable specification references and test requirement

(8) Summary of the test report

(9) A certifying statement with official signature

4.6.9 *The testing facility for each certification shall supply the following supportive verification data and information on letterhead stationery in electronic format:


(2) Report date

(3) Name of sample product or device

(4) Contractor’s address

(5) Serial and model number(s)

(6) Specification referral and amendment number(s), and test requirement(s)

(7) Test facilities used and location

(8) Test equipment used

(9) Test procedure(10) Test results

(11) Verifying test data

(12) Photographs

(13) Drawings

(14) Test conclusion(s)

(15) Witness(es)

(16) Authorized signature

one of the following:(1) A Nationally recognized testing laboratory, recognized by OSHA under

Appendix A to 29 CFR 1910.7

(2) An ISO/IEC 17025 accredited laboratory by an accreditation body that is recognized by the National Cooperation for Laboratory Accreditation (NACLA) or is a signatory to the International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement (MRA).


(b) The individual certifications will remain valid for 5 years as long as the type of ambulance tested remains in production.

(c) Design changes during the 5 year certification period must be tested at the time of production release.




(e) Certification(s) will be acceptable in lieu of actual verification test during inspections providing supporting verifying data complying with 4.6.1 is on file forexamination.

(f) Certification from OEM and individual equipment manufacturers are acceptable providing they are not part of a system(s) or altered and in accordance with 4.7.


4.6.1.2 Each ambulance constructed shall be tested by the FSAM to demonstrate compliance with AMD STDs 5, 9, 10, 15, 21 & 25 in addition to the initial type testing certification required.




This is text from the KKK specification that should be maintained. The NFPA 1917, Standard for Automotive Ambulances significantly weakened this requirement, which compromises safety. The current KKK standard requires independent third party certification and testing. The use of an independent third party for certification and testing removes any possibility of undue influence in this process or the ability to make any modifications to the test. The inconsistency in construct of boxes for patient care compartments has been widely noted in reports of ambulance collisions where boxes have been torn apart. The NFPA technical committee on ambulances should not condone any opportunity to allow undue influence or a degradation of the current standard.






4.6 Third-Party Certification of Test Results.Where this This standard requires the witnessing or performing of AMD tests by an independent third-party organization , that organization shall meet meets the requirements of this section.

4.6.1 The scope of testing requiring third-party certification of test results includes all AMD type tests.

4.6.1Testing shall be witnessed or performed by an organization that is accredited for inspection of ambulances in accordance with ISO/IEC 17020, General Criteria for the Operation of Various Types of Bodies Performing Inspection, or accredited for testing ambulances to this standard in accordance with ISO/IEC 17025, General Requirements for the Competence of Testing and Calibration Laboratories .

4.6.2The certification organization shall not be owned or controlled by the

final-stage ambulance manufacturer.4.6.3

The certification organization shall witness all tests and shall refuse to certify any test results for a system if all components of that system requiring testing do not pass the testing required by this standard. [ 1901: 4.7.4]

4.6.4Conditional, temporary, or partial certification of test results shall not

be permitted.4.6.5

Appropriate forms or data sheets shall be provided and used during the testing. [ 1901: 4.7.6]

4.6.6Programs shall be in place for training, proficiency testing, and

performance verification of any staff involved with certification. [ 1901:4.7.7]

4.6.7 Appeal Process.4.6.7.1

The certification organization's operating procedures shall provide a mechanism for the manufacturer to appeal decisions.

4.6.7.2The procedures shall include provisions for the presentation of

information from representatives of both sides of a controversy to a designated appeals panel.

4.6.8The third party that certifies any test results shall supply the

following information on the certification organization letterhead:

(1) Company or business for which the results are certified(2) Date of certification








(8) Summary of the test report(9) A certifying statement with official signature

4.6.9 *The testing facility for each certification shall supply the following

supportive verification data and information on letterhead stationery in electronic format:


(2) Report date

(3) Name of sample product or device(4) Contractor’s address





(9) Test procedure

(10) Test results

(11) Verifying test data(12) Photographs

(13) Drawings


(15) Witness(es)



File Name Description Approved1917_Allen.pdf Cover Sheet BNW_Comments_to_NFPA_1917-2013_2013-07-08e.docx

Word file of all public input




There is legitimate concern about manufacturer self-certification of required ambulance testing. What is needed is a means to assure that testing is performed by a qualified third party that is not inappropriately influenced by the manufacturer. It is essential that the NFPA 1917 technical committee consider the implications of mandating unnecessarily onerous certification requirements upon the testing agencies.Because there are fewer than twenty modular ambulance manufacturers in the country, there is not a large market demand for ambulance testing. There is no motivation for testing labs to certify to the current KKK requirements unless they can anticipate sufficient testing volume to justify their investment in obtaining and maintaining the required certification.The significant difference between the current 1917 requirement and the KKK requirement is that the latter requires the testing lab expand their scope of certification to specifically include the AMD standards.While there are many ISO/IEC 17020/17025-certified labs in the US, there are currently only three testing labs certified to the requirements specified by the federal KKK ambulance standard. None of those labs is located west of the Mississippi River. And because of the manufacturer density in that half of the country, there is no reason to expect that any labs in that area will elect to certify to the ambulance testing standards prescribed by KKK.In order to comply with required testing for the variety of chassis used and the number of module designs produced by a typical ambulance manufacturer, the testing needs to be performed at a testing facility in reasonable proximity to the manufacturer.Manufacturers located far from the currently-qualified testing labs will need to find or create a path for testing at a lab located in proximity to the manufacturer's facility. Absent sufficient market to justify their certification to the specific AMD ambulance testing standards, ISO/IEC 17020/17025-certified labs located in the west half of the country will not elect to obtain the additional certification now required by KKK.To create a viable path for initial and ongoing testing, manufactures located in the west half of the country will likely have to find a willing, local lab and pay them to obtain the additional certification specifically for AMD standards for the purpose of testing only that manufacturer's ambulances (as there will likely be no other ambulance manufacturers in proximity to that lab).Adopting the KKK requirements for certification fails to produce a level playing field for all manufacturers and creates the exact situation the industry seeks to avoid—one where a testing agency is beholden to the particular manufacturer that paid them to obtain the needed additional certification.The best approach for ensuring independent, third-party testing by a properly qualified lab is to retain the ISO/IEC 17020/17025 certification requirements of 1917-2013 (excluding the additional scope of accreditation for the specific AMD tests) but to require that all AMD type tests be witnessed or performed by that third party.


Submitter Full Name: Jerry AllenOrganization: Braun Northwest, Inc.Street Address: City:State: Zip: Submittal Date: Mon Jul 15 08:34:06 EDT 2013




I, Jerry Allen, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I herebywarrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am Jerry Allen, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature



BNW_Comments_to_NFPA_1917-2013_2013-07-08e.1373895624757 Page 1 of 9 Printed: 7/24/2013

Section N R D Proposal Statement of Problem

4.6 X

4.6 Third-Party Certification of Test Results. Where this This standard requires the witnessing or performing of AMD tests by an independent third-party organization, that organization shall meet that meets the requirements of this section.

4.6.1 The scope of testing requiring third-party certification of test results includes all AMD type tests.

(Re-number sections 4.6.1 through 4.6.9 following insertion of the new 4.6.1 above.)

There is legitimate concern about manufacturer self-certification of required ambulance testing. What is needed is a means to assure that testing is performed by a qualified third party that is not inappropriately influenced by the manufacturer. It is essential that the NFPA 1917 technical committee consider the implications of mandating unnecessarily onerous certification requirements upon the testing agencies.

Because there are fewer than twenty modular ambulance manufacturers in the country, there is not a large market demand for ambulance testing. There is no motivation for testing labs to certify to the current KKK requirements unless they can anticipate sufficient testing volume to justify their investment in obtaining and maintaining the required certification.

The significant difference between the current 1917 requirement and the KKK requirement is that the latter requires the testing lab expand their scope of certification to specifically include the AMD standards.

While there are many ISO/IEC 17020/17025-certified labs in the US, there are currently only three testing labs certified to the requirements specified by the federal KKK ambulance standard. None of those labs is located west of the Mississippi River. And because of the manufacturer density in that half of the country, there is no reason to expect that any labs in that area will elect to certify to the ambulance testing standards prescribed by KKK.

In order to comply with required testing for the variety of chassis used and the number of module designs produced by a typical ambulance manufacturer, the testing needs to be performed at a testing facility in reasonable proximity to the manufacturer.

Manufacturers located far from the currently-qualified testing labs will need to find or create a path for testing at a lab located in proximity to the manufacturer's facility. Absent sufficient market to justify their certification to the specific AMD ambulance testing standards, ISO/IEC 17020/17025-certified labs located in the west half of the country will not elect to obtain the additional certification now required by KKK.

To create a viable path for initial and ongoing testing, manufactures located in the west half of the country will likely have to find a willing, local lab and pay them to obtain the additional certification specifically for AMD standards for the purpose of testing only that manufacturer's ambulances (as there will likely be no other ambulance manufacturers in proximity to that lab).

Adopting the KKK requirements for certification fails to produce a level playing field for all manufacturers and creates the exact situation the industry seeks to avoid—one where a testing agency is beholden to the particular manufacturer that paid them to obtain the needed additional certification.

The best approach for ensuring independent, third-party testing by a properly qualified lab is to retain the ISO/IEC 17020/17025 certification requirements of 1917-2013 (excluding the additional scope of accreditation for the specific AMD tests) but to require that all AMD type tests be witnessed or performed by that third party.



4.7 X

4.7.1 The scope of testing to be certified by the FSAM includes all AMD non-type tests. That is, the AMD tests that must be performed on each individual vehicle manufactured by the FSAM.

(Re-number sections 4.7.1 through 4.7.8 following insertion of the new 4.6.1 above.)

This addition is recommended to clarify that the AMD tests other than the type tests covered in 4.6 need to be certified by the FSAM.

5.9.3 X

5.9.3 Unless the customer elects to forego the standard tire chain clearance, cClearance for tire chains shall be provided for rear wheels in accordance with SAE J683, Tire Chain Clearance — Trucks, Buses (Except Suburban, Intercity, and Transit Buses), and Combinations of Vehicles.

A.5.9.3 Standard practice for ambulance design is to provide clearance for tire chains on the rear wheels as prescribed by SAE J683. Customers who never use tire chains on the inside duals may elect to forego the interior side clearance to allow for greater aisle width or additional insulation. Customers who never use tire chains at all may elect to forego the tire chain clearance entirely in order to allow for greater aisle width, shorter wheel wells, or additional insulation.

This is a good practice to follow if the ambulance user intends to use tire chains. However, many ambulance users never use tire chains, and among those who do, most use chains only on the outside duals.

The problem with the requirement as written is that it unjustifiably restricts the ability of an ambulance user who does not use tire chains to elect a greater aisle width, reduced wheel well height or additional insulation on the wheel wells (because the tire chain clearance consumes space that would otherwise be available for additional aisle width of insulation).

The issue is resolved by allowing users to opt out of the SAE J683 clearance allowance if they do not use tire chains or if they only use chains on the outside duals.

6.12.6 X

6.12.6 Any absorbent material, such as carpeting, fabric, or inside/outside plastic-type carpeting, that resists cleaning and decontamination shall not be used. All surfaces shall be non-absorbent and shall be easy to clean and decontaminate.

The grammar needs to be improved to positively state the desired path rather than negatively stating the undesired path.

6.13.6 X

6.13.6 If the ambulance has a modular body, the subfloor shall be designed to prevent water penetration and shall include a heat shield above any exhaust component that is within 12" of the ambulance floor.

Exhaust components on medium duty chassis are usually more than 12" from the module floor, obviating the need for a heat shield. Radiant heat transfer diminishes with the square of the distance between the objects. Once the separation distance reaches 12", the rate of radiant heat transfer no longer warrants a heat shield. The requirement for a heat shield regardless of the separation of the exhaust components creates an unjustifiable additional expense.

6.16.6 X

6.16.6 Storage cabinets and compartments shall be firmly fastened to the body structure. Cabinet construction and attachment integrity shall be validated by static testing that confirms crashworthiness equivalent to the dynamic testing outlined in standards SAE J2917 and/or SAE J2956 as appropriate for the intended orientation and weight rating proposed by the manufacturer. (Insert additional text here to prescribe the static pull requirements that are equivalent to the dynamic test imposed by SAE J2917 and SAE J2956.)

The current standard does not sufficiently define the requirements for cabinet attachment. An objective, science-based test criterion is needed to confirm construction and attachment integrity.

While SAE J2917 and SAE J2956 lay the groundwork for the needed testing standards, they have not yet translated the results into static testing requirements as was the original intent of the NIOSH work. (Refer to https://www.fbo.gov/?s=opportunity&mode=form&id=dc3cf6bf92bf6644d6403cac3d3b9cea&tab=core&_cview=0 for a summary of the NIOSH solicitation.) Until such time as the referenced SAE standards are updated to convert the dynamic pulse corridor into an equivalent, repeatable, static test, the 1917 standard should prescribe a best-estimate static test requirement.

Prescribing dynamic testing requirements for vehicles over 8,500 lbs is inconsistent with the requirements of the FMVSS which are based upon statistical cost/benefit analysis.

https://www.fbo.gov/?s=opportunity&mode=form&id=dc3cf6bf92bf6644d6403cac3d3b9cea&tab=core&_cview=0

https://www.fbo.gov/?s=opportunity&mode=form&id=dc3cf6bf92bf6644d6403cac3d3b9cea&tab=core&_cview=0



While the virtue of dynamic testing is recognized, applying dynamic testing requirements to ambulances cannot be justified because the number of ambulances manufactured annual is relatively small and because nearly-equivalent results can be prescribed in the form of static testing.

The fact that the conversion from dynamic to static testing has not yet been completed does not justify adding the dynamic testing cost burden to a class of vehicles produced by twenty different manufacturers in a quantity of only 5000 units per year.

6.18.1 X

6.18 Equipment Mounting.

6.18.1 Medical Supplies and Equipment Storage Mounting. Supplies, devices, tools, and so forth, shall be stored in enclosed compartments or fastened to secure them during vehicle motion.

6.18.1 Storage and Securement of Medical Equipment and Supplies. The customer shall list equipment, and supplies weighing 3 lb (1.36 kg) or more that will be used in the ambulance but not enclosed in a cabinet or compartment. The FASM shall provide means for securing all listed equipment, and supplies weighing 3 lb (1.36 kg) or more that will not be enclosed in a cabinet or compartment,

6.18.2 Equipment weighing 3 lb (1.36 kg) or more mounted or stored in a driving or patient area shall be contained in an enclosed compartment The means of securement shall be capable of containing the contents restraining the listed equipment when a 10G force is applied in the longitudinal, lateral, or vertical axis of the vehicle, if the equipment is secured in a bracket(s) or mount that can contain the equipment when the equipment is subjected to those same forces.

This is a user requirement and therefore does not belong in an ambulance construction standard as originally written. However, the standard should address the legitimate need to secure items that are not stored in cabinets (which are covered in section 6.16.)

If Section 6.16 prescribes requirements for securement of items in cabinets and compartments, Section 16.18 should prescribe requirements for items that are not stored in cabinets or compartments.

6.19 X

6.19* Waste and Sharps Disposal. Unless declined by the customer, a A receptacle for general waste and an OSHA-compliant container for sharps disposal shall be provided in the patient compartment.

There is no basis for making a sharps container compulsory in a base ambulance standard when many customers do not use any sharps in their ambulance.

The issue is resolved by allowing the customer to opt out of the sharps container.

6.20.1 X

6.20.1 Unless declined by the customer, at least one One mounted device specifically designed for holding and securing an IV fluid container against accidental release during normal transport activity shall be provided.

There is no basis for making an IV hanger compulsory in a base ambulance standard when many customers do not use IVs in their ambulance.

The issue is resolved by allowing the customer to opt out of the IV holder.

The standard should not specify a quantity of one IV hanger, as this technically makes more than one IV hanger non-compliant. The language should allow for one or more IV hangers.

6.21.3.1 X 6.21.3.1* Each designated seating position shall be provided with a seat belt that is compliant with FMVSS 209 and FMVSS 210.

Requiring the presence of a seatbelt is a good start. However, to be effective, the standard should also specify the characteristics of the seatbelt.



6.21.3.2 X

6.21.3.2 Ambulances above 19,500 lb (8845 kg) GVWR shall provide seat belts in accordance with 6.21.3.2.1 and 6.21.3.2.2.

6.21.3.2.1 The effective seat belt web length for a Type 1 lap belt for pelvic restraint shall be a minimum of 60 in. (1524 mm) with the seat adjusted all the way back and down when measured using the following procedure and referring to Figure 6.21.3.2.1:

(1) Locate an imaginary line where the plane of the center of the seat back surface intersects the plane of the center of the seat cushion surface (see line 1 in Figure 6.21.3.2.1).

(2) Locate point A on line 1 at the outside of the seat on the retractor side of the seat.

(3) Locate point C on line 1 at the outside of the seat on the receiver side of the seat.

(4) Locate point D at the tip of the receiver.

(5) Pull the seat belt webbing entirely out of the retractor and measure along the webbing between point A and the male seat belt buckle.

(6) Record this length as AD.

(7) Measure from point C to point D and record this length as CD.

(8) Add AD and CD for the effective seat belt web length.

6.21.3.2.2 The effective seat belt web length for a Type 2 pelvic and upper torso restraint-style seat belt assembly shall be a minimum of 110 in. (2800 mm) with the seat adjusted all the way back and down when measured using the following procedure:

(1) Locate an imaginary line where the plane of the center of the seat back surface intersects the plane of the center of the seat cushion surface (see line 1 in Figure 6.21.3.2.1).

(2) Locate an imaginary line parallel with line 1 and lying on the center of the seat back surface 29 in. (740 mm) from line 1 (see line 2 in Figure 6.21.3.2.1).


(4) Locate point B on line 2 at the shoulder strap edge of the seat back.



(7) Pull the seat belt webbing entirely out of the retractor and

There is no basis for differentiation of seatbelt requirements based upon GVWR. The standard for all seatbelts should be FMVSS 209 and FMVSS 210 regardless of the ambulance GVWR.

The issue is resolved by requiring compliance with FMVSS 209 and 210 in 6.21.3.1



measure along the webbing between points A and B.

(8) Record this length as AB.


(10) Add AB and 2CD for the effective seat belt web length.

6.21.7.3 X 6.21.7.3 A back cushion that extends from the seat bottom cushion vertically is at least 7 in. (460 mm) in height and that is a minimum of 18 in. (460 mm) wide at the base shall be provided.

For back pads attached to an ambulance wall, providing a gap between the top of the seat base and the bottom of the back cushion provides better lumbar support than a seat without such a gap. The current standard implies that the bottom of the back cushion must be at the top of the seat base cushion. To provide for optimal back support, the height and width of the back cushion should be specified, but the elevation of the bottom of the back cushion should either not be specified our should be specified to allow a gap between the top of the seat cushion and the bottom of the back cushion. This change still allows the pad to be positioned at a lower elevation in cases where providing clearance for windows outweighs the benefit of improved back support.

6.21.8.1 X

6.21.8.1 If the primary patient care seat is an adjustable seat at the patient torso position, it shall be capable of being adjusted such that the nearest edge of the seat bottom cushion is within 6 in. (152 mm) of the nearest edge of the patient cot.

The depth of adjustable seats is typically 4" to 9" greater than bench seats. Requiring an adjustable seat in this position has the unintended consequence of diminishing the normal aisle clearance. Customers should be given the freedom to determine whether their application benefits more from an adjustable seat or greater aisle width.

6.21.9.1 X

6.21.9.1 Any seat with a built-in system suitable for transporting a child or an infant shall not be oriented in a side-facing designed for operation in a forward-facing or rear-facing direction during transport.

Improve the grammar by changing from a negative to a positive statement. Change this to a design requirement as this is a standard for ambulance construction rather than ambulance operation.

6.23.3.1 X 6.23.3.1 Ventilation system(s) in the patient compartments shall provide a change of ambient air with the vehicle stationary.

Without a requirement for an air change within a prescribed timeframe, this requirement adds nothing beyond what is required in 6.23.3.4. This section should be deleted and the subsequent sections re-numbered.

6.28.1 X 6.28.1 The Unless declined by the customer, the ambulance shall have a piped medical oxygen system capable of supplying a minimum of 3000 L of medical oxygen.

Depending upon transport scenarios, customers sometimes elect to use portable oxygen cylinders rather than a piped oxygen system. This being a standard for a basic ambulance, it should not compel customers to pay for a piped oxygen system if such a system is not needed or used in their application.

6.29.1 X 6.29.1 An When an electrically powered suction aspirator system shall be is furnished., it shall meet the requirements of this section.

Customers are increasingly favoring portable suction units over permanently installed suction systems. It is inappropriate for a standard for a basic ambulance to compel customers to pay for equipment that they do not need or use.

7.2.1.2 X 7.2.1.2 Voltage drops in all wiring from the power source to the using device shall not exceed 0.5 volt 5% of the nominal source voltage.

The industry standard allowance for voltage drop in a branch circuit is 5%. (Refer to the NEC, NFPA 70.) Specifying a lower allowed voltage drop will in some cases necessitate the use of larger conductors.

There is no justification for this ambulance standard to deviate from standard



industry practice in a way that compels higher cost to the customer for unnecessarily large conductor.

The issue should be resolved by changing the allowable drop to 5% of the source voltage.

7.4.2 X

7.4.2 If the ambulance is equipped to tow a trailer, an additional 45 20 amperes shall be added to the minimum continuous electrical load to provide electrical power for the federally required clearance and marker lighting and the optical warning devices mounted on the trailer.

The 45-amp requirement of this section far exceeds the actual load for a fully-compliant trailer. In the same way that this ambulance standard should specify minimum requirements for a basic ambulance, electrical load allowance for a trailer should be based upon a realistic, basic trailer rather than a worst case trailer electrical load. Typical load requirements for an FMVSS-compliant trailer would total less than 15 amperes as shown below.

The electrical load allowance for a trailer should be reduced to 20 amperes (which provides a 7A or 35% capacity margin).

Light Description and Quantity Total Electrical Load

Tail Lamps, 2 ea @ 0.03A = 0.06A

Stop Lamps, 2 ea @ 0.38A = 0.76A

Turn Lamps, 2 ea @ 0.38A = 0.76A

License Plate Lamp, 1 ea @ 0.5A = 0.50A

Rear Side Marker Lamps, 2 ea @ 0.05A = 0.10A

Front Side Marker Lamps, 2 ea @ 0.05A = 0.10A

Rear Clearance Lamps, 2 ea @ 0.05A = 0.10A

Rear Identification Lamps, 3 ea @ 0.05A = 0.15A

Front Clearance Lamps, 2 ea @ 0.05A = 0.10A

Side Flashers, 4 ea @ 0.60A = 2.40A

Rear Flashers, 2 ea @ 0.60A = 1.20A

Dome lights, 4 ea @ 1.5A = 6.00A

Total of all above loads = 12.23A

Reference to FMVSS 108 lighting requirements for trailers: http://www.nhtsa.gov/cars/rules/standards/conspicuity/trlrpstr.html

7.9.11.1 X

7.9.11.1 The minimum flash rate of any optical source shall be 75 flashes per minute, and the minimum maximum number of flashes at any measurement point shall be 150 flashes per minute. [1901:13.8.11.1]

Correct typo.

7.13.2 X 7.13.2 The backup alarm shall not have capacity to be turned Contrary to popular belief, OSHA does not require backup alarms on all trucks. Backup alarms are typically required only on construction sites. Even in cases

http://www.nhtsa.gov/cars/rules/standards/conspicuity/trlrpstr.html



off or disconnected. where backup protection is required, the use of a spotter is allowed as an alternative to an audible alarm.

Ambulances often operate in noise-restricted or noise-sensitive areas where the operation of a backup alarm is objectionable.

While we support the installation of a backup alarm on all ambulances, the prohibition of a momentary disable switch is inappropriate.

This section should be deleted as it inappropriately restricts the freedom of ambulance operators to employ alternate backing protocol in lieu of a backup alarm.

7.14 X

7.14 Stop, Tail, and Directional Lights.

7.14.1 The ambulance shall be equipped with all FMVSS 108 legally required stop, tail, and directional lights.

7.14.2 Directional lights shall be visible according to FMVSS 108.

7.14.3 On ambulances 30 ft (10 m) or longer in length, a turn signal shall be mounted approximately midway along the ambulance at approximately running board height.

7.14.4 Equipment shall not be mounted in a manner that obscures the stop, tail, or directional lights.

There is no justification for repeating FMVSS requirements in this standard. The ambulance cannot be legally operated on the highway unless it complies with all applicable FMVSS requirements.

Duplicating any portion of the FMVSS in this standard creates a bad precedent that should be avoided.

This section should be deleted from the 1917 standard.

8.2.2.8 X 8.2.2.8 When more than one shoreline receptacle is connected to a given load, relay(s) or transfer switch(es) shall be used to de-energize the unused shoreline receptacle.

Customers sometimes elect to install redundant shoreline receptacles to accommodate varying shorepower source locations. When that is done, a relay or transfer switch is needed to prevent possible electrocution from contact with the live contact beneath the cover of the unused shoreline connector.

A new section should be added to ensure that this protection is provided.

8.2.3 X

8.2.3 Receptacle.

8.2.3.1 The shoreline receptacle shall energize the vehicle’s internal line voltage circuit from an external power source such as utility power.

8.2.3.2 A proper-mating, weatherproof, minimum 15-ampere connector body conforming to the NEMA configuration shall also be furnished without cable and tagged specifying the size, the type of wire necessary, and the polarity of the future hookup.

These sections should be deleted as they are redundant with section 8.2.2.4 and 8.2.2.5.

8.2.4.3 X 8.2.4.3 Any fixed line voltage power source shall produce a maximum voltage output of no more than 10 110 percent of the power source's full rated voltage.

Correct typo.

8.3.1.7 X 8.3.1.7 Except for the ground-to-neutral bond at an electrical power source such as an inverter or generator, aAny bonding screws, straps, or buses in the distribution panelboard or in other system components between the neutral and equipment-grounding

The essential requirement here is that there must be one and only one point of connection between the neutral and ground. This connection normally occurs at the power distribution panel that supplies shorepower to the ambulance. However, when AC power is provided from an inverter or generator, it is imperative that the



conductor shall be removed and discarded. inverter or generator provide a bond between ground and neutral.

An exception should be added to this section to clarify that the ground-to-neutral bond should not be removed from the inverter or generator.

8.3.2.2.5 X

8.3.2.2.5 Except for distinctively marked, double-insulated tools and appliance supplied with a two-wire cord and plug, cCord-connected appliances shall be grounded by means of an approved cord with an equipment-grounding conductor and grounding attachment plug.

NEC section 250.114 provides an exception for double-insulated tools and appliances. It would be inappropriate for the ambulance standard to require modification of tools and appliances by installing a 3-wire cord and plug on devices that are legitimately and properly supplied with a 2-wire cord and plug.

An exception should be added to make this section consistent with the NEC.

8.3.3.3.5 X

8.3.3.3.5 The ambulance body and exterior covering shall be considered bonded when the following criteria have been met:

(1) The metal panels overlap or are welded to one another and are securely attached to the metal frame parts by metal fasteners or welding.

(2) The lower panel of the metal exterior covering is secured by metal fasteners at each cross member of the chassis, or the lower panel is bonded to the chassis by a metal strap.

The intent of this section is to ensure proper electrical bonding. Because welding panels to one another provides a bond equal or superior to overlapping, the option of welding should be added to item (1) of this section.

The intent of item (2) of this section is unclear, and the language is confusing. Ambulance exterior metal walls are typically one piece from top to bottom; there is not a separate lower panel. The cross members of the chassis (presuming that this is referring to the chassis frame cross members as opposed to the module support laterals) have no bearing whatsoever upon fastener location.

Item (2) appears to have no clear relevance and therefore should be eliminated.

8.3.3.3.6 X

8.3.3.3.6 Metal circulating air ducts shall be bonded to the chassis.

Metal circulating air ducts are rarely used in ambulances. When they are used, they are typically integrated into the module construction or bonded to the module which is in turn bonded to the chassis.

Because there is no justification for bonding ducts to the chassis as opposed to bonding them to the module, this section should be deleted.

8.4 X

8.4* Ground-Fault Circuit Interrupters. All line voltage ac circuits receptacles of the ambulance shall be protected by listed ground-fault circuit interrupters in accordance with ANSI/UL 498, Standard for Safety Attachment Plugs and Receptacles.

Except for underwater pool lights, the NEC calls for GFCI protection only for receptacles. Because the intent of this ambulance standard is to compel compliance with the NEC, the NEC requirements should not be altered by this standard.

The language of this section should be revised to bring it into conformity with NEC section 210.8.

8.12.4 X 8.12.4* Each switch shall indicate the position of its contact points (i.e., open or closed) and shall be rated for the continuous operation of the load being controlled. [1901:22.11.4]

The intent of this section is unclear. The important information for the user is identification of the switch function as required by section 8.12.4.1. For relay-controlled circuits, there is no reason why a user should be concerned about whether a switch performs its intended function by opening normally closed contacts or closing normally open contacts.

The requirement for a switch to indicate the position of its contacts should be eliminated.

8.12.5.2 X 8.12.5.2 Receptacles in the ambulance module shall be flush or near flush, vertically mounted.

When customers require receptacles behind the cab seats, the use of a handy box for surface mounting is preferred. The standard should not prohibit that practice.



There is no basis for requiring vertical orientation. NEC does not specify a mounting orientation. In the last few NEC revision cycles, proposals to specify the mounting orientation were all rejected. Ambulance receptacles are almost always mounted vertically, but there are instances where they need to be rotated, and there is no basis for this standard to restrict that option.

8.13 X 8.13 Cord Reels.

This section should be eliminated from the ambulance standard on the basis that it is extremely rare for an ambulance to have a cord reel.

If, for some reason it is deemed necessary to include standards for a cord reel, it would be better to simply stipulate compliance with the applicable section of NFPA 1901.

Public Input No. 318-NFPA 1917-2013 [ Sections 4.6, 4.7 ]

Sections 4.6, 4.74.6 Third-Party Certification of Test Results.Where this standard This standard requires the witnessing or performing of tests by an independent third-party organization, that organization shall meet the requirements of this section.4.6.

1 Testing1 The initial testing and inspections required for certification shall be

witnessed or performed by

an organization that is accredited for inspection of ambulances in accordance withISO/IEC 17020, General Criteria for the Operation of Various Types of Bodies Performing Inspection, or accredited for testing ambulances to this standard in accordance with ISO/IEC 17025, General Requirements for the Competence of Testing and Calibration Laboratories . 4.6.2

The certification organization shall not be owned or controlled by the final-stage ambulance manufacturer.

4.6.3The certification organization shall witness all tests and shall refuse to certify any test results for a system if all components of that system requiring testing do not pass the testing required by this standard. [ 1901: 4.7.4]



4.6.6Programs shall be in place for training, proficiency testing, and performance verification of any staff involved with certification. [ 1901: 4.7.7]4.6.7 Appeal Process.

4.6.7.1The certification organization's operating procedures shall provide a mechanism for the manufacturer to appeal decisions.

4.6.7.2The procedures shall include provisions for the presentation of information from representatives of both sides of a controversy to a designated appeals panel.

4.6.8The third party that certifies any test results shall supply the following information on the certification organization letterhead:


(2) Date of certification








(8) Summary of the test report

(9) A certifying statement with official signature

4.6.9 *The testing facility for each certification shall supply the following supportive verification data and information on letterhead stationery in electronic format:


(2) Report date(3) Name of sample product or device

(4) Contractor’s address





(9) Test procedure

(10) Test results(11) Verifying test data

(12) Photographs

(13) Drawings


(15) Witness(es)


4.7 Certification of Test Results by Manufacturer.Where this standard requires the results of tests or the performance of a component to be certified by the manufacturer, the manufacturer shall meet the requirements of this section. [ 1901: 4.8]

4.7.1A representative of the manufacturer shall witness all tests and shall refuse to certify any test results for a system unless all components of that system requiring testing pass the testing required by this standard. [ 1901: 4.8.1]


4.7.3The manufacturer shall have the facilities and equipment necessary to conduct the required testing, a program for the calibration of all instruments, and procedures to ensure the proper control of all testing. [ 1901: 4.8.3]

4.7.4



Appropriate forms or data sheets shall be provided and used during the testing. [ 1901: 4.8.4]

4.7.5Programs shall be in place for training, proficiency testing, and performance verification of any personnel involved with certification. [ 1901: 4.8.5]

4.7.6An official of the company that manufactures or installs the product shall designate in writing who is qualified to witness tests and certify results. [ 1901: 4.8.6]

4.7.7one of the following:

(1) A Nationally recognized testing laboratory, recognized by OSHA under Appendix A to 29 CFR 1910.7

(2) An ISO/IEC 17025 accredited laboratory by an accreditation body that is recognized by the National Cooperation for LaboratoryAccreditation (NACLA) or is a signatory to the International LaboratoryAccreditation Cooperation (ILAC) Mutual Recognition Arrangement(MRA).


(b) The individual certifications will remain valid for 5 years as long as the type of ambulance tested remains in production.

(c) Design changes during the 5 year certification period must be tested at the time of production release.


(e) Certification(s) will be acceptable in lieu of actual verification test during inspections providing supporting verifying data complying with 4.6.1 is on file for examination.

(f) Certification from OEM and individual equipment manufacturers are acceptable providing they are not part of a system(s) or altered and in accordance with 4.7.


4.6.1.2 Each ambulance constructed shall be tested by the FSAMto demonstrate compliance with AMD STDs 5, 9, 10, 15, 21 & 25 in addition to the initial type testing certification required.

4.7 CERTIFICATION LETTER FORMAT4.7.1 Certification letters submitted for the ambulance model,

components, and equipment being certified shall contain the following information on FSAM’s letterhead stationery in electronic format (pdf files):

1.To whom certifying.2. Date.3. Units or items.4. FSAM and address.5. Date product tested.6. Model number and specification data.7. Applicable specification references and test

requirement.



8. Summary of the test report.9. A certifying statement w/ official signature.

4.7.2Certification documentation shall be

delivered with the ambulance, including results of the certification tests. [ 1901:4.8.7]

4.7.

83

Certification tests performed on a substantially similar ambulance shall be valid for up to 7 years or until such time as the production product changes are so significant that they no longer meet the definition of a substantially similar ambulance.










4.7.5Programs shall be in place for training, proficiency testing, and performance verification of any personnel involved with certification. [ 1901: 4.8.5]

4.7.6An official of the company that manufactures or installs the product shall designate in writing who is qualified to witness tests and certify results. [ 1901:4.8.6]

4.7.74.7

Certification of Test Results by Manufacturer.Where this standard requires the results of tests or the performance of a component to be certified by the manufacturer, the manufacturer shall meet the requirements of this section. [ 1901: 4.8]

4.7.1A representative of the manufacturer shall witness all tests and shall refuse to certify any test results for a system unless all components of that system requiring testing pass the testing required by this standard. [ 1901: 4.8.1]


4.7.3The manufacturer shall have the facilities and equipment necessary to conduct the required testing, a program for the calibration of all instruments, and procedures to ensure the proper control of all testing. [ 1901: 4.8.3]CERTIFICATION LETTER FORMAT

4.7.1 Certification letters submitted for the ambulance model, components, and equipment being certified shall contain the following information on FSAM’s letterhead stationery in electronic format (pdf files):

1.To whom certifying.2. Date.3. Units or items.4. FSAM and address.5. Date product tested.6. Model number and specification data.7. Applicable specification references and test requirement.8. Summary of the test report.9. A certifying statement w/ official signature.

4.7.2



Certification documentation shall be delivered with the ambulance, including results of the certification tests. [ 1901: 4.8.7]

4.7. 8 3Certification tests performed on a substantially similar ambulance

shall be valid for up to 7 years or until such time as the production product changes are so significant that they no longer meet the definition of a substantially similar ambulance.













4.7 Certification of Test Results by Manufacturer.Where this standard requires the results of tests or the performance of a component to be certified by the manufacturer, the manufacturer shall meet the requirements of this section. [1901: 4.8]4.7.1A representative of the manufacturer shall witness all tests and shall refuse

to certify any test results for a system unless all components of that systemrequiring testing pass the testing required by this standard. [ 1901: 4.8.1]

4.7.2Conditional, temporary, or partial certification of test results shall not be

permitted.4.7.3The manufacturer shall have the facilities and equipment necessary to

conduct the required testing, a program for the calibration of all instruments, and procedures to ensure the proper control of all testing. [ 1901: 4.8.3]

4.7.4Appropriate forms or data sheets shall be provided and used during the

testing. [ 1901: 4.8.4]4.7.5Programs shall be in place for training, proficiency testing, and

performance verification of any personnel involved with certification. [ 1901:4.8.5]

4.7.6An official of the company that manufactures or installs the product shall

designate in writing who is qualified to witness tests and certify results.[ 1901: 4.8.6]

4.7.7Certification documentation shall be delivered with the ambulance,

including results of the certification tests. [ 1901: 4.8.7]4.7.8Certification tests performed on a substantially similar ambulance

shall be valid for up to 7 years or until such time as the production product changes are so significant that they no longer meet the definition of a substantially similar ambulance.

These sections should be revised as follows:

4.7 Certification of Test Results by Manufacturer. Where thisstandard requires the results of tests or the performance of a component to be certified by the manufacturer, the manufacturer shall meet the requirements of this section. [ 1901: 4.8]

4.7.1 A representative of the manufacturer shall witness all tests and shall refuse to certify any test results for a system unless all components of that system requiring testing pass the testing required by this standard. [ 1901: 4.8.1]

4.7.2 Conditional, temporary, or partial certification of test results shall not be permitted.



4.7.3 The manufacturer shall have the facilities and equipment necessary to conduct the required testing, a program for the calibration of all instruments, and procedures to ensure the proper control of all testing. [ 1901: 4.8.3]

4.7.4 Appropriate forms or data sheets shall be provided and used during the testing. [ 1901: 4.8.4]

4.7.5 Programs shall be in place for training, proficiency testing, and performance verification of any personnel involved with certification. [ 1901: 4.8.5]

4.7.6 An official of the company that manufactures or installs the product shall designate in writing who is qualified to witness tests and certify results. [ 1901: 4.8.6]

4.7 CERTIFICATION LETTER FORMAT4.7.1 Certification letters submitted for the ambulance model,

components, and equipment being certified shall contain the followinginformation on FSAM’s letterhead stationery in electronic format (pdffiles):

1.To whom certifying.2. Date.3. Units or items.4. FSAM and address.5. Date product tested.6. Model number and specification data.7. Applicable specification references and test requirement.8. Summary of the test report.9. A certifying statement w/ official signature.4.7. 2 7 Certification documentation shall be delivered with the

ambulance, including results of the certification tests. [ 1901: 4.8.7]4.7. 3 8 Certification tests performed on a substantially similar

ambulance shall be valid for up to 7 years or until such time as the production product changes are so significant that they no longer meet the definition of a substantially similar ambulance.






Public Input No. 372-NFPA 1917-2013 [ Section No. 4.7 [Excluding

any Sub-Sections] ]

Where this standard requires the results of tests or the performance of a component on a specific vehicle to be certified by the manufacturer, the manufacturer shall meet the requirements of this section. [1901: 4.8]




I propose that third party testing be required for the aspects of the ambulance in which testing each individual vehicle to the particular standard or specifically required test would be impractical. The NFPA standard should specify by passage the tests that are required on each individual ambulance by the manufacturer and those tests required by third party testing with a 7 year duration for testing a substantially similar vehicle types. Manufacturers will provide testing as required for individual vehicles.









4.7.1 The scope of testing to be certified by the FSAM includes all AMD non-type tests. That is, the AMD tests that must be performed on each individualvehicle manufactured by the FSAM.


File Name Description Approved1917_Allen.pdf Cover Sheet


This addition is recommended to clarify that the AMD tests other than the type tests covered in 4.6 need to be certified by the FSAM.









4.7.8Third-Party Certification tests testing performed on a substantially similar ambulance shall be valid for up to 7 years or until such time as the production product changes are so significant that they no longer meet the definition of a substantially similar ambulance.




I propose that third party testing be required for the aspects of the ambulance in which testing each individual vehicle to the particular standard or specifically required test would be impractical. The NFPA standard should specify by passage the tests that are required on each individual ambulance by the manufacturer and those tests required by third party testing with a 7 year duration for testing a substantially similar vehicle types.








Public Input No. 262-NFPA 1917-2013 [ Section No. 4.9.2.3.2 ]

4.9.2.3.2 * Controls and switches that are expected to be operated by the belted emergency medical service provider (EMSP) while the ambulance is in motion shall be visible and within reach of the designated primary patient care position. (including those of equipment) in the patient compartment shall be within a maximum functional reach of 26.7 in. (678 mm) to the EMSPs with height as short as 59.3 in. (1506 mm) while seated and restrained, or operable through a remote control stored within the same reach condition.


It is essential for EMSPs to have an easy reach to the control panel area or a stored remote control that communicates with the patient compartment controls, but that is not always the case. By accommodating the functional reach of these tools to a shorter demographic with a smaller reach, EMSPs will have fewer difficulties in reaching and accessing the controls. This will enhance their safety by allowing them to stay restrained more often and will also increase working efficiency. The human factors practices in MIL-STD 1472G, Design Criteria Standard Human Engineering (January 2012), have provisions for thumb-tip functional reach. Table B-I, Standing Body Dimensions – General Forces, of MIL-STD 1472G addresses functional reachability ranges for different size demographics.

Also, a star (*) is added to the section title, 4.9.2.3.2. This is because a new annex to this item is recommended.









4.11.1The ambulance shall meet the requirements of this standard at elevations up to 2000 ft (600 m) above sea level.


Because the vast majority of ambulances in the US operate at elevations well below 2000 ft above sea level, the requirement to test at that elevation creates an unjustifiable additional expense. The number of tests affected by elevation is small. For those tests that are affected by elevation, it is more reasonable for customers that operate at high elevation or the states that regulate them to add requirements for high elevation testing to the extent they are warranted by their operating requirements.









4.11.1The ambulance shall meet the requirements of this standard at elevations up to 2000 ft (600 m) above sea level.


File Name Description ApprovedSignature_Page.pdf Signatur Page


Because the vast majority of ambulances in the US operate at elevations well below 2000 ft above sea level, the requirement to test at that elevation creates an unjustifiable additional expense. The number of tests affected by elevation is small. For those tests that are affected by elevation, it is more reasonable for customers that operate at high elevation to add requirements for high elevation testing to the extent they are warranted by their operating requirements.









4.11.1The ambulance shall meet the requirements of this standard at elevations up

to 2000 ft (600 m) above sea level.

4.11.1 The ambulance shall meet the requirements of this standard at elevations up to 2000 ft (600 m) above sea level.


Substantiation: Because the vast majority of ambulances in the US operate at elevations well below 2000 ft above sea level, the requirement to test at that elevation creates an unjustifiable additional expense. The number of tests affected by elevation is small. For those tests that are affected by elevation, it is more reasonable for customers that operate at high elevation to add requirements for high elevation testing to the extent they are warranted by their operating requirements.









4.11.2 *The ambulance shall meet all the requirements of this standard while stationary on a grade of 6 percent in any direction.


While we fully expect the ambulance to perform to this standard while parked on a 6 percent grade in any direction, there is no feasible way to validate that performance. The platforms for performing such tests are not available. But even if they were, there is no justification for multiplying the testing cost by a factor of five on account of performing all tests at four orientations other than horizontal.









4.11.2 *The ambulance shall meet all the requirements of this standard while stationary on a grade of 6 percent in any direction.




While we fully expect the ambulance to perform to this standard while parked on a 6 percent grade in any direction, there is no feasible way to validate that performance. The platforms for performing such tests are not available. But even if they were, there is no justification for multiplying the testing cost by a factor of five on account of performing all tests at four orientations other than horizontal.









4.11.2 *The ambulance shall meet all the requirements of this standard while

stationary on a grade of 6 percent in any direction.

4.11.2* The ambulance shall meet all the requirements of this standard while stationary on a grade of 6 percent in any direction.This sections hould be deleted


Substantiation: While we fully expect the ambulance to perform to this standard while parked on a 6 percent grade in any direction, there is no feasible way to validate that performance. The platforms for performing such tests are not available. But even if they were, there is no justification for multiplying the testing cost by a factor of five on account of performing all tests at four orientations other than horizontal.


Submitter Full Name: Ronald ThackeryOrganization: American Medical Response, IncStreet Address: City: State:Zip: Submittal Date: Mon Jul 01 12:01:43 EDT 2013







4.11.3 *Where temperature requirements are not otherwise specified, the ambulance shall be designed to function in ambient temperature conditions between -20°F and 110°F (-29°C and 43°C 0°F to 95°F (-18°C to 35°C ).4.11.3.1All interior systems, components, and permanently attached equipment shall

function satisfactorily over a temperature range of 32°F to 95°F (0°C to 35°C).

4.11.3.1.1Compliance of the equipment function shall be validated by testing a

substantially similar ambulance in accordance with Section 9.11 .4.11.3.1.2

The ambulance and all systems, components, and equipment shall be capable of being stored at an ambient temperature between 32°F and 95°F (0°C to 35°C) without damage or deterioration.




Chassis manufacturers only provide pass through certification for cold start at 0°F. Expanding the range of degrees requires additional costs and testing that are unnecessary in most areas of the country. States that experience extremes oftemperature can impose regulations that conform to their environment, and/or local EMS agencies can spec to that. It is virtually impossible for the OEM or ambulance manufacturer to produce vehicles that comply with the NFPA 1917 requirements. There are specific areas of the United States with extremes of temperature that can and do establish specifications for temperature ranges for those variables. There is no need for the NFPA technical committee on ambulances to establish a one size fits all range of temperatures.







4.11.3 *Where temperature requirements are not otherwise specified, the

ambulance shall be designed to function in ambient temperature conditions between -20°F and 110°F (-29°C and 43°C).

4.11.3.1All interior systems, components, and permanently attached equipment

shall function satisfactorily over a temperature range of 32°F to 95°F (0°C to35°C).

4.11.3.1.1Compliance of the equipment function shall be validated by testing a

substantially similar ambulance in accordance with Section 9.11 .4.11.3.1.2The ambulance and all systems, components, and equipment shall be

capable of being stored at an ambient temperature between 32°F and 95°F (0°C to 35°C) without damage or deterioration.

4.11.3* Where temperature requirements are not otherwise specified, the ambulance shall be designed to function in ambient temperature conditions between −20°F and 110°F (−29°C and 43°C) 0°F to 95°F (-18°C to 35°C) .


Substantiation: Chassis manufacturers only provide pass through certification for cold start at 0°F. Expanding the range of degrees requires additional costs and testing that are unnecessary in most areas of the country. States that experience extremes of temperature can impose regulations that conform to their environment, and/or local EMS agencies can spec to that. It is virtually impossible for the OEM or ambulance manufacturer to produce vehicles that comply with the NFPA 1917 requirements. There are specific areas of the United States with extremes of temperature that can and do establish specifications for temperature ranges for those variables. There is no need for the NFPA technical committee on ambulances to establish a one size fits all range of temperatures.







any Sub-Sections] ]

Where temperature requirements are not otherwise specified, the ambulance shall be designed to function in ambient temperature conditions between -20°F and 110°F (-29°C and 43°C 0°F to 95°F (-18°C to 35°C ) .


Chassis manufacturers only provide pass through certification for cold start at 0°F. Expanding the range of degrees requires additional costs and testing that are unnecessary in most areas of the country. States that experience extremes of temperature can impose regulations that conform to their environment, and/or local EMS agencies can spec to that. It is virtually impossible for the OEM or ambulance manufacturer to produce vehicles that comply with the NFPA 1917 requirements. There are specific areas of the United States with extremes of temperature that can and do establish specifications for temperature ranges for those variables. There is no need for the NFPA technical committee on ambulances to establish a one size fits all range of temperatures.









4.12.3The maximum top speed of the ambulance shall not exceed 77 mph (124 km/hr) or the manufacturer's maximum service speed rating for the tiresinstalled on the ambulance, whichever is lower.


Substantiation: This provision was previously deleted from NFPA 1917 through a Temporary Interim Amendment. It is time to make that a permanent change. States are afforded the primary responsibility to establish speed for roadways and any exceptions for emergency vehicles. It is not within the purview of an ambulance design standard to supersede or subvert State rights. If there is scientific research or other information that the NFPA technical committee on ambulances desires to communicate to the ambulance community, it may be included or referenced in the annex. The requirement of a speed limiting device that places a maximum speed limit of 77 mph creates a safety hazard for operators and occupants of ambulances, especially in states that have posted speed limits above 77 mph. In some states, For example, Texas, there is a posted speed limit of 85 mph and an NFPA 1917 compliant ambulance would not be able to meet the posted speed limit, thus creating a safety hazard. This is also true in states where emergency vehicles are allowed to exceed the posted speed limit by 10 mph; with 77 mph being the maximum, in a standard that comprises minimum requirements, the posted speed limit would have to be as low as 67 mph which is not common in some states. This requirement places a restriction upon some states that would prohibit them from purchasing an NFPA 1917 compliant ambulance.


Submitter Full Name: ELENA SIERRAOrganization: Association of Air Medical Services (AAMS)Affilliation: Association of Air Medical Services (AAMS)Street Address:City: State: Zip:Submittal Date: Fri Jul 05 14:30:40 EDT 2013






This provision was previously deleted from NFPA 1917 through a Temporary Interim Amendment. This should be preserved as a permanent change. States are afforded the primary responsibility to establish speed limits for roadways and any exceptions for emergency vehicles. It is not within the purview of an ambulance design standard to supersede or subvert State rights. If there is scientific research or other information that the NFPA technical committee on ambulances desires to communicate to the ambulance community, it may be included or referenced in the annex. The requirement of a speed limiting device that places a maximum speed limit of 77 mph creates a safety hazard for operators and occupants of ambulances, especially in states that have posted speed limits above 77 mph. In some states, For example, Texas, there is a posted speed limit of 85 mph and an NFPA 1917 compliant ambulance would not be able to meet the posted speed limit, thus creating a safety hazard. This is also true in states where emergency vehicles are allowed to exceed the posted speed limit by 10 mph; with 77 mph being the maximum, in a standard that comprises minimum requirements, the posted speed limit would have to be as low as 67 mph which is not common in some states. This requirement places a restriction upon some states that would prohibit them from purchasing an NFPA 1917 compliant ambulance. This is a matter of state regulation and not design standards.









4.12.3The maximum top speed of the ambulance shall not exceed 77 mph (124 km/hr) or the manufacturer's maximum service speed rating for the tires installed on the ambulance , whichever is lower .




Regulation of speed is outside the scope of an ambulance standard. This is a states rights issue.











File Name Description Approved

Signature_Page.pdf Signature Page


This provision was previously deleted from NFPA 1917 through a Temporary Interim Amendment. It is time to make that a permanent change. States are afforded the primary responsibility to establish speed for roadways and any exceptions for emergency vehicles. It is not within the purview of an ambulance design standard to supersede or subvert State rights. If there is scientific research or other information that the NFPA technical committee on ambulances desires to communicate to the ambulance community, it may be included or referenced in the annex. The requirement of a speed limiting device that places a maximum speed limit of 77 mph creates a safety hazard for operators and occupants of ambulances, especially in states that have posted speed limits above 77 mph. In some states, For example, Texas, there is a posted speed limit of 85 mph and an NFPA 1917 compliant ambulance would not be able to meet the posted speed limit, thus creating a safety hazard. This is also true in states where emergency vehicles are allowed to exceed the posted speed limit by 10 mph; with 77 mph being the maximum, in a standard that comprises minimum requirements, the posted speed limit would have to be as low as 67 mph which is not common in some states. This requirement places a restriction upon some states that would prohibit them from purchasing an NFPA 1917 compliant ambulance.








4.12.3The maximum top speed of the ambulance shall not exceed 77 mph (124

km/hr) or the manufacturer's maximum service speed rating for the tires installed on the ambulance, whichever is lower.

4.12.3 The maximum top speed of the ambulance shall not exceed 77 mph (124 km/hr) or the manufacturer's maximum service speed rating for the tires installed on the ambulance, whichever is lower.


Substantiation: This provision was previously deleted from NFPA 1917 through a Temporary Interim Amendment. It is time to make that a permanent change. States are afforded the primary responsibility to establish speed for roadways and any exceptions for emergency vehicles. It is not within the purview of an ambulance design standard to supersede or subvert State rights. If there is scientific research or other information that the NFPA technical committee on ambulances desires to communicate to the ambulance community, it may be included or referenced in the annex. The requirement of a speed limiting device that places a maximum speed limit of 77 mph creates a safety hazard for operators and occupants of ambulances, especially in states that have posted speed limits above 77 mph. In some states, For example, Texas, there is a posted speed limit of 85 mph and an NFPA 1917 compliant ambulance would not be able to meet the posted speed limit, thus creating a safety hazard. This is also true in states where emergency vehicles are allowed to exceed the posted speed limit by 10 mph; with 77 mph being the maximum, in a standard that comprises minimum requirements, the posted speed limit would have to be as low as 67 mph which is not common in some states. This requirement places a restriction upon some states that would prohibit them from purchasing an NFPA 1917 compliant ambulance.







Public Input No. 8-NFPA 1917-2013 [ Sections 4.12.3, 4.12.4 ]

Sections 4.12.3, 4.12.4

4.12.3

The maximum top speed of the ambulance shall not exceed 77 mph (124 km/hr) or the manufacturer's maximum service speed rating for the tires installed on the ambulance, whichever is lower.4.12.4 *

The ambulance shall be capable of a sustained speed of not less than 65 mph (105 km/hr) over dry, hard-surfaced, level roads, at sea level, and passing speeds of 70 mph (112 km/hr) when tested under normal ambient conditions.


Note: This Proposal originates from Tentative Interim Amendment 1917-13-1 (TIA 1089) issued by the Standards Council on March 7, 2013.NASEMSO cannot support or enforce 4.12.3, and the need for this deletion remains even if the TIA related to Section 4.17 is granted. There are states where the legal speed limit is above 77 mph, including 80 and 85 mph.

Further, in some states, an ambulance operating with lights and sirens can legally exceed the posted speed limit by 10 mph. Therefore, while well intentioned for roadways with a posted speed limit of 65 mph or less, a governor set to 77 mph will actually create a safety hazard as a result of ambulances traveling at much slower speeds than the surrounding traffic. Speed should be governed by the states and the owners and operators of the ambulances. Since not every chassis manufacturer makes speed governors available, NASEMSO is also deeply concerned about the risk aversion expressed by ambulance manufacturers about aftermarket installation and device failure. Availability of this technology is extremely limited among chassis and aftermarket device

manufacturers, and only one brand has been identified that can be set at 77 mph. NASEMSO recognizes the importance of safe ambulance operations and is cognizant of other electronic means of speed monitoring, the annex content on monitoring systems, as well as local EMS agency policies related to the matter.

Emergency Nature: The requirement of a speed limiting device that places a maximum speed limit of 77 mph creates a safety hazard for operators and occupants of ambulances, especially in states that have posted speed limits above 77 mph. In some states, For example, Texas, there is a posted speed limit of 85 mph and an NFPA 1917–compliant ambulance would not be able to meet the posted speed limit, thus creating a safety hazard. This is also true in states where emergency vehicles are allowed to exceed the posted speed limit by 10 mph; with 77 mph being the maximum, in a standard that comprises minimum requirements, the posted speed limit would have to be as low as 67 mph which is not common in some states. This requirement places a restriction upon some states that would prohibit them from purchasing an NFPA 1917–compliant ambulance.




Submitter Full Name: Dia GainorOrganization: Nat'l Assn. of State EMS Officials (NASEMSO)Street Address:City: State: Zip:Submittal Date: Tue Mar 12 11:10:27 EDT 2013







4.13.1The ambulance shall be designed so that all the Chassis manufacturer's recommended routine maintenance checks of lubricant and fluid levels can be performed by the operator without the need for hand tools.




Clarification added the word chassis.









4.16.1 Ambulance Documentation.The contractor shall deliver with the ambulance at least one copy of the following documents:

(1) The manufacturer's record of ambulance construction details, including the following information:

(a) Owner's name and address

(b) Ambulance manufacturer, model, and serial number

(c) Chassis make, model, and vehicle identification number (VIN)

(d) GAWR of front and rear axles and GVWR

(e) Front tire size and total rated capacity in pounds (kilograms)

(f) Rear tire size and total rated capacity in pounds (kilograms)

(g) Type of fuel and fuel tank capacity(h) Electrical system voltage and alternator output in amps

(i) Paint manufacturer and paint number(s)

(j) Company name and signature of responsible company representative

(k) Documents from a certified scale showing curb weight on the front axle and rear axle(s) (without personnel and equipment)

(l) Documentation of each test performed as required by NFPA 1917 or AMD Standards 5, 9, 10, 15, 21, and 25 and the initial typetesting required.

(2) Certification of compliance of the optical warning system (see 7.9.16)

(3) Siren manufacturer’s certification of the siren (see 7.10.1.1)

(4) Written load analysis and results of the electrical system performance tests (see Section 9.1 and Section 9.2)

(5) Certification of slip resistance of all exterior stepping, standing, and walking surfaces (see Section 6.12 )


With the utilization of AMD testing standards, Ambulance Manufacturers will need to represent that all necessary testing in accord with those standards has been completed successfully to a purchaser. The AMD standards listed in (l) prescribe testing to be done on each ambulance. The documentation should be included with the ambulance as a record of the performance of each ambulance in each area of required testing. The proposed change to 6.11.4 eliminates item (5).







(2) Owner's name and address

(3) Ambulance manufacturer, model, and serial number

(4) Chassis make, model, and vehicle identification number (VIN)

(5) GAWR of front and rear axles and GVWR

(6) Front tire size and total rated capacity in pounds (kilograms)

(7) Rear tire size and total rated capacity in pounds (kilograms)(8) Type of fuel and fuel tank capacity

(9) Electrical system voltage and alternator output in amps

(10) Paint manufacturer and paint number(s)

(11) Company name and signature of responsible company representative

(12) Documents from a certified scale showing curb weight on the front axle and rear axle(s) (without personnel and equipment)

(13)Documentation of each test performed as required by NFPA 1917 or AMD Standards 5, 9, 10,15, 21, and 25 and the initial type testing required.

(14) Certification of compliance of the optical warning system (see7.9.16 )

(15) Siren manufacturer’s certification of the siren (see 7.10.1.1 )

(16) Written load analysis and results of the electrical system performance tests (see Section 9.1 and Section 9.2 )

Certification of slip resistance of all exterior stepping, standing, and walking surfaces (see Section 6.12 )

•






With the utilization of AMD testing standards, Ambulance Manufacturers will need to represent that all necessary testing in accord with those standards has been completed successfully to a purchaser. The AMD standards listed in (l) prescribe testing to be done on each ambulance. The documentation should be included with the ambulance as a record of the performance of each ambulance in each area of required testing. The proposed change to 6.11.4 eliminates item (5).











(a) Owner's name and address

(b) Ambulance manufacturer, model, and serial number

(c) Chassis make, model, and vehicle identification number (VIN)

(d) GAWR of front and rear axles and GVWR

(e) Front tire size and total rated capacity in pounds (kilograms)

(f) Rear tire size and total rated capacity in pounds (kilograms)

(g) Type of fuel and fuel tank capacity(h) Electrical system voltage and alternator output in amps

(i) Paint manufacturer and paint number(s)

(j) Company name and signature of responsible company representative

(k) Documents from a certified scale showing curb weight on the front axle and rear axle(s) (without personnel and equipment)

(2) Certification of compliance of the optical warning system (see 7.9.16)

(3) Siren manufacturer’s certification of the siren (see 7.10.1.1)

(4) Written load analysis and results of the electrical system performance tests (see Section 9.1 and Section 9.2)

(5) Certification of slip resistance of all exterior stepping, standing, and walking surfaces (see Section 6.12)

This section should be revised as follows:4.16.1 Ambulance Documentation. The contractor shall deliver with the

ambulance at least one copy of the following documents:(1) The manufacturer's record of ambulance construction details, including the following information:

(a) Owner's name and address(b) Ambulance manufacturer, model, and serial number(c) Chassis make, model, and vehicle identification number (VIN)(d) GAWR of front and rear axles and GVWR(e) Front tire size and total rated capacity in pounds (kilograms)(f) Rear tire size and total rated capacity in pounds (kilograms)(g) Type of fuel and fuel tank capacity(h) Electrical system voltage and alternator output in amps



(i) Paint manufacturer and paint number(s)(j) Company name and signature of responsible company representative(k) Documents from a certified scale showing curb weight on the front axle and rear axle(s) (without personnel and equipment)(l) Documentation of each test performed as required by NFPA

1917 or AMD Standards 5, 9, 10,15, 21, and 25 and the initial type testing required.

(5) Certification of slip resistance of all exterior stepping, standing, and walking surfaces (see Section 6.12 )


Substantiation: With the utilization of AMD testing standards, Ambulance Manufacturers will need to represent that all necessary testing in accord with those standards has been completed successfully to a purchaser. The AMD standards listed in (l) prescribe testing to be done on each ambulance. The documentation should be included with the ambulance as a record of the performance of each ambulance in each area of required testing. The proposed change to 6.11.4 eliminates item (5).









4.16.2.3 *The contractor shall also deliver with the ambulance the following documentation for the entire ambulance and each major operating system or major component of the ambulance:

(1) Manufacturer's name and address

(2) Country of manufacture(3) Source for service and technical information

(4) Parts replacement information

(5) Descriptions, specifications, and ratings of the chassis

(6) Wiring diagrams for low voltage and line voltage ambulance-specific systems to include the following information:

(a) Circuit logic for all electrical components and wiring(b) Circuit identification

(c) Connector pin identification

(d) Zone location of electrical components

(e) Safety interlocks

(f) Alternator battery power distribution circuits

(g) Input/output assignment sheets or equivalent circuit logic implemented in multiplexing systems

(7) Lubrication charts

(8) Operating instructions for the chassis and any major components

(9) Instructions regarding the frequency and procedure for recommended maintenance

(10) Overall ambulance operating instructions

(11) Safety considerations

(12) Limitations of use(13) Inspection procedures

(14) Recommended service procedures

(15) Troubleshooting guide

(16) Ambulance body, chassis, and other component manufacturer'swarranties

(17) Special data required by this standard

(18) Material safety Safety data sheet ( MSDS SDS ) for any fluid that is specified for use on the ambulance module




OSHA has amended the Hazard Communication standard to bring it into concert with the worldwide Global Harmonization Standard. As a result, the term “Material Safety Data Sheet” has been replaced with “Safety Data Sheet”.









4.16.2.3 *The contractor shall also deliver with the ambulance the following documentation for the entire ambulance and each major operating system or major component of the ambulance:














(9) Instructions regarding the frequency and procedure for recommended maintenance



(12) Limitations of use(13) Inspection procedures

(14) Recommended service procedures




(18) Material safety Safety data sheet ( MSDS SDS ) for any fluid that is specified for use on the ambulance module






OSHA has amended the Hazard Communication standard to bring it into concert with the worldwide Global Harmonization Standard. As a result, the term “Material Safety Data Sheet” has been replaced with “Safety Data Sheet”.









4.16.2.3 *The contractor shall also deliver with the ambulance the following

documentation for the entire ambulance and each major operating system or major component of the ambulance:














(9) Instructions regarding the frequency and procedure for recommendedmaintenance



(12) Limitations of use

(13) Inspection procedures(14) Recommended service procedures




(18) Material safety data sheet (MSDS) for any fluid that is specified for use on the ambulance module

This sections hould be revised as follows:4.16.2.3* The contractor shall also deliver with the ambulance the

following documentation for the entire ambulance and each major operating system or major component of the ambulance:



(1) Manufacturer's name and address(2) Country of manufacture(3) Source for service and technical information(4) Parts replacement information(5) Descriptions, specifications, and ratings of the chassis(6) Wiring diagrams for low voltage and line voltage ambulance-

specific systems to include the following information:(a) Circuit logic for all electrical components and wiring(b) Circuit identification(c) Connector pin identification(d) Zone location of electrical components(e) Safety interlocks(f) Alternator battery power distribution circuits(g) Input/output assignment sheets or equivalent circuit logic

implemented in multiplexing systems(7) Lubrication charts(8) Operating instructions for the chassis and any major

components(9) Instructions regarding the frequency and procedure for

recommended maintenance(10) Overall ambulance operating instructions(11) Safety considerations(12) Limitations of use(13) Inspection procedures(14) Recommended service procedures(15) Troubleshooting guide(16) Ambulance body, chassis, and other component manufacturer's

warranties(17) Special data required by this standard(18) Material safety Safety data sheet ( M SDS) for any fluid that is

specified for use on the ambulance module


Substantiation: OSHA has amended the Hazard Communication standard to bring it into concert with the worldwide Global Harmonization Standard. As a result, the term “Material Safety Data Sheet” has been replaced with “Safety Data Sheet”.





4.17 Statement of Exceptions.The entity responsible for final assembly of the ambulance shall deliver with the ambulance eithera certification that the ambulance fullycomplies with allminimum requirements of this standardor, alternatively, . When exceptions to this standard are required by the purchaser, aStatement of Exceptions specifically describing each aspect of the completed ambulance that is not fully compliant with the requirements of this standard at the time of deliverybased on any exceptions to this standard that are required to meet the specifications of the purchaser shall be listed and attached to owner's manual .4.17.1

The Statement of Exceptions shall contain, for each

noncompliant aspect of the ambulance or missing required item, the following information: A

exception at the time of delivery: a separate listing of the section(s) of the applicable standard for which

compliance is lacking

A description of the particular aspect of the ambulance that is not in compliance therewith or required equipment that is missing

•

A description of the further changes or modifications to the delivered ambulance that must be completed to achieve full compliance

•

Identification of the entity that will be responsible for making the necessary post-delivery changes or modifications or for supplying and installing any missing required equipment to the ambulance to achieve full compliance with this standard

•

an exception has occurred4.17.2

Prior to, or at the time of, delivery of the ambulance, the Statement of Exceptions shall be signed by an authorized agent of the entity responsible for final assembly of the ambulance and by an authorized agent of the purchasing entity, indicating mutual understanding and agreement between the parties regarding the substance thereof.

4.17.3



An ambulance that is delivered subject to a Statement of Exceptions other than a certification of full compliance shall not be placed in emergency service until the ambulance has been modified as necessary to accomplish full compliance with this standard.


Note: This Proposal originates from Tentative Interim Amendment 1917-13-2 (TIA 1088) issued by the Standards Council on March 7, 2013.The states’ EMS offices have the exclusive authority to license EMS agencies and vehicles to function in their respective states, and in turn, the National Association of State EMS Officials (NASEMSO) is the only nationally representative organization of the state EMS offices. NASEMSO has determined that there would be significant complications created related to its members’ ability to regulate ambulance vehicle design with the language as currently written. The language marked for deletion poses legal impediments with respect to the state EMS directors’ ability to certify ambulances in their respective states. Specifically, the requirement for a statement of exceptions including a prohibitive

provision (4.17.3) is contrary to the legislative mandate of states that set the conditions under which an ambulance may be placed into service. This is a function of the authority of the states and not one that can be agreed to between a purchaser and a manufacturer. We accept that the Statement of Exceptions should be published since that assists state EMS inspectors to determine what, if any, exceptions from this specification exist based on the manufacturer’s determination, and that 4.17.2 ensures awareness on the part of the purchaser, but any further conditions or requirements are an impediment to the states’ regulatory processes. Considering the seven states that do not regulate ambulance vehicle design and other

states that may incorporate only select components of a specification, other language is marked for deletion or modification because it is either too restrictive or suggestive of actions that may not be required in a given state (e.g., 4.17.1(3) and (4)). This would prevent state EMS directors from permitting vehicles that will operate safely and successfully as ambulances in their respective states. Furthermore, 4.17.3 may create considerable liability for the ambulance owner and the states. Foreseeable examples of this include the discovery after an incident or upon a state inspection of paperwork associated with the new vehicle that the ambulance purchaser documented that it would modify the vehicle prior to placing it into service when there was no legal obligation to do so. Approval of this TIA does not negate the need for favorable consideration of the TIA

related to 4.12.3.

Emergency Nature: The statement of exceptions, as noted in the 2013 edition of NFPA 1917, would prohibit states from being able to use the standard to purchase ambulances since it does not allow for variability from state to state. The requirement for a Statement of Exceptions, including a prohibitive provision (4.17.3), is contrary to the legislative mandate of states that sets the conditions under which an ambulance may be placed into service. This is a function of the authority of the states and not one that can be agreed to between a purchaser and a manufacturer. We accept that the Statement of Exceptions should be published since that assists state EMS inspectors to determine what, if any, exceptions from this specification exist based on the manufacturer’s determination, and that 4.17.2 ensures awareness on the part of the purchaser, but any further conditions or requirements are an impediment to the states’ regulatory processes.





4.17.1The Statement of Exceptions shall contain, for each noncompliant aspect of the ambulance or missing required item, the followinginformation:

(1) A separate listing of the section(s) of the applicable standard for which compliance is lacking

(2) A description of the particular aspect of the ambulance that is not in compliance therewith or required equipment that is missing

(3) A description of the further changes or modifications to the delivered ambulance that must be completed to achieve full compliance

(4) Identification of the entity that will be responsible for making the necessary post-delivery changes or modifications or for supplying and installing any missing required equipment to the ambulanceto achieve full compliance with this standard




Delete sections 3 and 4. This allows customers to have flexibility.








4.17.3An ambulance that is delivered subject to a Statement of Exceptions other than a certification of full compliance shall not be placed in emergency service until the ambulance has been modified as necessary to accomplish full compliance with this standard.




Unnecessary restriction.









5.1.1The manufacturer shall establish not exceed the required Chassis GVWR during the design of the ambulance using the method and values specified in Table 5.1.1 .Table 5.1.1 Required GVWR Calculation

Component

Weight

(lb)ChassisAmbulancebody completeAutomotivefluidsPermanentlymounted equipmentLooseequipment Type I 750

(Use one of these values unless the required loose equipment is specified bythe purchaser)

Type I-AD 1250

Type II 500Type III 750Type III-AD 1250

Beltedoccupant seating positions

(No. Seats) × 171

Cotpatient 171

Cot Standardcot 100

Power cot 150Sparecapacity 200

MinimumGVWR required



Note: 1 lb = 0.45 kg.




Clarification.


Submitter Full Name: Randy HansonOrganization: ASV/American Emergency VehicleStreet Address: City:State: Zip: Submittal Date: Wed Jul 10 08:10:23 EDT 2013







5.1.2The manufacturer shall design the ambulance such that the completed ambulance , when loaded to its required GVWR with all loose equipment distributed as close as practical to its intended in-service configuration, does not exceed the GVWR or GAWR of thechassis.




Impossible for the manufacturer to determine what the end user will ultimately carry onboard the ambulance. Impossible for the end user to determine how a crew or situation will effect the loading of the vehicle.









5.1.3.2 *The label shall show the height of the completed ambulance in feet and inches (meters), and the GVWR in tons (metric tons)pounds .




In many rural areas bridges are still rated and posted in pounds.









5.3.1.2Third party or OEM certification required. Compliance shall be validated by testing a substantially similar ambulance in accordancewith Section 9.22 .




Clarification of testing responsibility. I propose that third party testing be required for the aspects of the ambulance in which testing each individual vehicle to the particular standard or specifically required test would be impractical. The NFPA standard should specify by passage the tests that are required on each individual ambulance by the manufacturer and those tests required by third party testing with a 7 year duration for testing a substantially similar vehicle types.









5.3.4Idle reduction engine shutdown device shall be disabled if provided in accordance with federal and state exemptions.


This should be locally determined if not regulated by the state. There may be cases where statute prohibits disabling the idle reduction shutdown device. In any case, there is no reason to stipulate disabling of the shutdown device as the ambulance manufacturers will do this automatically in order to sustain the required alternator output. The exception will be on ambulances with anti-idling systems with a voltage-monitoring, auto re-start feature, in which case the requirement to disable the shutdown device would be inappropriate.









5.3.4Idle reduction engine shutdown device shall be disabled if provided in accordance with federal and state exemptions.




This should be locally determined if not regulated by the state. There may be cases where statute prohibits disabling the idle reduction shutdown device. In any case, there is no reason to stipulate disabling of the shutdown device as the ambulance manufacturers will do this automatically in order to sustain the required alternator output. The exception will be on ambulances with anti-idling systems with a voltage-monitoring, auto re-start feature, in which case the requirement to disable the shutdown device would be inappropriate.









5.3.4Idle reduction engine shutdown device shall be disabled if provided in

accordance with federal and state exemptions.

This section should be deleted:

5.3.4 Idle reduction engine shutdown device shall be disabled if provided in accordance with federal and state exemptions.


Substantiation: This should be locally determined if not regulated by the state. There may be cases where statute prohibits disabling the idle reduction shutdown device. In any case, there is no reason to stipulate disabling of the shutdown device as the ambulance manufacturers will do this automatically in order to sustain the required alternator output. The exception will be on ambulances with anti-idling systems with a voltage-monitoring, auto re-start feature, in which case the requirement to disable the shutdown device would be inappropriate.









5.4.1 *An engine speed auxiliary control device (high-idle switch, throttle, or automatic voltage monitor) shall be installed to allow an increase in the engine speed when the ambulance is parked. The engine speed is to be limited to 1500 RPM or the OEM guidelines if less than 1500RPM.




Clarify the limitations (1500 RPM) already established in other portions of this standard. Reference 9.12 (16) (26), 9.14. A range of 1500-1600 RPM would actually be more accurate and appropriate.









5.5.2Compliance of the engine’s cooling system shall be validated by OEM certification or Third party testing of a substantially similar ambulance in accordance with Section 9.14 .













5.8.2 *A traction control feature shall be provided if available from the OEM .




The current wording restricts the use of some currently used chassis.









5.8.4 Any ambulance with an air-ride suspension shall include an a (heated) air dryer and automatic heated moisture ejection device to ensure that the air system is provided with dry air to protect the suspension control components.


File Name Description Approved1917_Lammers.pdf Cover Sheet


Kelderman has been using a heated dryer without the heated spitter valve for 4 years now and has not had any issues related to moisture freezing within the components of the air management systems. Prior to having a heated dryer as standard, problems did occur, especially with the mechanical height control valves. Today, 95% of all ambulances that use air rides select the electronic systems, thus eliminating the need for mechanical height control valves. Requiring the need for a heated spitter valve is an unneeded expense and also creates the need for additional maintenance.


Submitter Full Name: Lanny LammersOrganization: Kelderman Air SuspensionsStreet Address:City: State: Zip:Submittal Date: Thu Jan 24 12:23:37 EST 2013


I, Lanny Lammers, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement ofProblem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am Lanny Lammers, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature




5.8.4 Any ambulance with an air-ride suspension shall include a manual drain valve on the air tank and an air dryer and automatic heated moisture ejection device capable of dew point depression to ensure that the air system is provided with dry air to protect the suspension control components.


We have run into an issue with the current version of 1917. The standard calls for both and “air dryer and automatic heated moisture ejection device” commonly known as an automatic drain valve in the heavy truck industry. The use of a dew point depressing air dryer and a manual drain valve on the air reservoir obsoletes the older and less robust technology of the automatic drain valve. There are also devices on the market which call themselves air dryers but do not cause an actual dew point depression and therefore do not prevent moisture condensation inside the air reservoir. The ambulance market that uses a truck or van chassis with hydraulic brakes must be equipped with electric compressors that run off the vehicle's electrical system. The use of air on these vehicles is only for the rear suspension and uses considerably less air volume than a normal air-braked vehicle. The current vehicles have no space on the engine for a belt driven compressor. The result is that the ambulance makers desire a small, quiet electric powered air compressor which uses minimal amperage. The current technology of automatic drain valves were designed to work on Class 8 vehicle air systems. These class 8 truck systems, in comparison, have an almost unlimited air source. Tech sheets of these automatic drain valves all show leakage rates at low temperatures. Small leaks in this valve are unnoticeable on the normal class 8 vehicle. The same leakage rate on these small 12V air compressor systems is significant and since it causes the air compressor to operate in order to replace the air lost due to leakage, this leakage is detrimental to compressor life (based on vehicle service time or mileage). If the air dryer is functioning properly, there is no liquid water in the reservoir and therefore no value added for the cost of the automatic drain valve and loss of compressor life. We do recommend installing a manual drain valve on the reservoir that should be used on a routine basis to check for proper air dryer performance.


Submitter Full Name: WILLIAM OTTOrganization: LINK MFG LTDStreet Address:City: State: Zip:Submittal Date: Fri Feb 01 10:46:38 EST 2013




I, WILLIAM OTT, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I herebywarrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am WILLIAM OTT, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature




Loose Wheel Nut (Lug Nut) IndicatorsEach wheel nut (lug nut) shall include a visual indicator to ensure lug nuts have not loosened.


Loose wheel indicators will allow for the often visual inspection by regular Fire and EMS crews, ensuring the in integrity of the lug nuts. Without insured integrity the lugs will loosen during regular use and potentially cause the wheel to separate from the hub of the ambulance. The wheel (tire and rim) become a projectile travelling at highway speeds away from the ambulance that has now lost its wheel and is sitting on three wheels and losing control. Some American trucking industry statics claim there are over 11,000 lug nut issues per year of various severities. Yielding in 400 wheel loses and multiple road side fatalities. All NYC MTA busses and newer FDNY trucks as well as my own fleet (Saint Clares, NJ) now have them after we had lost lug nuts without our staff noticing for a few days.

Just one article. http://www.jsonline.com/business/29311759.html


Submitter Full Name: James WoodsOrganization: Saint Clares Health System NJ NON-PROFITStreet Address: City:State: Zip: Submittal Date: Tue Apr 16 02:10:31 EDT 2013


I, James Woods, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I herebywarrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am James Woods, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature




5.9.3 *Unless the customer elects to forego the standard tire chain clearance. Clearance for tire chains shall be provided for rear wheels in accordance with SAE J683, Tire Chain Clearance — Trucks, Buses (Except Suburban, Intercity, and Transit Buses), and Combinations of Vehicles .

A.5.9.3 Standard practice for ambulance design is to provideclearance for tire chains on the rear wheels as prescribed by SAE J683. Customers who never use tire chains on the inside duals may elect to forego the interior side clearance to allow for greater aisle width or additional insulation. Customers who never use tire chains at all may elect to forego the tire chain clearance entirely in order to allow for greater aisle width, shorter wheel wells, or additional insulation.




This is a good practice to follow if the ambulance user intends to use tire chains. However, many ambulance users never use tire chains, and among those who do, most use chains only on the outside duals.The problem with the requirement as written is that it unjustifiably restricts the ability of an ambulance user who does not use tire chains to elect a greater aisle width, reduced wheel well height or additional insulation on the wheel wells (because the tire chain clearance consumes space that would otherwise be available for additional aisle width of insulation).The issue is resolved by allowing users to opt out of the SAE J683 clearance allowance if they do not use tire chains or if they only use chains on the outside duals.








5.11.2.6The stepping surface shall have a minimum depth of of 9. 5 in.( 127 240 mm) and a maximum depth of 10 with 11 in. to 12 in. ( 254 280 mm to 305 mm ) preferred .


The depth of the tread on the stairs should allow EMSPs walk on the steps with minimal risk of grip loss. The requirement provided is based on tread depth requirements standards included in Figure 79, Stair Dimensions, of MIL-STD-1472G, Design Criteria Standard Human Engineering (January 2012).









5.11.2.8.2Compliance of the rear step surface shall be validated by third party testing a substantially similar ambulance or bumper and step structure in accordance with Section 9.18 .












Public Input No. 139-NFPA 1917-2013 [ New Section after 5.11.2.8.7 ]

5.11.2.8.8Steps at the entry/exit of doorways shall be at least the width of the doorway opening.


Entry to and exit points from the ambulance is where an accidental misstep by EMS providers and passengers can take place, especially when they are walking backwards and carrying the patient onto or off the ambulance. If such an accident should occur serious injuries can occur. To reduce the risk the practice recommended is that the width of the stairs should not be smaller than the width of the entry/exit opening.


Submitter Full Name: Jennifer MarshallOrganization: NISTStreet Address: City:State: Zip: Submittal Date: Mon Jul 01 16:22:58 EDT 2013






Public Input No. 140-NFPA 1917-2013 [ New Section after 5.11.2.8.7 ]

5.11.2.8.9A safety grating step shall run the width of the rear door opening, be at least 9.5 in. (240 mm) deep and pivot to permit ambulance attendants to move closer when loading and unloading a cot.


One of the major causes of injuries among EMSPs is back strain due to heavy lifting such as when loading a patient onto the ambulance. To reduce potential lifting burden on EMSPs, the step should be designed to pivot and get out of the way to enable the cot to be moved close to the ambulance rear entrance. The requirement is according to Section 3.10.2, Rear Step Bumper, of the Canadian Ambulance Vehicle Code, January 2010.









5.14.5Medium and heavy duty vehicles (>14,400 GVW) should be equipped with a camera at the rear of the vehicle, that can be seen and monitored by the driver when in the reverse position.


For larger ambulances, when in reverse, it is near impossible to see what is immediately behind the vehicle. However when in the reverse position, the ambulance camera automatically activates, and the person is easily visible to the driver.









5.14.4Each side view mirror’s reflective surface outboard edge shall extend at least 1 in. (25.4 mm) beyond the outside of the modular body.


This change is being suggested as the current text is in conflict with FMVSS.













FMVSS rules already cover this requirement.













This change is being suggested as the current text is in conflict with FMVSS.









5.14.4Each side view mirror’s reflective surface outboard edge shall extend at least

1 in. (25.4 mm) beyond the outside of the modular body.

5.14.4 Each side view mirror’s reflective surface outboard edge shall extend at least 1 in. (25.4 mm) beyond the outside of the modular body.


Substantiation: This change is being suggested as the current text is in conflict with FMVSS.









6.1.3 Floor Height. The finished floor (loading) height shall be a maximum of 34 in (864 mm).


It is noted that 34" is the maximum load height most cots are designed to and to go any higher than 34” could potentially create an unsafe lifting situation for those providers who are not physically able to lift that high.









6.1.3* Floor Height. The finished floor (loading) height shall be a maximum of 34 in (864 mm).A.6.1.3 It should also be noted that 4X4 ambulances are note subject to this requirement and most 4X4 ambulances wouldn’t meet the requirement as the 4X4 option raises the chassis.


Substantiation: It is noted that 34" is the maximum load height most cots are designed to and to go any higher than 34” could potentially create an unsafe lifting situation for those providers who are not physically able to lift that high.









6.1 Patient Compartment Configuration.The patient compartment shall provide a minimum of 275 ft 3 (7.7 m 3 ) of space, less volume for cabinets, while complying with 6.1.1 and 6.1.2 .

6.1.1 A minimum of 10 : a minimum of 12 in. (

254 mm) shall be provided from the nearest edge of the cot mattress to the loadingdoor(s). 6.1.2 The compartment shall provide a minimum of 12

305 mm) space, 15 in. (300 mm) of clear aisle walkway on at least one side of the patient cot

381 mm) preferred, shall be provided around a standard size cot and ingress/egress doors .


EMSPs need sufficient space if they may need to walk around the cot to provide patient care. Thus there needs to be a proper amount of clearance without any obstructions to pave a way for EMSPs between the cot and their seats. The human factors practices in MIL-STD 1472G, Design Criteria Standard Human Engineering (January 2012), have provisions for mobile workspace dimensions. Table XLVIII, Mobil Workspace Dimensions, in this standard addresses required and preferred catwalk workspace dimensions.









6.1.3Interior height of patient compartment shall be at least 76 in. (1930 mm).


A study carried out by the National Institute of Standards and Technology showed that taller EMSPs have difficulty keeping upright around the ambulance, forcing them to adopt uncomfortable postures. In some cases, they have injured themselves when they knock their heads against the ceiling. (Reference: “Survey Report for Ambulance Patient Compartment Design,” NIST Technical Note 1772, http://nvlpubs.nist.gov/nistpubs/TechnicalNotes/NIST.TN.1772.pdf)Unnatural statures and postures such as hunching can be detrimental to the health of EMSPs. By taking into account human factors principles, an appropriate height can be required to accommodate most EMSPs. Looking into anthropometric data for other emergency providers in “Fire Apparatus Manufacturer’s Association Firefighter Anthropometric Data White Paper,” 76 inches seems likely to accommodate most EMSPs.


Submitter Full Name: Jennifer MarshallOrganization: NISTStreet Address: City:State: Zip: Submittal Date: Fri Jul 05 11:34:43 EDT 2013







6.1.3* Floor Height. The finished floor (loading) height shall be a maximum of 34 in (864 mm).A.6.1.3 It should also be noted that 4X4 ambulances are note subject to this requirement and most 4X4 ambulances wouldn’t meet the requirement as the 4X4 option raises the chassis.




It is noted that 34" is the maximum load height most cots are designed to and to go any higher than 34” could potentially create an unsafe lifting situation for those providers who are not physically able to lift that high.









6.1.2The compartment shall provide a minimum of 12 in. (300 mm) of clear aisle walkway on at least one side of the patient cot.


The 12 in requirement limits the types of chassis available as well as limiting innovation for development of ambulance interiors


Submitter Full Name: Aarron ReinertOrganization: Lakes Region EMSAffilliation: NEMSMA / Chapter 6 taskgroupStreet Address:City: State: Zip:Submittal Date: Tue Jul 02 19:33:59 EDT 2013


I, Aarron Reinert, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement ofProblem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am Aarron Reinert, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature






Substantiation: This change is being suggested as there is no rationale to the 12 inches and it could possibly be design restrictive. If a minimum width is ever specified, it should be driven by anthropomorphic/ergonomic studies such as those being conducted by NIOSH. There remains no specific reasoning for a minimum space for a clear aisle walkway in the patient compartment. With the increasing demand for ergonomics design criteria in the patient compartment, the current provision may be unnecessarily restrictive. The standard should be silent on this issue. The inside track dimension of the rear tires plus the required tire chain clearance pursuant to SAE J683 creates an absolute limit on the maximum aisle width between the wheel wells. Depending uponthe cot dimensions—especially in the case of a bariatric cot—it may not be possible to provide a 12" clear aisle.











This change is being suggested as there is no rationale to the 12 inches and it could possibly be design restrictive. If a minimum width is ever specified, it should be driven by anthropomorphic/ergonomic studies such as those being conducted by NIOSH. There remains no specific reasoning for a minimum space for a clear aisle walkway in the patient compartment. With the increasing demand for ergonomics design criteria in the patient compartment, the current provision may be unnecessarily restrictive. The standard should be silent on this issue. The inside track dimension of the rear tires plus the required tire chain clearance pursuant to SAE J683 creates an absolute limit on the maximum aisle width between the wheel wells. Depending upon the cot dimensions—especially in the case of a bariatric cot—it may not be possible to provide a 12" clear aisle.









6.1.2The compartment shall provide a minimum of 12 in. (300 mm) of clearaisle walkway on at least one side of the patient cot.




This change is being suggested as there is no rationale to the 12 inches and it could possibly be design restrictive. If a minimum width is ever specified, it should be driven by anthropomorphic/ergonomic studies such as those being conducted by NIOSH. There remains no specific reasoning for a minimum space for a clear aisle walkway in the patient compartment. With the increasing demand for ergonomics design criteria in the patient compartment, the current provision may be unnecessarily restrictive. The standard should be silent on this issue. The inside track dimension of the rear tires plus the required tire chain clearance pursuant to SAE J683 creates an absolute limit on the maximum aisle width between the wheel wells. Depending upon the cot dimensions—especially in the case of a bariatric cot—it may not be possible to provide a 12" clear aisle.









6.1.2The compartment shall provide a minimum of 12 in. (300 mm) of clear aisle

walkway on at least one side of the patient cot.

6.1.2 The compartment shall provide a minimum of 12 in. (300 mm) ofclear aisle walkway on at least one side of the patient cot.


Substantiation: This change is being suggested as there is no rationale to the 12 inches and it could possibly be design restrictive. If a minimum width is ever specified, it should be driven by anthropomorphic/ergonomic studies such as those being conducted by NIOSH. There remains no specific reasoning for a minimum space for a clear aisle walkway in the patient compartment. With the increasing demand for ergonomics design criteria in the patient compartment, the current provision may be unnecessarily restrictive. The standard should be silent on this issue. The inside track dimension of the rear tires plus the required tire chain clearance pursuant to SAE J683 creates an absolute limit on the maximum aisle width between the wheel wells. Depending upon the cot dimensions—especially in the case of a bariatric cot—it may not be possible to provide a 12" clear aisle.









any Sub-Sections] ]

Any Type I, I-AD ambulance body shall withstand a force equal to 2.5 times the curb weight of the vehicle applied to the roof of the vehicle’s body structure, validated by testing a substantially similar ambulance in accordance with Section 9.1.


Makes consistent with definitions in chapter 3









any Sub-Sections] ]

Any Type Im I ambulance -AD ambulance body shall withstand a force equal to 2.5 times the curb weight of the vehicle applied to the roof of the vehicle’s body structure, validated by third party testing a using a substantially similar ambulance in accordance with Section 9.1.













6.3.1.1The modular body shall be tested in accordance with Section 9.1 .


Referenced in 6.3.1…redundant.









6.3.2Any Type II ambulance body shall withstand a force equal to 1.5 times the curb weight of the vehicle applied to the roof of the vehicle’s body structure, validated by testing a substantially similar ambulance in accordance with Section 9.1.


Need a better definition, maybe one in FMVFSS


Submitter Full Name: Aarron ReinertOrganization: Lakes Region EMSAffilliation: NEMSMA / Chapter 6Street Address: City:State: Zip: Submittal Date: Tue Jul 02 19:44:31 EDT 2013







6.3.2Any Type II ambulance body shall withstand a force equal to 1.5 times the curb weight of the vehicle applied to the roof of the vehicle’s body structure, validated by third party testing using a substantially similar ambulance in accordance with Section 9.1 .













6.3.3Any Type III, III-AD ambulance body shall withstand a force equal to 2.5 times the curb weight of the vehicle applied to the roof of thevehicle’s body structure, validated by testing a substantially similar ambulance in accordance with Section 9.1.











6.3.3Any Type III ambulance , III-AD ambulance body shall withstand a force equal to 2.5 times the curb weight of the vehicle applied to the roof of the vehicle’s body structure, validated by third party testing using asubstantially similar ambulance in accordance with Section 9.1 .













6.3.4The downward vertical movement at any point on the roof application plate shall not exceed 5.12 in. (130 mm).


Have a concern, need more information, unsure of how to change









6.4.1Any Type I, I-AD ambulance body shall withstand a force equal to 2.5 times the curb weight of the vehicle applied to either the driver orpassenger side of the vehicle’s body structure, validated by testing asubstantially similar ambulance in accordance with Section 9.1.











6.4.1Any Type I ambulance , I-AD ambulance body shall withstand a force equal to 2.5 times the curb weight of the vehicle applied to either the driver or passenger side of the vehicle’s body structure, validated by third party testing using a substantially similar ambulance in accordance with Section 9.1 .













6.4.3 Each rear door of the vehicle shall be capable of opening and closing during the full application of the force and after release of force


means of egress should be validated during testing side load structural integrity.









6.4.4 The Type I, I-AD and III, III-AD modular body will be structurally tested using SAE 2917 Frontal Impact Pulse and SAE 2956 Lateral Impact Pulse in addition to the above referenced tests


Static load testing of the modular body does not reflect the dynamics involved in actual accidents. The two SAE impact pulses are specific to ambulances for frontal and lateral impacts.









6.4.2Any Type III, III-AD ambulance body shall withstand a force equal to 2.5 times the curb weight of the vehicle applied to either the driver or passenger side of the vehicle’s body structure, validated by testing asubstantially similar ambulance in accordance with Section 9.1.











6.4.2Any Type III ambulance , II-AD ambulance body shall withstand a force equal to 2.5 times the curb weight of the vehicle applied to either the driver or passenger side of the vehicle’s body structure, validated by third party testing using a substantially similar ambulance in accordance with Section 9.1 .













6.5.1.1There shall be no water leakage into the cab, any exterior compartment, or the patient compartment or through any door seal, light seal, or cab-to-module seal .


Clarification that there is no area where water should be allowed to leak in









6.5.1.2Compliance of the body sealing out water shall be validated by testing each finished ambulance the manufacturer for each unitproduced by testing in accordance with Section 9.10 .




I propose that third party testing be required for the aspects of the ambulance in which testing each individual vehicle to the particular standard or specifically required test would be impractical. The water spray testing is not one of these items. This test should be performed by the manufacturer for each unit produced.









6.5.2 Sealing Out Exhaust Gas .6.5.2.1

The body shall be sealed and vented so that the interior carbon monoxide level does not exceed 13 ppm of carbon monoxide (CO).

6.5.2.2The patient compartment shall include a listed CO detector in accordance with ANSI/UL 2034, Standard for Safety, Single and Multiple Station Carbon Monoxide Alarms.


Need more information on the correct levels to include in the specification









6.6.1Wheel housings of modular bodies shall include metal or plastic splash shields between the body wheel housing and the wheels extending over the top of the tires to the bottom of the body side skirting.


there may be other materials other than metal and plastic that would be acceptabe









6.7.1A bulkhead partition shall be provided between the cab and the patientcompartment. The bulkhead may contain either a window or walk thru doorway.




Clarification. The doorway provision was not clearly explained.









6.7.2.1 If additional cab seats are provided, the bulkhead partition shall be located directly behind the last cab seat and when in the rearmost position and the seat back reclined a minimum of 15 degrees


This addition clarifies that additional seating options such as crew cabs are permitted









6.7.2The partition(s) shall be located directly behind the driver’s seat and the cab passenger seat when in the rearmost position position and the seat back reclined a minimum of 15 degrees .


All cab seats recline. If we do not specify a minimum recline angle the bulkhead could be positioned directly behind the seats with the seat back in a non reclined vertical position.









6.7.8 If so equipped, a walk through opening with a door shall be provided with a clear opening space of at least 17 inches wide by 43 inches tall.




Clarification, the requirement for a partition door was not defined.









6.8 * Access Handrails or Handholds.6.8.1

Interior or exterior access handrails or handholds shall be provided at each entrance to a driving or crew compartment and at each position where steps or ladders for climbing are located.

6.8.2Exterior access handrails shall be constructed of or covered with a slip-resistant (e.g., cross-hatched stainless steel, rubberized), noncorrosive material.

6.8.3Exterior access handrails shall be between 1 in. and 1 5⁄8 in. (25 mm and 42 mm) in diameter and have a minimum clearance between the handrails and any surface of at least 2 in. (50 mm).

6.8.4All exterior access handrails shall be designed and mounted to reduce the possibility of hand slippage and to avoid snagging of equipment or clothing.

6.8.5Access handrails supplied by the chassis manufacturer on a commercial chassis shall be permitted to be used to meet the requirements of this section.

6.8.6 Handrail Testing.6.8.6.1

Handrails shall withstand a force of 300 lb (136 kg) applied in any direction without detaching, loosening, or permanently deforming.

6.8.6.2Compliance of the handrail shall be validated by testing a substantially similar ambulance or body structure in accordance with Section 9.8.


A star (*) is added to the section title of 6.8. This is because a new annex to 6.8 is recommended.


Submitter Full Name: Jennifer MarshallOrganization: NISTStreet Address: City:State: Zip: Submittal Date: Tue Jul 02 09:30:59 EDT 2013





6.8 Access Handrails or Handholds.6.8.1

Interior or exterior access handrails or handholds shall be provided at each entrance to a driving or crew compartment and at each position where steps or ladders for climbing are located.

6.8.2Exterior access handrails shall be constructed of or covered with a slip-resistant (e.g., cross-hatched stainless steel, rubberized), noncorrosive material.

6.8.3Exterior access handrails shall be between 1 in. and 1 5⁄8 in. (25 mm and 42 mm) in diameter and have a minimum clearance between the handrails and any surface of at least 2 in. (50 mm).


6.8.5Access handrails supplied by the chassis manufacturer on a commercial chassis shall be permitted to be used to meet the requirements of this section.



6.8.6.2Compliance of the handrail shall be validated by testing a substantially similar ambulance or body structure in accordance with Section 9.8.


The word access is not needed and the standard should apply to all handrails and handholds







6.8 Access Handrails or Handholds.6.8.1

Interior Handrails or exterior access handrails or handholds shall be provided at each entrance to a driving or crew compartment and at each position where steps or ladders for climbing are located and on the ceiling of the patient compartment .

6.8.2Exterior access handrails shall be constructed of or covered with a

slip-resistant (e.g., cross-hatched stainless steel, rubberized), noncorrosive material.

6.8.3

Exterior access handrails shall be between 1 in. and 1 5 ⁄ 8 in. (25 mm and 42 mm) in diameter and have a minimum clearance between the handrails and any surface of at least 2 in. (50 mm).

6.8.4All exterior access handrails shall be designed and mounted to

reduce the possibility of hand slippage and to avoid snagging of equipment or clothing.

6.8.5Access handrails supplied by the chassis manufacturer on a

commercial chassis shall be permitted to be used to meet the requirements of this section.



6.8.6.2Compliance of the handrail shall be validated by testing a

substantially similar ambulance or body structure in accordance with Section 9.8 .




The specification for interior or exterior is superfluous; there is no way they cannot be interior or exterior. Grab bars on the ceiling of the patient compartment are generally accepted as a standard in the industry.





6. 8 Access Handrails or Handholds.6. 8.1 Interior or exterior access handrails or H andrails or handholds shall be provided at each entrance to a driving or crew compartment and at each position where steps or ladders for climbing are located and on the ceiling of the patient care compartment .


The specification for interior or exterior is superfluous; there is no way they cannot be interior or exterior. Grab bars on the ceiling of the patient compartment are generally accepted as a standard in the industry.









6.8.1Interior or exterior access handrails or handholds shall be provided at each

entrance to a driving or crew compartment and at each position where steps or ladders for climbing are located.

6.8 Access Handrails or Handholds.6.8.1 Interior or exterior access handrails or handholds shall be provided

at each entrance to a driving or crew compartment and at each position where steps or ladders for climbing are located and on the ceiling of the patientcompartment .


Substantiation: The specification for interior or exterior is superfluous; there is no way they cannot be interior or exterior. Grab bars on the ceiling of the patient compartment are generally accepted as a standard in the industry.









6.8.2Exterior and interior access handrails shall be constructed of or covered with a slip-resistant (e.g., cross-hatched stainless steel,rubberized), noncorrosive material.


Slippery surfaces and objects in the patient compartment can cause avoidable injuries to the EMSP. The patient compartment exterior and interior both need to be designed in a way such that potential slips, falls, and trips can be avoided. Handrails and handholds need to be slip-resistant as they are frequently accessed by EMSPs. Handrails and handholds are especially important to be slip-resistant since their primary function is to provide balance support for EMSPs.









6.8.2Exterior access handrails shall be constructed of or covered with a slip-resistant (e.g., cross-hatched stainless steel, rubberized), , nonporous, noncorrosive material.


The key requirements are: slip-resistant, nonporous, and noncorrosive. Examples of compliant options belong in the annex.









6.8.2Exterior access handrails shall be constructed of or covered with a slip-resistant (e.g., , nonporous, noncorrosive material.A.6.8.2 Some examples could be cross-hatched stainless

steel , or rubberized), noncorrosive material

.




The key requirements are: slip-resistant, nonporous, and noncorrosive. Examples of compliant options belong in the annex.








6.8.2Exterior access handrails shall be constructed of or covered with a slip-

resistant (e.g., cross-hatched stainless steel, rubberized), noncorrosivematerial.

6.8.2 * Exterior access handrails shall be constructed of or covered with a slip-resistant (e.g., cross-hatched stainless steel, rubberized) , nonporous ,noncorrosive material.

A.6.8.2 Some examples could be cross-hatched stainless steel or rubberized.


Substantiation: The key requirements are: slip-resistant, nonporous, and noncorrosive. Examples of compliant options belong in the annex.











Move to annex


Submitter Full Name: Aarron ReinertOrganization: Lakes Region EMSAffilliation: NEMSMA / Chapter 6 taskgroupStreet Address: City:State: Zip: Submittal Date: Tue Jul 02 20:31:21 EDT 2013









These requirements are desired features of both interior and exterior handrails. This is a safety related matter.













These requirements are desired features of both interior and exterior handrails.









6.8.4All exterior access handrails shall be designed and mounted to reduce the

possibility of hand slippage and to avoid snagging of equipment or clothing.

6.8.4 All exterior access handrails shall be designed and mounted to reduce the possibility of hand slippage and to avoid snagging of equipment or clothing.


Substantiation: These requirements are desired features of both interior and exterior handrails.









6.8.5Access handrails Handrails supplied by the chassis manufacturer on a commercial chassis shall be permitted to be used to meet the requirements deemed sufficant for the purpose of this section.


Changes clarify that intent of this item









6.8.5Access handrails Handrails supplied by the chassis manufacturer on a commercial chassis shall be permitted to be used to meet the requirements deemed sufficient for the purposes of this section.


These changes clean up this section and delete non value added words. There is no need for requiring cross hatched stainless steel and or rubberized handrails, particularly inside the patient compartment. As revised, the provision provides an adequate base level of safety for an ambulance operation.









6.8.5Access handrails Handrails supplied by the chassis manufacturer on a commercial chassis shall be permitted to be used to meet the requirements deemed sufficient for purposes of this section.




These changes clean up this section and delete non value added words. There is no need for requiring cross hatched stainless steel and or rubberized handrails, particularly inside the patient compartment. As revised, the provision provides an adequate base level of safety for an ambulance operation.









6.8.5Access handrails supplied by the chassis manufacturer on a commercial

chassis shall be permitted to be used to meet the requirements of thissection.

6.8.5 Access handrails supplied by the chassis manufacturer on acommercial chassis shall be deemed sufficient for purposes permitted to be used to meet the requirements of this section.


Substantiation: These changes clean up this section and delete non value added words. There is no need for requiring cross hatched stainless steel and or rubberized handrails, particularly inside the patient compartment. As revised, the provision provides an adequate base level of safety for an ambulance operation.









6.8.6Handrails, where provided, shall be placed between 34 in. (864 mm) and 37 in. (940 mm), above the standing surface and shall include an intermediate guard.


EMS providers need protection from the risk of falling, when climbing up or down the stairs to enter or exit the vehicle. Providing appropriate firm handholds on either side of the stair at these heights will provide a surface with which the EMSPs can steady themselves. The requirement provided is obtained from Figure 80, Stair-ladder Dimensions, of MIL-STD-1472G, Design Criteria Standards for human Engineering (January 2012).









6.8.6.2Compliance of the handrail shall be validated by third party testingusing a substantially similar ambulance or body structure in accordance with Section 9.8 .













6.9 Patient Compartment Entry Doors.6.9.1

Door handles shall be designed and installed to protect against accidental or inadvertent opening.

6.9.2Entry doors and door openings shall be designed to minimize

inadvertent snagging of apparel.6.9.3

Door latches, hinges, and hardware furnished by OEMs and final stage ambulance manufacturers (FSAMs) shall meet the performance requirements of FMVSS 206.

6.9.4When doors are open, the hinges, latches, and door-checks shall not

protrude into the access area.6.9.5

Doors shall have hardware or devices to prevent inadvertentclosing.

6.9.6One externally operated lock for each door opening shall be

provided.6.9.7 *

An internal lock on each patient compartment primary entry door shall be provided.

6.9.8If a key lock is provided, all patient compartment entry door locks

shall be identically keyed.6.9.9

Doors shall be equipped with not less than 250 in. 2 (161,300 mm 2 ) of safety glass area per door.

6.9.10Doors shall be designed to prevent leakage of exhaust fumes,

dust, water, and air into the patient compartment.6.9.11Doors shall, in addition to meeting applicable FMVSS standards,

withstand the loads on the latches and hinges listed in Table 6.9.11 when tested in accordance with Section 9.2 .

Table 6.9.11 Loads Withstood on Ambulance Door Latches and Hinges



Side Door

Transverse Load Longitudinal Load

Latch or Hinge lbf N lbf N

Fully latched position 2,500 11,120 2,500 11,120

Secondarylatched position

1,500 6,672 1,500 6,672

Hinge 2,500 11,120 2,500 11,120

6.9.11.1Compliance of the door shall be validated by testing on a patient

compartment sample of a substantially similar design.6.9.11.2

During the tests, the door(s) or its retention components shall not do either of the following:

(1) Open at any time during the test procedure

(2) Fail at the latch, striker(s), hinge, or their points of attachment to the door or the body framework


Change section title to include all doors.









6.9.1Door handles shall should be designed and installed to protect against accidental or inadvertent opening.


Clarifies the item









6.9.2Entry doors and door openings shall should be designed to minimize inadvertent snagging of apparel.


Clarifies this item


Submitter Full Name: Aarron ReinertOrganization: Lakes Region EMSAffilliation: NEMSMA / Chapter 6Street Address: City:State: Zip: Submittal Date: Tue Jul 02 20:38:26 EDT 2013







6.9.4When doors are open, the hinges and latches , latches, and door-checks shall not protrude into the access area.




Clarification, door checks, shocks, or brackets do protrude into the doorway clear space.









6.9.5Doors shall have hardware or devices to prevent inadvertent closing. be equiped with a hold open device


clarifies the items









6.9.8If a key lock is provided, all patient compartment entry door locks shall be identically keyed.


The additional words are not needed









6.9.9Doors shall Patient loading doors shall be equipped with not less than 250 in. 2 (161,300 mm 2 ) of safety glass area per door.


The patient needs to be unloaded as soon as the ambulance reaches the hospital. Therefore, in the event that there are obstacles outside the loading doors, then the ambulance occupants should be able to view them from inside and avoid packing next to them. Adequate safety glass also enables the condition of the traffic so as to take appropriate action with the car or the patient. The other doors on the ambulance are the driver compartment doors, which are small in size, and are out of scope.









6.9.12Entry doors shall be distinguishable from exterior storage doors


Emergency medical service providers (EMSPs) need quick access to both exterior storage doors and patient compartment entry doors. This is possible if the purpose of these doors can easily be visually identified before EMSPs attempt to open them.









6.9.13Doors shall require 44 N to 133 N (10 lb-force to 30 lb-force) of operating force to open.


Patient compartment doors shall allow EMSPs to open them without delay and, at the same time, ensure that doors not inadvertently opened by casual contact with the handle. The requirement is based on the force requirements standards included in Section 5.7.6.2, Emergency Doors and Exits, of MIL-STD-1472G, Design Criteria Standard Human Engineering (January 2012).









6.9.14Door handles shall accommodate the full range of hand sizes, including hand length between 6.5 in. and 8.3 in. (165 mm and 211 mm), breadth between 2.7 in. and 3.9 in. (69 mm and 98 mm), circumference between 6.6 in. and 9.0 in. (168 mm and 229 mm), and palm length between 3.5 in. and 4.6 in. (90 mm and 117 mm).


The size of the door handles should be designed to allow EMSPs to have a firm grip of the door handle in order to open the door quickly and easily. The requirement is obtained from Table B-XIII, Hand and Foot Dimensions – General Forces, of MIL-STD-1472G, Design Criteria Standard Human Engineering (January 2012). This standard determines the range of human hand lengths and palm size for which the handles should be designed.









6.9.15Each egress door shall have a failsafe method of opening and no method of locking should preclude egress.


EMSPs need to be able to quickly exit the patient compartment in the event of an emergency or at the hospital, regardless of whether the door is locked or not. If the doors cannot be opened as quickly as desired, delays can occur for EMSPs to exit or for unloading of the patient. Such delays can lead to deterioration of the patient’s condition or increased injury risk for EMS providers. This requirement should ensure there is an alternative guaranteed method of exiting the ambulance.









6.9.16Egress out of a secondary door (other than the main loading/unloading door) with a patient on a patient transport device shall not require disassembly of any patientcompartment structures.


A patient needs to be unloaded from the ambulance as soon as the ambulance reaches the hospital. In case the primary entrance cannot be used due to a mechanical problem, doors being blocked at the medical facility, or other reasons then the secondary exit has to be used. The requirement is that this secondary exit door should be as wide as the cot size for quick unloading of the patient and the compartment configured such that nothing prevents maneuvering the patient out the door.









6.9.11

Doors shall, in addition to meeting applicable FMVSS standards, withstand the loads on the latches and hinges listed in Table 6.9.11 when tested in accordance with Section 9.2 .

Table 6.9.11 Loads Withstood on Ambulance Door Latches and HingesSide Door Rear Door Transverse Load Longitudinal Load Transverse Load Longitudinal Load Latch or Hinge lbf N lbf N lbf N lbf N Fully latchedposition 2,500 11,120 2,500 11,120 2,500 11,120 2,500 11,120 Secondary latched position 1,500 6,672 1,500 6,672 1,500 6,672 1,500 6,672 Hinge 2,500 11,120 2,500 11,120 2,500 116.9.11.1

Compliance of the door shall be validated by testing on a patient compartment sample of a substantially similar design.

6.9.11.2During the tests, the door(s) or its retention components shall not do either of the following:




Currently, FMVSS 206 covers these requirements. There is no need to specify anything in addition to or different from FMVSS 206 which could create conflict and confusion.








6.9.11

Doors shall, in addition to meeting applicable FMVSS standards, withstand the loads on the latches and hinges listed in Table 6.9.11 when tested in accordance with Section 9.2 .

Table 6.9.11 Loads Withstood on Ambulance Door Latches and HingesSide Door Rear Door Transverse Load Longitudinal Load Transverse Load Longitudinal Load Latch or Hinge lbf N lbf N lbf N lbf N Fully latchedposition 2,500 11,120 2,500 11,120 2,500 11,120 2,500 11,120 Secondary latched position 1,500 6,672 1,500 6,672 1,500 6,672 1,500 6,672 Hinge 2,500 11,120 2,500 11,120 2,500 116.9.11.1

Compliance of the door shall be validated by testing on a patient compartment sample of a substantially similar design.

6.9.11.2During the tests, the door(s) or its retention components shall not do either of the following:






Currently, FMVSS 206 covers these requirements. There is no need to specify anything in addition to or different from FMVSS 206 which could create conflict and confusion.







6.9.11Doors shall, in addition to meeting applicable FMVSS standards, withstand

the loads on the latches and hinges listed in Table 6.9.11 when tested in accordance with Section 9.2 .


Side Door Rear Door

TransverseLoad

LongitudinalLoad

TransverseLoad

LongitudLoad

Latch or Hinge lbf N lbf N lbf N lbf

Fullylatched position

2,500 11,120 2,500 11,120 2,500 11,120 2,500 11

Secondarylatched position

1,500 6,672 1,500 6,672 1,500 6,672 1,500 6,6

Hinge 2,500 11,120 2,500 11,120 2,500 11,120 2,500 11

6.9.11.1Compliance of the door shall be validated by testing on a patient

compartment sample of a substantially similar design.6.9.11.2During the tests, the door(s) or its retention components shall not do either

of the following:



6.9.11 Doors shall, in addition to meeting applicable FMVSS standards, withstand the loads on the latches and hinges listed in Table6.9.11 when tested in accordance with Section 9.2 .




Side Door Rear

Transverse Load Longitudinal Load Trans

Latch or Hinge lbf N lbf N lbf

Fully latched position

2,500 11,120 2,500 11,120 2,500

Secondary latched position

1,500 6,672 1,500 6,672 1,500

Hinge 2,500 11,120 2,500 11,120 2,500

6.9.11.1 Compliance of the door shall be validated by testing on a patient compartment sample of a substantially similar design.

6.9.11.2 During the tests, the door(s) or its retention components shall not do either of the following:

(1) Open at any time during the test procedure(2) Fail at the latch, striker(s), hinge, or their points of attachment to

the door or the body framework


Substantiation: Currently, FMVSS 206 covers these requirements. There is no need to specify anything in addition to or different from FMVSS 206 which could create conflict and confusion.






6.9.11.1Compliance of the door shall be validated by third party testingon using a patient compartment sample of a substantially similardesign.













6.10 Means of Escape Egress .6.10.1

Any interior area to be occupied by personnel The patient compartment area shall have a minimum of two means of escape.

6.10.2 Each means of escape opening shall be a minimum of 24 in. × 24 in. (610 mm × 610 mm).

egress sized and positioned to allow for the removal of a patient on abackboard.


The existing provision is a standard similar to that found in busing operations. In an ambulance environment, it is imperative that a patient may be removed while on a backboard. The task group suggests making a clear statement about what is needed, and allows the manufacturer and purchaser determine how to accomplish that requirement.









6.10 Means of Escape Egress .6.10.1

Any interior area to be occupied by personnelThe patient compartment area shall have a minimum of two means of escape.


egress sized and positioned to allow for the removal of a patient on a backboard.




The existing provision is a standard similar to that found in busing operations. In an ambulance environment, it is imperative that a patient may be removed while on a backboard. The task group suggests making a clear statement about what is needed, and allows the manufacturer and purchaser determine how to accomplish that requirement.






6.10 Means of Escape.6.10.1Any interior area to be occupied by personnel shall have a minimum of two

means of escape.6.10.2Each means of escape opening shall be a minimum of 24 in. × 24 in. (610

mm × 610 mm).

6.10 Means of Egress Escape .6.10.1 The patient compartment area shall have a minimum of two

means of egress sized and positioned to allow for the removal of a patient on a backboard. Any interior area to be occupied by personnel shall have a minimum of two means of escape.



Substantiation: The existing provision is a standard similar to that found in busing operations. In an ambulance environment, it is imperative that a patient may be removed while on a backboard. The task group suggests making a clear statement about what is needed, and allows the manufacturer and purchaser determine how to accomplish that requirement.









6.11.4The contractor shall deliver with the ambulance a certification that all materials used for exterior surfaces designated as stepping, standing, and walking areas meet the requirements of Section 6.11 .


This section duplicates the requirements of section 4.17. To the extent the standard requires a feature (such as slip resistance) and stipulates that all exceptions must be documented, it logically follows that all requirements other than those documented as an exception are compliant.









6.11.4The contractor shall deliver with the ambulance a certification that all materials used for exterior surfaces designated as stepping, standing, and walking areas meet the requirements of Section 6.11 .




This section duplicates the requirements of section 4.17. To the extent the standard requires a feature (such as slip resistance) and stipulates that all exceptions must be documented, it logically follows that all requirements other than those documented as an exception are compliant.









6.11.4The contractor shall deliver with the ambulance a certification that all

materials used for exterior surfaces designated as stepping, standing, and walking areas meet the requirements of Section 6.11 .

6.11.4 The contractor shall deliver with the ambulance a certification that all materials used for exterior surfaces designated as stepping, standing, and walking areas meet the requirements of Section 6.11 .


Substantiation: This section duplicates the requirements of section 4.17. To the extent the standard requires a feature (such as slip resistance) and stipulates that all exceptions must be documented, it logically follows that all requirements other than those documented as an exception are compliant.









6.12.1Doors shall provide secure closure properties All exterior compartment doors shall have latches with locks that hold the door in a closed position .


Clarifies the item









6.12.4All primary exterior compartment doors shall have latches with locks.


Duplicates 6.12.1 after edits to 6.12.1









6.12.5All The interior of all exterior compartments greater than 4 ft3 (0.11 m3) shall be automatically illuminated when opened and shall meet the requirements of 7.11.7.1.


Clarifies the item









6.12.6Any absorbent material, such as carpeting, fabric, or inside/outside plastic-type carpeting, that resists cleaning and decontamination shall not be used All surfaces shall be non-absorbent and shall be easy to clean and decontaminate .




The grammar needs to be improved to positively state the desired path rather than negatively stating the undesired path.









6.14 Fire safety of interior materials6.14.1 FMVSS 302 is a US federal standard that specifies flammability requirements for materials used in the occupant compartments of motor vehicles. Its purpose is to reduce deaths and injuries to motor vehicle occupants caused by vehicle fires,especially those originating in the interior of the vehicle from sources such asmatches or cigarettes.6.14.2 Any portion of a single or composite material which is within 0.5 inches (13 mm) of the occupant compartment air space is required to meet one of the following requirements:(a) the material shall not burn, nor transmit a flame front across its surface, at a rate of more than 4 inches (102 mm) per minute, or(b) If the material stops burning before it has burned for 60 seconds from the start of timing, and has not burned more than 2 inches (51 mm) from the point where the timing was started, it shall be considered to meet the burn-rate requirement of 6.14.2(a).6.14.3* NFPA 556, Guide on Methods for Evaluating Fire Hazard to Occupants of Passenger Road Vehicles, has demonstrated that FMVSS 302 does not ensure passenger road vehicle fire safety.A.6.14.3 FMVSS 302 is a mandatory test for the flammability of some of the materials contained within the passenger compartment of passenger road vehicles in the US. NFPA 556, Guide on Methods for Evaluating Fire Hazard to Occupants of Passenger Road Vehicles, discusses the usefulness (or lack of it) of compliance with FMVSS 302 to ensure fire safety of occupants of passenger road vehicles. Guide NFPA 556 also provides some guidance into improved flammability requirements formaterials and products in various areas of passenger road vehicles.Also: add NFPA 556 into chapter 2 and the annex on referenced NFPA standards.


There is a need for a generic section explaining that some materials need to be covered by the flammability test in FMVSS 302 and additional information showing that it does not provide adequate fire safety. This is particularly important when considering the fact that ambulances transport individuals who cannot escape easily from a fire.


Submitter Full Name: Marcelo HirschlerOrganization: GBH InternationalStreet Address: City:State: Zip: Submittal Date: Fri Jul 05 14:49:23 EDT 2013





Patient Compartment FloorThe patient compartment floor at the rear loading doors shall be no more than 33 inches from the road surface. On vehicles with air ride systems the measurement will be taken in the kneeling (dumped) position.


if the floor is more than 33 inches from the road surface the stretcher will not go in because the floor is to high for the guide wheels to clear the doorframe.


Submitter Full Name: Richard KramerOrganization: Gloucester Vol Fire RescueStreet Address:City: State: Zip:Submittal Date: Mon Jul 01 15:00:11 EDT 2013


I, Richard Kramer, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement ofProblem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am Richard Kramer, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature




6.13.2With the exception of cot retention hardware, the floor shall be unencumbered free of obsructions in the door(s) access and work area.


clarifies the item


Submitter Full Name: Aarron ReinertOrganization: Lakes Region EMSAffilliation: NEMSMA / Chapter 6 task itemStreet Address: City: State:Zip: Submittal Date: Tue Jul 02 20:52:14 EDT 2013


I, Aarron Reinert, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.





6.13.2With the exception of cot, equipment retention hardware, and equipment mounted in its hardware, the floor shall be unencumbered in the door(s) access and work area.


Substantiation: This addition is to allow for the inclusion of retention hardware for specialty equipment, such as balloon pumps, and the presence of such equipment on the floor when mounted. In addition, tracking materials may be built into the flooring for securement of NICU equipment.









6.13.2With the exception of the cot , equipment retention hardware, the and equipment mounted in its hardware, the floor shall be unencumbered in the door(s) access and work area.


This addition is to allow for the inclusion of retention hardware for specialty equipment, such as balloon pumps, and the presence of such equipment on the floor when mounted. In addition, tracking materials may be built into the flooring for securement of NICU equipment.









6.13.2With the exception of cot retention , equipment retention hardware, and equipment mounted in its hardware, the floor shall be unencumbered in the door(s) access and work area.




This addition is to allow for the inclusion of retention hardware for specialty equipment, such as balloon pumps, and the presence of such equipment on the floor when mounted. In addition, tracking materials may be built into the flooring for securement of NICU equipment.









6.13.2With the exception of cot retention hardware, the floor shall be

unencumbered in the door(s) access and work area.

6.13.2 With the exception of cot, equipment retention hardware, and equipment mounted in its hardware, the floor shall be unencumbered in the door(s) access and work area.


Substantiation: This addition is to allow for the inclusion of retention hardware for specialty equipment, such as balloon pumps, and the presence of such equipment on the floor when mounted. In addition, tracking materials may be built into the flooring for securement of NICU equipment.









6.13.6If the ambulance has a modular body, the subfloor shall be designed to prevent water penetration and shall include a heat shield above any exhaust component that is within 12" of the ambulance floor .




Exhaust components on medium duty chassis are usually more than 12" from the module floor, obviating the need for a heat shield. Radiant heat transfer diminishes with the square of the distance between the objects. Once the separation distance reaches 12", the rate of radiant heat transfer no longer warrants a heat shield. The requirement for a heat shield regardless of the separation of the exhaust components creates an unjustifiable additional expense.









6.13.7.1If the subfloor is constructed of plywood, the plywood shall have an

American Plywood Association (APA) floor rating of 16 in. (406 mm) on center or better.

6.13.7.1 If the subfloor is constructed of plywood, the plywood shall have an American Plywood Association (APA) floor rating of 16 in. (406 mm) on center or better


Substantiation: AMD testing standards, specifically AMD 20, Floor distributed load test provides the necessary specifications for flooring material.








Public Input No. 337-NFPA 1917-2013 [ Sections 6.13.7.1, 6.13.7.2 ]

Sections 6.13.7.1, 6.13.7.26.13.7.1

If the subfloor is constructed of plywood, the plywood shall have an American Plywood Association (APA) floor rating of 16 in. (406 mm) on center or better.

6.13.7.2If the subfloor is constructed of other than plywood, it shall be tested using a 3 in. (76 mm) disk and have a maximum of 0.125 in. (3 mm) deflection at 200 lb (91 kg) force and a minimum ultimate load of 400 lb (181 kg) for a 16 in. (406 mm) on center load.

6.13.7.2.1The maximum floor structure spacing shall be used for testing.

6.13.7.2.2Compliance of the floor structural integrity shall be validated by testing the midpoint of the longest unsupported section of a substantially similar ambulance or floor structure in accordance with the concentrated static load test procedure in ASTM E 661, Standard Test Method for Performance of Wood and Wood-Based Floor and Roof Sheathing Under Concentrated Static and Impact Loads .

6.13.7.2.2.1If panel joints occur at the maximum span location, they should be present in the test sample as a worst-case scenario.


AMD testing standards, specifically AMD 20, Floor distributed load test provides the necessary specifications for flooring material.








Sections 6.13.7.1, 6.13.7.26.13.7.

1 If the subfloor is constructed of plywood, the plywood shall have an American Plywood Association (APA) floor rating of 16 in. (406 mm)on center or better.

6.13.7.2 If the subfloor is constructed of other than plywood, it shall be tested using a 3 in.(76 mm) disk and have a maximum of 0.125 in. (3 mm) deflection at 200 lb (91 kg) force and a minimum ultimate load of 400 lb (181 kg) for a 16 in. (406 mm) on center load.6.13.7.2.1

The maximum floor structure spacing shall be used for testing.

6.13.7.2.2

Compliance of the floor structural integrity shall be validated by testing the midpoint of the longest unsupported section of a substantially similar ambulance or floor structure in accordance with the concentrated static load test procedure in ASTM E 661, StandardTest Method for Performance of Wood and Wood-Based Floor and Roof Sheathing Under Concentrated Static and Impact Loads .

6.13.7.2.2.1If panel joints occur at the maximum span location, they

should be present in the test sample as a worst-case scenario.




AMD testing standards, specifically AMD 20, Floor distributed load test provides the necessary specifications for flooring material.





6.13.7.2If the subfloor is constructed of other than plywood, it shall be tested using a

3 in. (76 mm) disk and have a maximum of 0.125 in. (3 mm) deflection at 200 lb (91 kg) force and a minimum ultimate load of 400 lb (181 kg) for a 16 in. (406 mm) on center load.

6.13.7.2.1The maximum floor structure spacing shall be used for testing.6.13.7.2.2Compliance of the floor structural integrity shall be validated by testing the

midpoint of the longest unsupported section of a substantially similar ambulance or floor structure in accordance with the concentrated static load test procedure in ASTM E 661, Standard Test Method for Performance of Wood and Wood-Based Floor and Roof Sheathing Under Concentrated Static and Impact Loads .

6.13.7.2.2.1If panel joints occur at the maximum span location, they should be

present in the test sample as a worst-case scenario.

6.13.7.2 If the subfloor is constructed of other than plywood, it shall be tested using a 3 in. (76 mm) disk and have a maximum of 0.125 in. (3 mm) deflection at 200 lb (91 kg) force and a minimum ultimate load of 400 lb (181 kg) for a 16 in. (406 mm) on center load.


Substantiation: AMD testing standards, specifically AMD 20, Floor distributed load test provides the necessary specifications for flooring material.








6.14 Floor Covering.6.14.1

Floor covering shall be nonpermeable, seamless, and easily cleaned.6.14.2*

The floor covering shall cover the entire length and width of the compartment’s exposed floor.

6.14.3Joints where the floor covering meets the sidewalls shall be sealed and bordered with corrosion-resistant cove molding, or the floor covering shall extend at least 3 in. (76 mm) up the sidewalls.

6.14.4 All floor covering materials shall comply with a critical radiant flux of not less than Class II (0.22 Watts/cm2) when tested inaccordance with NFPA 253 (Standard Method of Test for Critical Radiant Flux of Floor Covering Systems Using a Radiant Heat Energy Source).

Also: add NFPA 253 to Chapter 2 on referenced standards.


The use of fire test requirements for interior floor finish is typical of most environments. A Class II requirement is a reasonably mild requirement that most interior floor finish that meets the other requirements should meet.









6.14.1Floor covering shall be nonpermeable, seamless, and easilycleaned.


easily is not measurable









6.14.2 *The floor covering shall cover the entire length and width of the compartment’s exposed floor.


The current Annex A6.14.2 is not correctly linked to this requirement.









6.14.4Floor covering shall minimize the risk of slipping (e.g., multi-directional aggressive gripping surface) and shall provide a static friction coefficient equal to or greater than 0.8 under dry conditions.


Slippery surfaces in the patient compartment can cause serious injuries to the EMSP. The patient compartment interior needs to be designed in a way such that potential slips, falls and trips can be avoided. Floors are the primary areas where slips can occur. Without the appropriate floor covering, EMSPs can potentially slip and injure themselves. However, this can be avoided by requiring all patient compartment floor coverings to minimize the risk of slipping. This can also be done by requiring that patient compartment floors should have an appropriate amount of friction. In the “Canadian Ambulance Vehicle Code January 2010,” requirement 3.6.4, a static friction coefficient for ambulance vehicle floor coverings is mentioned which is intended to minimize slips and falls.









6.15 Insulation.6.15.1

Where the patient compartment is insulated, it shall be insulated with a nonsettling type, verminproof, mildewproof, nontoxic, and nonhygroscopic material that meets the requirements of FMVSS 302 .

6.15.2

Insulation shall be separated from the patient compartment by interior surfaces complying with 6.17.6.15.3

If fiberglass insulation is used, it shall be protected from exposure towater.

6.15.4

If foam plastic insulation is used it shall be separated from the interior of the patient compartment by a thermal barrier meeting the requirements of NFPA 275 (Standard Method of Fire Tests for the Evaluation of Thermal Barriers).6.15.5

Insulation shall comply with a flame spread index not exceeding 200 when tested in accordance with ASTM E84 or UL 723. The smokedevelopment shall not be limited.

Also: add the following standards into chapter 2:

NFPA 275 (Standard Method of Fire Tests for the Evaluation of Thermal Barriers)

ASTM E84 (Standard Test Method for Surface BurningCharacteristics of Building Materials; 2013a)UL 723 (Standard for Test for Surface Burning Characteristics of Building Materials)


Insulation must be separated from the interior of the patient compartment. Any material that is not exposed to the atmosphere of the passenger (in this case, patient) compartment is not required to meet FMVSS 302. FMVSS 302 does not assess fire resistance. Foam plastic insulation must never be used exposed and must be covered by a thermal barrier. The fire test requirement proposed for insulation (ASTM E84 Class C) is the mildest possible requirement.





6.16.7 Each patient compartment cabinet shall be permanently labeled with its maximum load capacity.6.16.8 Patient compartment cabinets shall be tested dynamically using SAE J2917 and/or SAE J2956 as appropriate for the intended orientation and weight rating proposed by the manufacturer.6.16.8.1 The cabinet shall be mounted on a rigid test fixture using the hardware provided by the cabinet manufacturer.6.16.8.2 An analog device of a weight matching the proposed weight limit of the cabinet shall be placed at the center of the cabinet.6.16.8.3 Post-test inspection shall confirm the analog device remained in the cabinet and the cabinet remained attached to the test fixture.


These added sections provide testing parameters in support of 6.16.7. Cabinets and equipment mounts previously showed a requirement for a 10g load requirement with no discussion of method to valid compliance. The 10g value was also an arbitrary number. Ambulance, seat, and cot manufacturers are all moving to a dynamic loading test based on actual crash testing of ambulances. The results from those crash tests are covered by SAE J2917 (frontal impact) and SAE J2956 (side impact). It would be an obvious extension to test cabinet mounts to those same dynamic loads.









6.16.7 Each patient compartment cabinet shall be permanently labeled with its maximum load capacity.6.16.8 Patient compartment cabinets shall be tested dynamically using SAE J2917 and/or SAE J2956 as appropriate for the intended orientation and weight rating proposed by the manufacturer.6.16.8.1 The cabinet shall be mounted on a rigid test fixture using the hardware provided by the cabinet manufacturer.6.16.8.2 An analog device of a weight matching the proposed weight limit of the cabinet shall be placed at the center of the cabinet.6.16.8.3 Post-test inspection shall confirm the analog device remained in the cabinet and the cabinet remained attached to the test fixture.


Substantiation: These added sections provide testing parameters in support of 6.16.7. Cabinets and equipment mounts previously showed a requirement for a 10g load requirement with no discussion of method to valid compliance. The 10g value was also an arbitrary number. Ambulance, seat, and cot manufacturers are all moving to a dynamic loading test based on actual crash testing of ambulances. The results from those crash tests are covered by SAE J2917 (frontal impact) and SAE J2956 (side impact). It would be an obvious extension to test cabinet mounts to those same dynamic loads.









6.16.1The interior of the patient compartment shall provide enclosed storage cabinetry, compartment space , and shelf space .


Evolving design considerations may not include cabinets or compartment space. As written, the language suggests cabinets and compartments are required. The designation of separate types of space is unnecessary. There is also no apparent justification for specifying or restricting the type of storage space provided.









6.16.1The interior of the patient compartment shall provide enclosed storage cabinetry, compartment space , and shelf space .




Evolving design considerations may not include cabinets or compartment space. As written, the language suggests cabinets and compartments are required. The designation of separate types of space is unnecessary. There is also no apparent justification for specifying or restricting the type of storage space provided.









6.16.1The interior of the patient compartment shall provide enclosed storage

cabinetry, compartment space, and shelf space.

6.16.1 The interior of the patient compartment shall provide enclosed storage cabinetry , compartment space, and shelf space.


Substantiation: Evolving design considerations may not include cabinets or compartment space. As written, the language suggests cabinets and compartments are required. The designation of separate types of space is unnecessary. There is also no apparent justification for specifying or restricting the type of storage space provided.









6.16.8Where furnished, interior storage cabinets, shelves, and drawers shall not be obscured by other equipment or structures.


In order to improve reachability of the equipment, devices, medicine, and supplies in the patient compartment, it is best to remove any impediment that may obscure the EMSP from being able to reach them. This means that all interior storages need to be designed such that they allow the EMSP to reach them without having to go through any obstructions or hindrances. This will allow the EMSP to work more efficiently and with less difficulty.









6.16.9Interior storage cabinets, shelves, and drawers designed for storing common and critical equipment or supplies shall be within a maximum functional reach of 26.7 in. (678 mm) to the EMSPs with height as short as 59.3 in. (1506 mm) while seated and restrained. The securing mechanism of those interior storage cabinets and drawers, if provided, shall be capable of being accessed under the same reach condition.


Since common and critical equipment/supplies are more likely to be used by the EMSPs or are more important or critical for certain patients, their storage locations should be given higher priority for EMSPs’ reachability. By accommodating the functional required for these tools and their securing mechanisms to a shorter demographic with a smaller reach, EMSPs will have fewer difficulties in reaching the common and/or critical equipment. This will enhance their safety by allowing them to stay restrained more often and will also increase working efficiency. The human factors practices in MIL-STD 1472G, Design Criteria Standard Human Engineering (January 2012), have provisions for functional reach. Table B-I, Standing Body Dimensions – General Forces, of MIL-STD 1472G addresses functional reachability ranges for different size demographics.









6.16.10Interior storage cabinet doors shall not intrude on working space.


Obstructions and hindrances in the patient compartment working environment can lower working efficiency, and in some cases they may even lead to injuries. The interior storage cabinet doors have the potential to turn into a hindering or dangerous obstacle by intruding the workspace. To avoid this, they shall be designed in such a way that would prohibit them from intruding on the working space.









6.16.11The interior storage design shall not allow for items greater than 31 lb. (14 kg) being stored higher than 5ft (1524 mm) from the floor and for items greater than 44 lb. (20 kg) being not being stored higher than 3ft (914 mm) from the floor.


Heavy objects or items that are placed in higher storage areas pose three main injury risks. First, retrieving a heavy object from a higher-up shelf or storage area can cause a potential injury to a person should it fall on them. Second, heavy object may cause significant injuries when it falls from a top shelf or high storage area in the case of an accident or acceleration/deceleration. Third, lifting or retrieving a heavy object to a high elevation storage area can lead to musculoskeletal injury to the EMSPs. The human factors practices in MIL-STD 1472G, Design Criteria Standard Human Engineering (January 2012), does have requirements for human strength and handling capabilities. Table XXXVIII , Maximum Design Weight Limits, in MIL-STD 1472G addresses maximum design weight limits for different heights.









6.16.12Interior storage cabinet or drawer compartment handles, where provided, shall not pose a risk of injury, especially for the finger.


It’s not uncommon to find pinch points or finger traps on handles of storage cabinets or drawers. These scenarios can inflict avoidable minor injuries on the EMSP, and can become a huge annoyance when they are trying to provide healthcare for the patient. Apart from the discomfort or injury, getting extricated from pinch points and finger or clothing traps can take time away from the EMSP, which could have been used to attend to the patient. By designing the handles of the interior storage cabinet or drawer compartments to avoid posing a risk of such injuries, EMSP safety and worker performance can be enhanced.









6.16.13Interior storage cabinets, shelves, and drawers, where provided, shall have the capability to be labeled.


Proper labeling will enhance EMSP working efficiency. Proper labeling puts emphasis on the organizational aspects of the patient compartment working environment, which can reduce visual search time required by the EMSP to find the storage area of the device, tool, equipment, or supply they need. This reduced search time due to proper labeling can be used by the EMSP for patient health care.









These subsections build on previous text6.16.7 Each patient compartment cabinet shall be permanently labeled with its maximum load capacity.6.16.8 Patient compartment cabinets shall be tested dynamically using SAE J2917 and/or SAE J2956 as appropriate for the intended orientation and weight rating proposed by the manufacturer.6.16.8.1 The cabinet shall be mounted on a rigid test fixture using the hardware provided by the cabinet manufacturer.6.16.8.2 An analog device of a weight matching the proposed weight limit of the cabinet shall be placed at the center of the cabinet.6.16.8.3 Post-test inspection shall confirm the analog device remained in the cabinet and the cabinet remained attached to the test fixture....


These added sections provide testing parameters in support of 6.16.7. Cabinets and equipment mounts previously showed a requirement for a 10g load requirement with no discussion of method to valid compliance. The 10g value was also an arbitrary number. Ambulance, seat, and cot manufacturers are all moving to a dynamic loading test based on actual crash testing of ambulances. The results from those crash tests are covered by SAE J2917 (frontal impact) and SAE J2956 (side impact). It would be an obvious extension to test cabinet mounts to those same dynamic loads. These sections also expand the storage section while separating storage from equipment mounts in section 6.18


Submitter Full Name: James GreenOrganization: National Institute for Occupational Safety and HealthStreet Address:City: State: Zip:Submittal Date: Wed Jul 03 22:27:40 EDT 2013




I, James Green, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I herebywarrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am James Green, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature




6.16.7 Each patient compartment cabinet shall be permanently labeled with its maximum load capacity.6.16.8 Patient compartment cabinets shall be tested dynamically using SAE J2917 and/or SAE J2956 as appropriate for the intended orientation andweight rating proposed by the manufacturer.6.16.8.1 The cabinet shall be mounted on a rigid test fixture using thehardware provided by the cabinet manufacturer.6.16.8.2 An analog device of a weight matching the proposed weight limit of the cabinet shall be placed at the center of the cabinet.6.16.8.3 Post-test inspection shall confirm the analog device remained in the cabinet and the cabinet remained attached to the test fixture.




These added sections provide testing parameters in support of 6.16.7. Cabinets and equipment mounts previously showed a requirement for a 10g load requirement with no discussion of method to valid compliance. The 10g value was also an arbitrary number. Ambulance, seat, and cot manufacturers are all moving to a dynamic loading test based on actual crash testing of ambulances. The results from those crash tests are covered by SAE J2917 (frontal impact) and SAE J2956 (side impact). It would be an obvious extension to test cabinet mounts to those same dynamic loads.








6.16.7Where furnished, interior storage cabinets, shelves, and drawers, and their securing mechanisms shall be within a maximum standing functional reach of 26.7 in. (678 mm) and their contents shall be retrievable by EMSPs with height as short as 59.3 in. (1506 mm) while standing.


The equipment, medicine, devices, and supplies stored in the patient compartment cabinets, shelves, or drawers are hard to reach for many EMSPs. By accommodating the functional reach of these items to a shorter demographic with a smaller reach, EMSPs will have fewer difficulties in reaching and retrieving what they need. This will enhance their safety by allowing them to stay restrained more often and will also increase working efficiency. The human factors practices in MIL-STD 1472G, Design Criteria Standard Human Engineering (January 2012), have provisions for both thumb-tip functional reach and extended functional reach. Table B-I, Standing Body Dimensions – General Forces, of MIL-STD-1472G addresses functional reachability ranges for different size demographics.









6.16.6Storage cabinets and compartments shall be firmly fastened to the body structure. Cabinet construction and attachment integrity shall bevalidated by static testing that confirms crashworthiness equivalent to the dynamic testing outlined in standards SAE J2917 and/or SAE J2956 as appropriate for the intended orientation and weight rating proposed by the manufacturer. (Insert additional text here to prescribe the static pull requirements that are equivalent to the dynamic test imposed by SAE J2917 and SAE J2956.)




The current standard does not sufficiently define the requirements for cabinet attachment. An objective, science-based test criterion is needed to confirm construction and attachment integrity.While SAE J2917 and SAE J2956 lay the groundwork for the needed testing standards, they have not yet translated the results into static testing requirements as was the original intent of the NIOSH work. (Refer to https://www.fbo.gov/?s=opportunity&mode=form&id=dc3cf6bf92bf6644d6403cac3d3b9cea&tab=core&_cview=0 for a summary of the NIOSH solicitation.) Until such time as the referenced SAE standards are updated to convert the dynamic pulse corridor into an equivalent, repeatable, static test, the 1917 standard should prescribe a best-estimate static test requirement.Prescribing dynamic testing requirements for vehicles over 8,500 lbs is inconsistent with the requirements of the FMVSS which are based upon statistical cost/benefit analysis.While the virtue of dynamic testing is recognized, applying dynamic testing requirements to ambulances cannot be justified because the number of ambulances manufactured annual is relatively small and because nearly-equivalent results can be prescribed in the form of static testing.The fact that the conversion from dynamic to static testing has not yet been completed does not justify adding the dynamic testing cost burden to a class of vehicles produced by twenty different manufacturers in a quantity of only 5000 units per year.







6.17 Interior Surfaces.6.17.1

The interior of the body shall be free of all sharp projections and sharp corners.

6.17.2All hangers or supports for equipment and devices shall be mounted as flush as possible with the surrounding surface.

6.17.3The finish of the entire patient compartment and exterior storage, including interiors of storage cabinets, shall be as follows:

(1) Impervious to soap, water, body fluids, and disinfectants

(2) Mildew resistant

(3) Fire resistant in compliance with FMVSS 302

(4) Able to be cleaned and disinfected

6.17.4Countertop horizontal surface shall be seamless and impervious to contaminants.

6.17.5All edges that meet vertical cabinets shall be sealed.

6.17.6

Interior surface materials shall meet the flammability requirements of FMVSS 302 as well as one of the following:

(a) They shall exhibit a flame spread index not exceeding 200 when tested in accordance with ASTM E84 or ANSI/UL 723. The smokedeveloped

index shall not be limited.

(b) The shall exhibit a a radiant panel index not exceeding 200 when tested in accordance with ASTM E 162, Standard Test Method for Surface

Flammability of Materials Using a Radiant Heat Energy Source.

Also: add ASTM E84, UL 723 and ASTM E162 to chapter 2 on referenced standards.




FMVSS 302 does not assess fire resistance and is a required but insufficient fire test. The use of ASTM E84 or of ASTM E162 and the recommendation of a very low fire performance in those tests is consistent with requirements for manufactured homes and is much less severe than the guidelines or requirements for other types of public transport (airplanes, buses, subways, ships, etc.)









6.17.1The interior of the body shall be free of all sharp projections and sharp corners

Exposed edges that could come in contact with the occupant during normal use shall have a radius of curvature of not less than 0.1 in. (2.5 mm) except in the case of projections of less than 0.13 in. (3.3 mm), measured from the panel. In this case, the minimum radius shall not apply provided the height of the projection is not more than half its width and its edges are blunted .


Exposed sharp edges in the patient compartment may lead to detrimental injuries if any patient compartment occupant comes into hard contact with them, such as during an accident or a simple trip and fall. To avoid this, they shall be designed in a way that would prohibit sharp edges from being present in the patient compartment. Taking steps to define and prohibit such edges can save many EMSPs from injuries. The British standard for ambulances, BS EN 1789-2007, has a requirement for the roundness of exposed edges allowed in the patient compartment which provides a more precise definition for sharp edges. Enforcing this definition and requirement shall be a step forward in prohibiting sharp edges and avoiding injuries that come as a result of contact with such edges.









6.17.2All hangers or supports for equipment and , lighting, controls, and devices shall be mounted as flush as possible with the surrounding surface.


All hangers and supports for lighting and controls may also cause safety issue. Their locations should not get in way of movement or execution of emergency medical care tasks.









6.17.3 *The finish and seals of the entire patient compartment and exterior storage, including interiors of storage cabinets, shall be as follows:

(1) Impervious to soap, water, body fluids, and disinfectants

(2) Mildew resistant

(3) Fire resistant in compliance with FMVSS 302(4) Able to be cleaned and disinfected


The interior of the patient compartment needs to be easily cleaned. When surfaces, corners, edges, seals and joints get exposed to liquids, it becomes very difficult. The seals should also meet the criteria identified under 16.7.3. As a result, the patient compartment’s hygiene may deteriorate and be even detrimental to the health of incoming patients and EMSPs. To preserve the patient compartment’s hygiene and cleanliness, it’s essential for the interior patient compartment surfaces, corners, edges, and joints to be sealed by a liquid-proof bonding material. In addition, an asterisk has been added to correspond with additional material provided in annex.









6.17.6Workspace surfaces (i.e. countertops) shall have a mechanism to keep items from falling off the surface.


Taking measures to make sure that items can be placed in their appropriate locations without falling or moving around can avoid instances where the EMSP loses their item or has to repeatedly adjust their item’s positioning to keep it from falling. Having a requirement to avoid these unnecessary distractions and disturbances can lead to a more efficient working environment for the EMSP. This can be accomplished by providing all workspace surfaces with a mechanism to keep items from falling off the surface.









6.17.7The patient compartment shall be designed without small crevices, cracks, protrusions, and structures that may trap or catch the occupant's body parts.


Exposed sharp corners, projections, crevices, cracks, and other objects in the patient compartment may lead to detrimental injuries. Not only do they pose a hazard during an accident or a slip and fall, but they can become pinch points or finger traps. These scenarios can inflict injuries on the EMSP, and hinder the provision of healthcare for the patient. Apart from the injury hazards, getting out of pinch points and finger or clothing traps can take time away from the EMSP, which could have been used to attend to the patient. Prohibiting sharp projections, sharp corners, crevices, cracks, protrusions, and structures in the patient compartment can both avoid some injuries and save time for the EMSPs.









6.16.8 Each patient compartment cabinet will be tested to the maximum labeled weight using the SAE2917 Frontal Impact Pulse and SAE2956 Lateral Impact Pulse


If we are going to require cabinets to have labeled weight restriction we should also require they be tested. These two SAE pulses are specific for ambulances.









6.18.5Equipment securing mechanisms shall not impede use of that equipment by obscuring equipment controls, openings, or other critical areas of the equipment.


The research and survey carried out by the National Institute of Standards and Technology showed that unsecured equipment often becomes a projectile in case of sudden stop and therefore, of danger to EMSP. Such equipment is also often used while ambulance is in motion. In order to use them effectively while they are secured, the requirement is that the securing mechanisms should not cross their points of control or labels. (Reference: “Survey Report for Ambulance Patient Compartment Design,” NIST Technical Note 1772, http://nvlpubs.nist.gov/nistpubs/TechnicalNotes/NIST.TN.1772.pdf)









6.18 Equipment Mounting.6.18.1Storage and Securement of Medical Equipment and Suppliesand Equipment Storage Mounting.

Supplies, devices, tools, and so forth, shall be stored in enclosed compartments or fastened to secure them during vehicle motion.

6.18.2 Equipment . The customer shall list equipment, and supplies weighing 3 lb (1.36 kg) or more that will be used in the ambulance but not enclosed in a cabinet or compartment. The FASM shall provide means for securing all listed equipment, and supplies weighing 3 lb (1.36 kg) or more

mounted or stored that will not be enclosed in a

driving or patient area shall be contained in an enclosed compartment capable ofcontaining the contents

cabinet or compartment,

6.18.2The means of securement shall be capable of restraining the listed equipment when a 10G force is applied in the longitudinal, lateral, or vertical axis of the vehicle , if the equipment is secured in a bracket(s) or mount that can contain the equipment when the equipment is subjected to those same forces .

6.18.3Each patient compartment cabinet shall be permanently labeled with

its maximum load capacity.




This is a user requirement and therefore does not belong in an ambulance construction standard as originally written. However, the standard should address the legitimate need to secure items that are not stored in cabinets (which are covered in section 6.16.)If Section 6.16 prescribes requirements for securement of items in cabinets and compartments, Section 16.18 should prescribe requirements for items that are not stored in cabinets or compartments.





6.18.1 Medical Supplies and Equipment Storage Mounting.Supplies, devices, tools, and so forth other equipment , shall be stored in enclosed compartments or fastened to secure them during vehicle motion.


"and so forth" should not be in a specification/standard









6.18.2Equipment weighing 3 lb (1.36 kg) or more mounted or stored in a driving or

patient area shall be contained in an enclosed compartment capable of containing the contents when a 10G force is applied in the longitudinal, lateral, or vertical axis of the vehicle, if the equipment is secured in a bracket(s) or mount that can contain the equipment when the equipment is subjected to those same forces.

6.18.2 Equipment weighing 3 lb (1.36 kg) or more mounted or stored in a driving or patient area shall be contained in an enclosed compartment capable of containing the contents when a 10G force is applied in the longitudinal, lateral, or vertical axis of the vehicle, if the equipment is secured in a bracket(s) or mount that can contain the equipment when the equipment is subjected to those same forces.

6.18.2 Equipment weighing 3 lbs. (1.36 kg) or more that is to be mounted or secured in the patient compartment but not in an enclosed, labeled cabinet shall be dynamically tested using SAE J2917 and/or SAE J2956, as appropriate for the expected location and orientation of the equipment in the patient compartment.

6.18.2.1 The test shall include the equipment mount and the piece of equipment or a representative analog device to be mounted or secured.

6.18.2.2 The equipment mount or securing device shall be mounted to the test fixture using the manufacturer’s suggested mounting hardware.

6.18.2.3 Post-test inspection shall confirm the equipment or analog remained in the equipment mount or securing device and that the mount or securing device remained attached to the test fixture.


Substantiation: These added sections provide testing parameters in support of 6.18. Equipment mounts previously showed a requirement for a 10g load requirement with no discussion of method to valid compliance. The 10g value was also an arbitrary number. Ambulance, seat, and cot manufacturers are all moving to a dynamic loading test based on actual crash testing of ambulances. The results from those crash tests are covered by SAE J2917 (frontal impact) and SAE J2956 (side impact). It would be an obvious extension to test equipment mounts to those same dynamic loads.






6.18.2

Equipment weighing 3 lb (1.36 kg) or more mounted or stored in a driving or patient area shall be contained in an enclosed compartment capable of containing the contents when a 10G force is applied in the longitudinal, lateral, or vertical axis of the vehicle, if the equipment is secured in a bracket(s) or mount that can contain the equipment when the equipment is subjected to those same forces .6.18.2 Equipment weighing 3 lbs. (1.36 kg) or more that is to be mounted or secured in the patient compartment but not in anenclosed, labeled cabinet shall be dynamically tested using SAE J2917 and/or SAE J2956, as appropriate for the expected location and orientation of the equipment in the patient compartment.6.18.2.1 The test shall include the equipment mount and the piece of equipment or a representative analog device to be mounted or secured.6.18.2.2 The equipment mount or securing device shall be mounted to the test fixture using the manufacturer’s suggested mounting hardware.6.18.2.3 Post-test inspection shall confirm the equipment or analog remained in the equipment mount or securing device and that the mount or securing device remained attached to the test fixture.


These added sections provide testing parameters in support of 6.18. Equipment mounts previously showed a requirement for a 10g load requirement with no discussion of method to valid compliance. The 10g value was also an arbitrary number. Ambulance, seat, and cot manufacturers are all moving to a dynamic loading test based on actual crash testing of ambulances. The results from those crash tests are covered by SAE J2917 (frontal impact) and SAE J2956 (side impact). It would be an obvious extension to test equipment mounts to those same dynamic loads.





6.18.2

Equipment weighing 3

lblbs. (1.36 kg) or more that is to be mounted or

stored in a driving or patient area shall be contained in an enclosed compartment capable of containing the contents when a 10G force is applied in the longitudinal, lateral, or vertical axis of the vehicle, if the equipment issecured in a bracket(s) or mount that can contain the equipment when theequipment is subjected to those same forces

secured inthe patient compartment but not in an enclosed, labeled cabinet shall be dynamically tested using SAE J2917 and/or SAE J2956, as appropriate for the expected locationand orientation of the equipment in the patient compartment.

6.18.2.1The test shall include the equipment mount and the piece of equipment or a representative analog device to be mounted or secured.

6.18.2.2

The equipment mount or securing device shall be mounted to the test fixture using the manufacturer’s suggested mounting hardware.

6.18.2.3Post-test inspection shall confirm the equipment or analog remained in the equipment mount or securing device and that the mount or securing device remained attached to the test fixture .


Substantiation: These added sections provide testing parameters in support of 6.18. Equipment mounts previously showed a requirement for a 10g load requirement with no discussion of method to valid compliance. The 10g value was also an arbitrary number. Ambulance, seat, and cot manufacturers are all moving to a dynamic loading test based on actual crash testing of ambulances. The results from those crash tests are covered by SAE J2917 (frontal impact) and SAE J2956 (side impact). It would be





6.18.2Equipment weighing 3 lb lbs. (1.36 kg) or more that is to be mounted or stored secured ina driving or patient area shall be contained in an enclosed compartment capable of containing the contents when a 10G force is applied in the longitudinal, lateral, or vertical axis of the vehicle, if the equipment is secured in a bracket(s) or mount that can contain the equipment when the equipment is subjected to those same forcesthe patient compartment but not in an enclosed, labeled cabinet shall be dynamically tested using SAE J2917 and/or SAE J2956, as appropriate for the expected location and orientation of the equipment in the patient compartment.6.18.2.1 The test shall include the equipment mount and the piece of

equipment or a representative analog device to be mounted or secured.6.18.2.2 The equipment mount or securing device shall be mounted

to the test fixture using the manufacturer’s suggested mounting hardware.6.18.2.3 Post-test inspection shall confirm the equipment or analog

remained in the equipment mount or securing device and that the mount or securing device remained attached to the test fixture .







6.18.2Equipment weighing 3 lblbs. (1.36 kg) or more that is to be mounted or stored secured ina driving or patient area shall be contained in an enclosed compartment capable of containing the contents when a 10G force is applied in the longitudinal, lateral, or vertical axis of the vehicle, if the equipment is secured in a bracket(s) or mount that can contain the equipment when the equipment is subjected to those same forcesthe patient compartment but not in an enclosed, labeled cabinet shall be dynamically tested using SAE J2917 and/or SAE J2956, as appropriate for the expected location and orientation of the equipment in the patient compartment.

6.18.2.1 The test shall include the equipment mount and the piece of equipment or a representative analog device to be mounted or secured.

6.18.2.2 The equipment mount or securing device shall be mounted to the test fixture using the manufacturer’s suggested mounting hardware.

6.18.2.3 Post-test inspection shall confirm the equipment or analog remained in the equipment mount or securing device and that the mount orsecuring device remained attached to the test fixture .









6.18.4Power receptacles should be located near open counter-space or equipment that requires power (such as near laptop dock or portable radio storage).


Power receptacles placed far away from where they are needed are inefficient as they are hard to use and can lead to cords being strung across the patient compartment. Appropriate placing of power receptacles has quite a few benefits related to human factors. Appropriate placement of the receptacles means that the EMSP can spend less time looking for the ports to connect the devices to them. Also, since the devices are closer to the power receptacles, there will be less wiring required and some wire entanglements can be avoided in this manner. As a result of these human factors benefits to the patient compartment work environment, EMSPs can increase their working efficiency.









6.18.3Each patient compartment cabinet shall be permanently labeled with its

maximum load capacity.

6.18.3 Each patient compartment cabinet shall be permanently labeled with its maximum load capacity.


Substantiation: This change is being suggested as this is being moved to 6.16.7.









6.18 16 .3 7Each patient compartment cabinet shall be permanently labeled with its maximum load capacity.


This section belongs under interior storage and not section 16.8 Equipment Mounting.









6.18.3Each patient compartment cabinet shall be permanently labeled with its maximum load capacity.


Testing requirements for cabinets were previously addressed in comments made to paragraph 6.16.7. This would be a redundant statement if the earlier input for 6.16.7 is accepted.

Related Public Inputs for This Document

Related Input Relationship

Public Input No. 268-NFPA 1917-2013 [New Section after 6.16.6]

These two inputs separate cabinet requirements from equipment mounting requirements.











Substantiation: This change is being suggested as this is being moved to 6.16.7.











This change is being suggested as this is being moved to 6.16.7.









6.19.1Wall mounted disposal containers shall remain attached to the wall during accidents, vehicle maneuvers, and extreme motion.


Any object in the patient compartment that can dislodge from its position when subjected to strong acceleration and deceleration forces has the potential to become a projectile when those forces affect the patient compartment. Once a projectile hazard, an object can do a lot of damage in the patient compartment, including inflicting serious injuries on patient compartment occupants. Just like any other object, waste disposals have the potential to become dislodged from their positions, and consequently become a projectile hazard to the patient compartment occupants. To avoid this, it is important for them to have a sturdy mechanism to keep them attached to the wall whenever strong acceleration/deceleration forces affect the ambulance.









6.19.2Securing mechanism for waste and sharps disposal containers shall be capable of being removed and emptied without the use of tools.


The waste and sharps disposals in the patient compartment need to be emptied frequently and easily in order to keep a hygienic working environment. For them to comply to best human factors practices, they shall be able to be disconnected and removed for emptying with relative ease, without any additional tools. At the same time, this shouldn’t take away from the disposal container’s mounting security. They should still be able to have a mechanism to keep them attached to the wall whenever strong acceleration/deceleration forces affect the ambulance. This requirement promotes work environment hygiene while taking into account easy ergonomic practices and work environment safety.









6.19.3Containers for contaminated sharps shall be within a maximum functional reach of 26.7 in. (678 mm) to the EMSPs with height as short as 59.3 in. (1506 mm) and located as close as is feasible to the immediate area where sharps are used or can be reasonably anticipated to be found.


The waste and sharps disposals in the patient compartment are frequently accessed by EMS providers in order to throw away unnecessary byproducts and keep a hygienic patient compartment. By accommodating the reachability of the disposal containers to a shorter demographic with a smaller reach, EMS providers will have fewer difficulties in reaching them and throwing out their waste. This will enhance their safety by allowing them to stay restrained more often and will also increase working efficiency, as well as helping them maintain a clean working environment. The human factors practices in OSHA 1910.1030(d)(4)(iii)(A)(2)(i-iii) has provisions for the reachability of containers used for contaminated sharps as well as MIL-STD-1472G, Design Criteria Standard Human Engineering (January 2012), have provisions for thumb-tip functional reach. Table B-I, Standing Body Dimensions – General Forces, of MIL-STD-1472G which addresses functional reachability ranges for different size demographics.


Submitter Full Name: Jennifer MarshallOrganization: NISTStreet Address:City: State: Zip:Submittal Date: Tue Jul 02 09:24:12 EDT 2013







6.19 * Waste and Sharps Disposal.A receptacle for general waste and an OSHA-1910.1030 compliant container for sharps disposal shall be provided in the patient compartment.


It is helpful to identify the OSHA regulation to follow. Following safe practices from OSHA 1910.1030, contaminated sharps disposal containers can be required to keep their contents secure and safe from the rest of the patient compartment.









6.19 * Waste and Sharps Disposal.A receptacle Unless declined by the customer, a receptacle for general waste and an OSHA-compliant container for sharps disposal shall be provided in the patient compartment.




There is no basis for making a sharps container compulsory in a base ambulance standard when many customers do not use any sharps in their ambulance.The issue is resolved by allowing the customer to opt out of the sharps container.









6.20.1One Unless declined by the customer, at least one mounted device specifically designed for holding and securing an IV fluid containeragainst accidental release during normal transport activity shall beprovided.




There is no basis for making an IV hanger compulsory in a base ambulance standard when many customers do not use IVs in their ambulance.The issue is resolved by allowing the customer to opt out of the IV holder.The standard should not specify a quantity of one IV hanger, as this technically makes more than one IV hanger non-compliant. The language should allow for one or more IV hangers.









6.21.1 Seat Integrity.Any seat mounted on an adjustable seat device shall be dynamically tested along the direction of the adjustment using the crash pulse in SAE J2917, Occupant Restraint and Equipment Mounting Integrity — Frontal Impact System-Level Ambulance Patient Compartment.6.21.1.1The test shall be conducted with the seat oriented in the direction of

adjustment for both the forward-facing and rear-facing directions.6.21.1.2During and after the test, the seat shall remain securely attached to the

adjustment device.6.21.1.3Seat belt anchorages on side facing seats shall be tested in accordance

with the strength requirements of FMVSS 210.

6.21.1 Seat Integrity . Any seat and occupant restraint system mounted on a fixed or an adjustable seat device shall be dynamically tested along thedirection of the adjustment using the crash pulse in SAE J2917 , OccupantRestraint and Equipment Mounting Integrity—Frontal Impact System-Level Ambulance Patient Compartment. and SAE J2956 as appropriate for the proposed orientation of the seat and occupant restraint system in thevehicle .

6.21.1.1 If adjustable, tThe test shall be conducted with the seat oriented in the direction of adjustment for both the forward-facing and rear-facing directions.

6.21.1.2 The test shall include a 50 th percentile male anthropometric test device (ATD) as appropriate for the seating orientation and in accordance with the requirement of 49 CFR 572.

6.21.1. 2 3 During and after the test, the seat shall remain securely attached to mounting fixture the adjustment device .

6.21.1.4 During, and after the test, the ATD shall remain securely attached to the seating system.

6.21.1. 3 5 Seat belt anchorages on side facing wall mounted seats shall be tested in accordance with the strength requirements of FMVSS210.


Substantiation: The original language required a frontal impact test only, with an empty seat and limited acceptance criteria. NIOSH has now published a side impact test load input. The side impact should be included in the seat test requirement regardless of seat orientation. Also, loading of the structure is substantially increased with a 175 lb. crash test dummy installed. This will substantially increase the loading to the seat and seat attachment hardware. Seating manufacturers are already working with NIOSH and testing using this philosophy.





6.21.1

Seat Integrity.Any seat and occupant restraint system mounted on a fixed or an

adjustable adjustable seat device shall be dynamically tested along the direction of the adjustment using the crash

pulsepulse in SAE J2917, Occupant Restraint and Equipment Mounting

Integrity — Frontal Integrity—Frontal Impact System-

Level Level Ambulance Patient Compartment . and SAE J2956 as appropriatefor the proposed orientation of the seat and occupant restraint system in the vehicle.6.21.1.1

The If adjustable, tThe test shall be conducted with the seat oriented in the direction

of of adjustment for both the forward-facing and rear-facing directions.6.21.1.2

The test shall include a 50th percentile male anthropometric test device (ATD) as appropriate for the seating orientation and in accordance with the requirement of 49 CFR 572.6.21.1.3During and after the test, the seat shall remain securely attached to mounting fixture the adjustment device.6.21.1.

3 4



During, and after the test, the ATD shall remain securely attached to the seating system.6.21.1.5Seat belt anchorages on side facing wall mounted seats shall be tested inaccordance with the strength requirements of FMVSS 210.


Substantiation: The original language required a frontal impact test only, with an emptyseat and limited acceptance criteria. NIOSH has now published a side impact test load input. The side impact should be included in the seat test requirement regardless of seat orientation. Also, loading of the structure is substantially increased with a 175 lb. crash test dummy installed. This will substantially increase the loading to the seat and seat attachment hardware. Seating manufacturers are already working with NIOSH andtesting using this philosophy.









6.21.1 Seat Integrity.Any seat and occupant restraint system mounted on a fixed or an adjustable seat device shall be dynamically tested along the direction of the adjustment using the crash pulse in SAE J2917, Occupant Restraint and Equipment Mounting Integrity — Frontal Impact System-Level Ambulance PatientCompartment and SAE J2956 as appropriate for the proposed orientation of the seat and occupant restraint system in the vehicle .6.21.1.1

The If adjustable, the test shall be conducted with the seat oriented in the direction of adjustment for both the forward-facing and rear-facingdirections.

6.21.1.2

The test shall include a 50 th percentile male anthropometric test device (ATD) as appropriate for the seating orientation and in accordance with the requirement of 49 CFR 572.

6.21.1.3 During and after the test, the seat shall remain securely attached to the adjustment device mounting fixture .6.21.1.

34 During, and after the test, the ATD shall remain securely attached to the seating system.

6.21.1.5Seat belt anchorages on side facing wall mounted seats shall be tested in accordance with the strength requirements of FMVSS 210.


The original language required a frontal impact test only, with an empty seat and limited acceptance criteria. NIOSH has now published a side impact test load input. The side impact should be included in the seat test requirement regardless of seat orientation. Also, loading of the structure is substantially increased with a 175 lb. crash test dummy installed. This will substantially increase the loading to the seat and seat attachment hardware. Seating manufacturers are already working with NIOSH and testing using this philosophy.





6.21.1 Seat Integrity.Any seat and occupant restraint system mounted on a fixed or an adjustable seat device shall be dynamically tested along the direction of the adjustment using the crash pulse in SAE J2917 , Occupant Restraint and Equipment Mounting Integrity — Frontal Impact System-Level Ambulance Patient Compartment and SAE J2956 as appropriate for the proposed orientation of the seat and occupant restraint system in the vehicle .6.21.1.1

The If adjustable, the test shall be conducted with the seat oriented in the direction of adjustment for both the forward-facing and rear-facingdirections.6.21.1.2The test shall include a 50 th percentile male anthropometric test device

(ATD) as appropriate for the seating orientation and in accordance with the requirement of 49 CFR 572.

6.21.1.3During and after the test, the seat shall remain securely attached to theadjustment device mounting fixture.

6.21.1.4 During, and after the test, the ATD shall remain securely attached to the seating system .

6.21.1. 3 5Seat belt anchorages on side facing wall mounted seats shall be tested in accordance with the strength requirements of FMVSS 210.




The original language required a frontal impact test only, with an empty seat and limited acceptance criteria. NIOSH has now published a side impact test load input. The side impact should be included in the seat test requirement regardless of seat orientation. Also, loading of the structure is substantially increased with a 175 lb. crash test dummy installed. This will substantially increase the loading to the seat and seat attachment hardware. Seating manufacturers are already working with NIOSH and testing using this philosophy.





any Sub-Sections] ]

Any seat and occupant restratint system mounted on a fixed or an adjustable seat device shall be dynamically tested along the direction of the adjustment using the crash pulse in SAE J2917, Occupant Restraint and Equipment Mounting Integrity — Frontal Impact System-Level Ambulance PatientCompartment and SAE J2956 as appropriate for the proposed orientation of the seat and occupant restraint system in the vehicle .


NIOSH with substantial help from the ambulance manufacturers has developed front and side impact crash pulses. Also, testing should be based on the orientation of the seating system in the ambulance. This section will be expanded with subsections to follow that expand on the testing criteria to include crash test dummies for front and side impact testing.








Public Input No. 274-NFPA 1917-2013 [ New Section after 6.21.1.1 ]

TITLE OF NEW CONTENT6.21.1.2 The test shall include a 50th percentile male anthropometric test device (ATD) as appropriate for the seating orientation and in accordance with the requirement of 49 CFR 572.


Previous requirements for seat testing required dynamic testing of an empty seat. This change adds a requirement to include a crash test dummy just as is used in civilian automotive testing. This adds approximately 171 lbs to the seat substantially increasing loading in the seat, restraints and floor attachments.


Related Input RelationshipPublic Input No. 273-NFPA 1917-2013 [Section No. 6.21.1.1]









6.21.1.1The If adjustable, the test shall be conducted with the seat oriented in the direction of adjustment for both the forward-facing and rear-facingdirections.


Not all seats are adjustable. This simply tries to clarify the intent of the test and will go well with the added and modified paragraphs to be suggested later in this section.


Related Input RelationshipPublic Input No. 271-NFPA 1917-2013 [Section No. 6.21.1 [Excluding any Sub-Sections]]









TITLE OF NEW CONTENT6.21.1.4 During, and after the test, the ATD shall remain securely attached to the seating system.


Previously I suggested a revision to require a crash test dummy (ATD) be installed on the seat and restrained using the manufacturer's suggested restraint system. This new paragraph will become part of the post test acceptance criteria.



Section 6.21.1.2 required a dummy in the seat during testing. This requirement suggests the dummy must still be in seat post test.









6.21.1. 2 3During and after the test, the seat shall remain securely attached to the adjustment device mounting fixture .


This clarifies the test acceptance criteria related to seat structural integrity. It is expected the seat will be mounted to a sled testing fixture.









6.21.1. 3 5Seat belt anchorages on side facing wall mounted seats shall be tested in accordance with the strength requirements of FMVSS 210.


Individually this change recognizes not all bench or wall mounted seats are side facing. Rather, all bench seats whether side, rear, or fwd facing must have their restraint anchorage points tested in accordance with FMVSS 210.









6.21.2* SCBA Storage.SCBA Self Contained Breathing Apperatus packs shall not be stored in the seat backs of seats in the patient compartment.


Clarifies that the packs are SCBA packs and not air cylinders that may be used for other items and they can not be anywhere in the patient compartment









6.21.3 * Seat Belts Restraint Systems .6.21.3.1 *

Each designated seating position shall be provided with a seatbelt restraint .

6.21.3.2Ambulances above 19,500 lb (8845 kg) GVWR shall provide seat belts in

accordance with 6.21.3.2.1 and 6.21.3.2.2 .6.21.3.2.1The effective seat belt web length for a Type 1 lap belt for pelvic restraint

shall be a minimum of 60 in. (1524 mm) with the seat adjusted all the way back and down when measured using the following procedure and referring to Figure 6.21.3.2.1 :

(1) Locate an imaginary line where the plane of the center of the seat back surface intersects the plane of the center of the seat cushion surface (see line 1 in Figure 6.21.3.2.1 ).








Figure 6.21.3.2.1 Dimension Lines for Measuring Seat Belt Effective Length.



6.21.3.2.2The effective seat belt web length for a Type 2 pelvic and upper torso

restraint-style seat belt assembly shall be a minimum of 110 in. (2800 mm) with the seat adjusted all the way back and down when measured using the following procedure:


(2) Locate an imaginary line parallel with line 1 and lying on the center of the seat back surface 29 in. (740 mm) from line 1 (see line 2 in Figure6.21.3.2.1 ).


(4) Locate point B on line 2 at the shoulder strap edge of the seatback.


(6) Locate point D at the tip of the receiver.(7) Pull the seat belt webbing entirely out of the retractor and measure

along the webbing between points A and B.




6.21.3.3Signs that read “Occupants Must Be Seated and Belted and Restrained When Ambulance Is in Motion” shall be visible from each seated position.




With the growth and focus on restraint system requirements it may be favorable to rename this section to ‘restraints’ as this will especially help for consistency between requirements laid out in the standard. Also added an asterisk to correspond with supporting material in annex.









6.21.3.1*Each designated seating position shall be provided with a seat belt belt and associated hardware which complies with FMVSS 209 .


clarifies item and provides a standard









6.21.3.1 *Each designated seating position shall be provided with a seat belt that is compliant with FMVSS 209 and FMVSS 210 .




Requiring the presence of a seatbelt is a good start. However, to be effective, the standard should also specify the characteristics of the seatbelt.









6.21.3.2Ambulances above 19,500 lb (8845 kg) GVWR shall provide seat belts in accordance with 6.21.3.2.1 and 6.21.3.2.2 .

6.21.3.2.1The effective seat belt web length for a Type 1 lap belt for pelvic restraint shall be a minimum of 60 in. (1524 mm) with the seat adjusted all the way back and down when measured using the following procedure and referring to Figure 6.21.3.2.1 :









Figure 6.21.3.2.1 Dimension Lines for Measuring Seat Belt Effective Length.



6.21.3.2.2The effective seat belt web length for a Type 2 pelvic and upper torso restraint-style seat belt assembly shall be a minimum of 110 in. (2800 mm) with the seat adjusted all the way back and down when measured using the following procedure:


(2) Locate an imaginary line parallel with line 1 and lying on the center of the seat back surface 29 in. (740 mm) from line 1 (see line 2 in Figure6.21.3.2.1 ).


(4) Locate point B on line 2 at the shoulder strap edge of the seat back.



(7) Pull the seat belt webbing entirely out of the retractor and measure along the webbing between points A and B.







There is no basis for differentiation of seatbelt requirements based upon GVWR. The standard for all seatbelts should be FMVSS 209 and FMVSS 210 regardless of the ambulance GVWR.The issue is resolved by requiring compliance with FMVSS 209 and 210 in 6.21.3.1.







6.21.3.4*Restraint systems shall fit all occupants with heights between 59.3 in. and 73.4 in. (1506 mm and 1887 mm), and weights between 111.2 lbs and 270.3 lb. (50.5 kg and 122.8 kg).


In order to provide the necessary safety for users, restraints and restraint systems need to adhere to standard human factors practices. With a more ergonomic design, EMSPs will be allowed to perform work activities more efficiently. An ergonomic, appropriately-sized restraint will give them an extra support to comfortably work in a restrained position. The human factors practices in the National Health Statistics Reports Number 10, “Anthropometric Reference Data for Children and Adults: United States, 2003-2006,” have provisions for the restraint sizes. In addition, an asterisk has been added to correspond with additional material provided in annex.









6.21.3.3Signs that read “Occupants Must Be Seated and Belted When Ambulance Is

in Motion” shall be visible from each seated position.

6.21.3.3 Signs that read “Occupants Must Be Seated and Belted When Ambulance Is in Motion” shall be visible from each seated position.


Substantiation: This should be removed from the document and/or moved to an appropriate place in the annex as this should be an option for the AHJ. A design/construction standard should not include operational parameters, which the sign language is indicative of.









6.21.3.3Signs that read “Occupants Must Be Seated and Belted When Ambulance Is in Motion” shall be visible from each seated position.


This should be removed from the document and/or moved to an appropriate place in the annex as this should be an option for the AHJ. A design/construction standard should not include operational parameters, which the sign language is indicative of.









6.21.3.3Signs that read “Occupants Must Be Seated and Belted When Ambulance Is in Motion” shall be visible from each seated position.




This should be removed from the document and/or moved to an appropriate place in the annex as this should be an option for the AHJ. A design/construction standard should not include operational parameters, which the sign language is indicative of.









6.21.5.1Seats that rotate shall have a locking detent at a minimum of every 45° throughout the range of the seat rotation.


Seats that can rotate are of value for EMSPs. Seat rotation provides mobility for the EMSPs to access different parts of the patient’s body while simultaneously allowing them to remain in their seated, restrained position. If such a seat is used, it is important for it to be capable of locking at fixed positions. This stabilizes the EMSPs’ seating as they shift from one seating position to the other, and as a result allows a more efficient work process. A minimum of a locking detent at every 45° throughout the range of seat rotation provides a reference point for enhancing the usability of the seat’s feature.









6.21.7.6* The seat height shall be a maximum of 21 in. (533 mm), measured from the floor.


The seat height should accommodate the different height s of the occupants for comfortable seating. The human factors practices in MIL-STD 1472G has provisions for an appropriate seating height for work that involves seated operations. Requirement 5.10.3.2.7 of MIL-STD 1472G addresses the seat heights. In addition, an asterisk has been added to correspond with additional material provided in annex.









6.21.7.2 *Seat bottom cushions shall be between 15 in. and 19 in. (380 mm and 483 mm) from the front of the cushion to the face of the seat back.


Added asterisk to correspond with additional material provided in annex.









6.21.7.3A back cushion that extends from the seat bottom cushion vertically at least 7 in. (460 mm) and that is a minimum of 18 in. (460 mm) wide at the base shall be provided.


limits design and innovation









6.21.7.3 *A back cushion that extends from the seat bottom cushion vertically at least 7 in. (460 mm) and that is a minimum of 18 in. (460 mm) wide at the base shall be provided.











6.21.7.3A back cushion that extends from the seat bottom cushion vertically is at least 7 in. (460 mm) in height and that is a minimum of 18 in. (460 mm) wide at the base shall be provided.




For back pads attached to an ambulance wall, providing a gap between the top of the seat base and the bottom of the back cushion provides better lumbar support than a seat without such a gap. The current standard implies that the bottom of the back cushion must be at the top of the seat base cushion. To provide for optimal back support, the height and width of the back cushion should be specified, but the elevation of the bottom of the back cushion should either not be specified our should be specified to allow a gap between the top of the seat cushion and the bottom of the back cushion. This change still allows the pad to be positioned at a lower elevation in cases where providing clearance for windows outweighs the benefit of improved back support.









6.21.7.4Each seat shall provide back and head support beginning no more than 24 in. (610 mm) above the seat bottom cushion and continuing to at least 32 in. (813 mm) above the seat bottom cushion.


is restrictive to design and possible safety concern









6.21.7.4 *Each seat shall provide back and head support beginning no more than 24 in. (610 mm) above the seat bottom cushion and continuing to at least 32 in. (813 mm) above the seat bottom cushion.











6.21.8 * Access to Patient.6.21.8.1

If the primary patient care seat is at the patient torso position, it shall be capable of being adjusted such that the nearest edge of the seat bottom cushion is within 6 in. (152 mm) of the nearest edge of the patient cot.

6.21.8.2If the primary patient care position is at the patient torso position, the

fore-aft position of the seat shall be capable of lining up within 6 in. (152 mm) of the midpoint between the head end of the cot and the backrest hinge.

6.21.8.3If the primary patient care seat is at the patient head position, it shall

be capable of being adjusted such that the nearest edge of the seat bottom cushion is within 6 in. (152 mm) of the nearest edge of the patient cot.

6.21.8.4If the designated primary patient care seat is at the patient head

position, the longitudinal centerline of the seat shall line up within 11 in. (280 mm) of the longitudinal centerline of the cot.


An asterisk has been added to account for additional information provided in the annex.









6.21.8.1If the primary patient care seat is at the patient torso position, it shall be capable of being adjusted such that the nearest edge of the seat bottom cushion is within 6 in. (152 mm) of the nearest edge of thepatient cot.


Clarification









6.21.8.1If the primary patient care seat is an adjustable seat at the patient torso position, it shall be capable of being adjusted such that thenearest edge of the seat bottom cushion is within 6 in. (152 mm) of the nearest edge of the patient cot.




The depth of adjustable seats is typically 4" to 9" greater than bench seats. Requiring an adjustable seat in this position has the unintended consequence of diminishing the normal aisle clearance. Customers should be given the freedom to determine whether their application benefits more from an adjustable seat or greater aisle width.









6.21.8.2If the primary patient care position is at the patient torso position, the fore-aft position of the seat shall be capable of lining up within 6 in. (152 mm) of the midpoint between the head end of the cot and the backrest hinge.

6.21.8.2 If the primary patient care position seat is at the patient torso position, the fore-aft position of the seat shall be capable of lining up within 6 in. (152 mm) of the midpoint between the head end of the cot and the backrest hinge.


This change was made for the purposes of clarifying that the requirement is pertaining to the primary patient care seat rather than position.









6.21.8.2If the primary patient care position seat is at the patient torso position, the fore-aft position of the seat shall be capable of lining up within 6 in. (152 mm) of the midpoint between the head end of the cot and the backrest hinge.


This change was made for the purposes of clarifying that the requirement is pertaining to the primary patient care seat rather than position









6.21.8.2If the primary patient care position care seat is at the patient torso position, the fore-aft position of the seat shall be capable of lining up within 6 in. (152 mm) of the midpoint between the head end of the cot and the backrest hinge.




This change was made for the purposes of clarifying that the requirement is pertaining to the primary patient care seat rather than position.









6.21.9.1Any seat with a built-in system suitable for transporting a child or an infant shall not be oriented designed for operation in aside forward -facing or rear-facing direction during transport.




Improve the grammar by changing from a negative to a positive statement. Change this to a design requirement as this is a standard for ambulance construction rather than ambulance operation.









6.21.10 Seatbelt Warning System.6.21.10.1An occupant restraint warning system shall be provided for each designated

seating position in the patient compartment.6.21.10.2The warning system shall indicate if an occupant in the patient compartment

is not belted or restrained.6.21.10.3The warning system shall consist of an audible and visual warning device

that can be heard and seen by the driver and seen by the occupants of the patient compartment.

6.21.10.4The warning shall be activated when the parking brake is released and

the transmission is not in neutral or park.6.21.10.5The warning system shall not show an affirmative indication unless it has

determined that the seat was occupied before the seat belt or restraint wasbuckled.

6.21.10 Seatbelt Warning System.6.21.10.1 An occupant restraint warning system shall be provided for

each designated seating position in the patient compartment.6.21.10.2 The warning system shall indicate if an occupant in the

patient compartment is not belted or restrained.6.21.10.3 The warning system shall consist of an audible and visual

warning device that can be heard and seen by the driver and seen by the occupants of the patient compartment.

6.21.10.4 The warning shall be activated when the parking brake is released and the transmission is not in neutral or park.

6.21.10.5 The warning system shall not show an affirmative indication unless it has determined that the seat was occupied before the seat belt or restraint was buckled.


Substantiation: This change is being suggested as it is believed that this distracts the driver, does not alarm if provider departs the seat, there may be clinical demands warranting seat departure, it does not correspond to the need to stop the vehicle. This could be moved to the annex and expand to include policy issues as well as other crew monitoring mechanisms. A design/construction standard should not include operational parameters. It was previously added to the standard as a good idea. The visual and audible alarm will add distraction to a driver. The system may be defeated if the unbelted and seated Caregiver simply stands in the Patient Compartment – which has been documented as a unsafe position for an occupant in the Patient Compartment. It is well established that there may be clinical demands warranting seat departure for patient care. As a good idea, this could be moved to the annex and expand to include policy issues as well as other crew monitoring mechanisms.




6.21.10 Seatbelt Warning System.6.21.10.1

An occupant restraint warning system shall be provided for each designated seating position in the patient compartment.

6.21.10.2The warning system shall indicate if an occupant in the patient compartment is not belted or restrained.

6.21.10.3The warning system shall consist of an audible and visual warning device that can be heard and seen by the driver and seen by the occupants of the patient compartment.

6.21.10.4The warning shall be activated when the parking brake is released and the transmission is not in neutral or park.

6.21.10.5The warning system shall not show an affirmative indication unless it has determined that the seat was occupied before the seat belt or restraint wasbuckled.


The requirement for a audible and visual seatbelt warning system does not match the current design of ambulances which do not allow for the personnel to remain seated while providing patient care. This requirement will only increase the non-use of seatbelts and will encourage users to over-ride or disable the system. The requirement of use of seatbelts is a service level requirement, not a requirement of a standard. Move item to the annex so if a user selects this the builder can provide the item


Submitter Full Name: Aarron ReinertOrganization: Lakes Region EMSStreet Address: City:State: Zip: Submittal Date: Tue Jul 02 21:19:35 EDT 2013













This change is being suggested as it is believed that this distracts the driver, does not alarm if provider departs the seat, there may be clinical demands warranting seat departure, it does not correspond to the need to stop the vehicle. This could be moved to the annex and expand to include policy issues as well as other crew monitoring mechanisms. A design/construction standard should not include operational parameters. It was previously added to the standard as a good idea. The visual and audible alarm will add distraction to a driver. The system may be defeated if the unbelted and seated Caregiver simply stands in the Patient Compartment – which has been documented as a unsafe position for an occupant in the Patient Compartment. It is well established that there may be clinical demands warranting seat departure for patient care. As a good idea, this could be moved to the annex and expand to include policy issues as well as other crew monitoring mechanisms.







6.22 Patient Cot Retention.6.22.1Each patient cot retention system shall not fail or release when subjected to

the greater of the cot manufacturer’s recommended retention force or a minimum retention force of 2200 lb (998 kg) applied in the longitudinal, lateral, and vertical directions.

6.22.2Compliance of the cot retention system shall be validated by testing a

sample retention device using a substantially similar ambulance or body structure in accordance with Section 9.4 .

6.22 Patient Cot Retention .6.22.1 Each patient cot retention system shall not fail or release when

subjected to the greater of the cot manufacturer’s recommended retention force or a minimum retention force of 2200 lb (998 kg) applied in the longitudinal, lateral, and vertical directions. Each patient cot, patient restraint, and cot retention system shall be dynamically tested as a system using SAE J2917 and SAE J2956, as appropriate.

6.22.1.1 Pre-test, a 50 th percentile male ATD with pedestrian pelvis shall be properly positioned on the cot per manufacturer’s instructions.

6.22.1.2 During and after the test the cot shall remain securely attached to cot mounting system.

6.22.1.3 During and after the test the cot mounting system shall remain securely attached to the test fixture.

6.22.1.4 During and after the test, the ATD shall remain securely attached to the cot.

6.22.2 Compliance of the cot retention system shall be validated by testing a sample retention device using a substantially similar ambulance or body structure in accordance with Section 9.4.


Substantiation: Cot testing previously showed a requirement for a 2200 lb. static loading of cot retention device in multiple directions based on the AMD 004 test. The 2200 lb. value was an arbitrary number. Ambulance, seat, and cot manufacturers are all moving to a dynamic loading test based on actual crash testing of ambulances. The results from those crash tests are covered by SAE J2917 (frontal impact) and SAE J2956 (side impact). Cot manufacturers are also working with NIOSH to test cots installed into the cot retention and loaded with a 50th percentile crash test dummy (175 lb.) The loading experienced by the cot and cot retention device in such a crash is far greater than was found in the 2200 lb. pull test.





6.22 * Patient Cot Loading and Retention.6.22.1

Each patient cot retention system shall not fail or release when subjected to the greater of the cot manufacturer’s recommended retention force or a minimum retention force of 2200 lb (998 kg) applied in the longitudinal, lateral, and vertical directions.

6.22.2Compliance of the cot retention system shall be validated by testing a

sample retention device using a substantially similar ambulance or body structure in accordance with Section 9.4 .


We have recommended a number of items to this section that include loading of the cot onto the ambulance. Thus a new section title is suggested. In addition, a star (*) is added to the section title of 6.22 for new annex item to be associated with.









6.22 Patient Cot Retention.6.22.1

Each patient cot

retention system shall not fail or release when subjected to the greater of the cot manufacturer’s recommended retention force or a minimum retention force of 2200 lb (998 kg) applied in the longitudinal, lateral, and vertical directions, patient restraint, and cot retention system shall be dynamically tested as a system using SAE J2917 and SAE J2956, as appropriate.

6.22.1.1 Pre-test, a 50 th percentile male ATD with pedestrian pelvis shall be properly positioned on the cot per manufacturer’s instructions .

6.22.

2 Compliance of the cot retention system shall be validated by testing a sample retention device using a substantially similar ambulance or body structure in accordance with Section 9.4 .1.2 During and after the test the cot shall remain securely attached to cot mounting system.


6.22.1.4 During and after the test, the ATD shall remain securely attached to the cot.




Cot testing previously showed a requirement for a 2200 lb. static loading of cot retention device in multiple directions based on the AMD 004 test. The 2200 lb. value was an arbitrary number. Ambulance, seat, and cot manufacturers are all moving to a dynamic loading test based on actual crash testing of ambulances. The results from those crash tests are covered by SAE J2917 (frontal impact) and SAE J2956 (side impact). Cot manufacturers are also working with NIOSH to test cots installed into the cot retention and loaded with a 50th percentile crash test dummy (175 lb.) The loading experienced by the cot and cot retention device in such a crash is far greater than was found in the 2200 lb. pull test.









6.22 Patient Cot Retention.6.22.1

Each patient cotretention system shall not fail or release when subjected to the greater of the cot manufacturer’s recommended retention force or a minimum retention force of 2200 lb (998 kg) applied in the longitudinal, lateral, and vertical directions, patient restraint, and cot retention system shall be dynamically tested as a system using SAE J2917 and SAE J2956, as appropriate.

6.22.1.1 Pre-test, a 50 th percentile male ATD with pedestrian pelvis shall be properly positioned on the cot per manufacturer’sinstructions .

6.22.

2 Compliance of the cot retention system shall be validated by testing a sample retention device using a substantially similar ambulance or body structure in accordance with Section 9.4

1.2 During and after the test the cot shall remain securely attached to cot mounting system.


6.22.1.4 During and after the test, the ATD shall remain securely attached to the cot .




Cot testing previously showed a requirement for a 2200 lb. static loading of cot retention device in multiple directions based on the AMD 004 test. The 2200 lb. value was an arbitrary number. Ambulance, seat, and cot manufacturers are all moving to a dynamic loading test based on actual crash testing of ambulances. The results from those crash tests are covered by SAE J2917 (frontal impact) and SAE J2956 (side impact). Cot manufacturers are also working with NIOSH to test cots installed into the cot retention and loaded with a 50th percentile crash test dummy (175 lb.) The loading experienced by the cot and cot retention device in such a crash is far greater than was found in the 2200 lb. pull test.




TITLE OF NEW CONTENT6.22.1.1 Pre-test, a 50th percentile male ATD with pedestrian pelvis shall be properly positioned on the cot per manufacturer’s instructions.6.22.1.2 During and after the test the cot shall remain securely attached to cot mounting system.6.22.1.3 During and after the test the cot mounting system shall remain securely attached to the test fixture.6.22.1.4 During and after the test, the ATD shall remain securely attached to the cot....


These new added paragraphs constitute the acceptance criteria for the lead paragraph which requires a full test of the cot, patient restraint, and cot anchorage system. this work is already being done by NIOSH and its industry partners and has been determined to be attainable.


Related Input RelationshipPublic Input No. 278-NFPA 1917-2013 [Section No. 6.22.1]

6.22.1 is test requirment while sub-paragrpahs offer acceptance criteria






6.22.1Each patient cot retention system shall not fail or release the cot when subjected to the greater of the cot manufacturer’s recommended retention force or a minimum retention force of 2200 lb (998 kg) applied in the longitudinal, lateral, and vertical directions relative to the vehicle center line .


clarification









6.22.1Each patient cot retention system shall not fail or release when

subjected to the greater of the cot manufacturer’s recommended retention force or a minimum retention force of 2200 lb (998 kg) applied in the longitudinal, lateral, and vertical directions. Each patient cot, patient restraint, and cot retention system shall be dynamically tested as a system using SAE J2917 and SAE J2956, as appropriate.


Cot testing previously showed a requirement for a 2200 lb. static loading of cot retention device in multiple directions based on the AMD 004 test. The 2200 lb. value was an arbitrary number. Ambulance, seat, and cot manufacturers are all moving to a dynamic loading test based on actual crash testing of ambulances. The results from those crash tests are covered by SAE J2917 (frontal impact) and SAE J2956 (side impact). Cot manufacturers are also working with NIOSH to test cots installed into the cot retention and loaded with a 50th percentile crash test dummy (175 lb.) The loading experienced by the cot and cot retention device in such a crash is far greater than was found in the 2200 lb. pull test. While this single modification does not spell of this out, the linked sections to be added will expand to include the crash test dummy as part of the required test.









6.22.3Cot guidance and securing mechanism shall incorporate a universal locking and mounting system that is able to secure cots of all models and from all vendors.


The purpose of the cot guidance and securing mechanism is to assist the EMSPs in loading a patient onto the ambulance as soon as possible. The cots are manufactured by different companies and are generally available in different models and sizes. There may be times when the EMSP will want to load a cot that is different from their normal cot, such as during a mass casualty event. Having standard guidance and securing mechanisms will facilitate this. The recommendation is for a guidance system that can enable loading a patient irrespective of the cot size or configuration.









6.22.4The floor height and design of the patient compartment shall allow for the cot to beinserted into the compartment by one EMS provider without having to bear the full weight of the cot .


The EMSPs carry out a number of physically strenuous activities such as inserting the cot into the patient compartment. The level of physical effort needed to insert the cot depends on the floor height to which the cot is to be raised and on the design of the rear of the compartment, which should be such that one EMSP can accomplish the task without bearing the entire load to avoid musculoskeletal injuries.









6.22.5The cot guidance and retention system shall have no potentially harmful protrusions such as pinch points, sharp projections, or edges .


The purpose of the cot guidance and securing mechanism is to assist the EMSPs load a patient onto the ambulance as soon as possible. In the rush to get the patient to the hospital where mistakes can easily be made, any risks of harm to occupants should be minimized by elimination of potentially harmful projections. Sharp projections can also inflict serious injuries to emergency medical workers, especially in case of an accident or sudden maneuver. The recommendation is for a best practice in design and manufacturing that should result in smooth edges on the cot loading mechanism.









6.22.6The force required to secure and to release the cot from the cot retention system shall be no greater than 23 N (5 lb.).


The cot securing mechanism should be designed to allow EMSPs be able to secure or release the cot. The requirement is obtained from the Figure 14, Push Button (Resistance-Thumb/Palm), of MIL-STD-1472G, Design Criteria Standard Human Engineering (January 2012).









6.22.7The EMSP shall be able to determine if the cot has been properly secured.


Patient cots have been known to detach in case of accident or sudden maneuver. When this happens serious injuries are often inflicted on the patient and other ambulance occupants. To ensure that the cots are fully secured and minimize this risk, there should be some sort of visual, tactile, or audible feedback that the cot has been firmly secured.









6.22.8A cot loading mechanism, if used, shall allow use only if cot is in the proper position.


Cot loading mechanism may be activated when the cot is not correctly in place with the end result that the cot is not properly secured. The requirement is for a design where the mechanism should not load until this is done.









6.22.9The cot loading mechanism shall be free of pinch points and sharp projections.


Safe working environment includes work equipment that is designed to be not only easy to use but also free of features that can potentially injure its user. The loading of a patient onto the ambulance is done in a hurry to rush to the hospital. Therefore, the requirement is that the loading mechanism should be free of any feature that can potentially cause harm to emergency medical workers.









6.22.2Compliance of the cot retention system shall be validated by testing a sample retention device using a substantially similar ambulance or body structure in accordance with Section 9.4 .


Earlier linked paragraphs are suggesting a dynamic test using crash load inputs to be a replacement for the previously identified static test in section 9.4


Related Input RelationshipPublic Input No. 278-NFPA 1917-2013 [Section No. 6.22.1] Dynamic test requirement

Public Input No. 279-NFPA 1917-2013 [New Section after 6.22.1]

Post dynamic test acceptancecriteria









6.23.3.1Ventilation system(s) in the patient compartments shall provide a change of ambient air with the vehicle stationary.




Without a requirement for an air change within a prescribed timeframe, this requirement adds nothing beyond what is required in 6.23.3.4. This section should be deleted and the subsequent sections re-numbered.









6.23.3.5Air vents shall be located where they will not be obscured by interior storage cabinet doors, other equipment storage, and seats.


Ventilation systems are important to provide heating, air conditioning and airflow inside the patient compartment. Proper ventilation allows the EMSP to perform within a suitable working environment in terms of comfort and safety. Once obscured or blocked, air vents will not be able to deliver air to the compartment adequately and properly. Therefore, it is necessary to require air vents to be properly placed such that interior storage cabinet doors, other equipment storage, or EMSPs wouldn’t be able to obscure or block them.









6.25 * Reflective Striping.6.25.1 *A retroreflective stripe or combination of stripes shall be affixed to the

ambulance in the following proportions:

(1) 25 percent of the width of the front of the ambulance visible when approached from the front

(2) 50 percent of the overall ambulance length visible when approached from each side

6.25.2The stripe or combination of stripes shall be a minimum of 4 in. (100 mm) in

total vertical width.6.25.3The 4 in. (100 mm) wide stripe or combination of stripes shall be permitted

to be interrupted by objects (e.g., receptacles, cracks between slats in roll updoors), provided the full stripe is conspicuous as the ambulance isapproached.

6.25.4A graphic design shall be permitted to replace all or part of the required

striping material if the design or combination thereof covers at least the sameperimeter length(s) required by 6.28.1 .

6.25.5Any vertically hinged door shall have at least 60 in. 2 (38,710 mm 2 ) of

retroreflective material affixed to the inside of the door.6.25.6At least 50 percent of the rear-facing vertical surfaces, visible from the

rear of the ambulance, shall be equipped with retroreflective striping in a chevron pattern sloping downward and away from the centerline of the vehicle at an angle of 45 degrees.

6.25.6.1Each stripe in the chevron shall be a single color alternating between

red and either yellow, fluorescent yellow, or fluorescent yellow-green.6.25.6.2Each stripe shall be 6 in. (150 mm) in width.6.25.7All retroreflective material shall conform to the requirements of

ASTM D 4956, Standard Specification for Retroreflective Sheeting for Traffic Control , Section 6.1.1, for Type I Sheeting.

6.25.8All retroreflective materials that are colors not listed in ASTM D

4956, Standard Specification for Retroreflective Sheeting for Traffic Control ,Section 6.1.1, shall have a minimum coefficient of retroreflection of 10 with anobservation angle of 0.2 degrees and an entrance angle of -4degrees.

6.25.9



Any printed or processed retroreflective film construction shall conform to the standards required of an integral colored film as specified in ASTM D 4956, Standard Specification for Retroreflective Sheeting for Traffic Control , Section 6.1.1.

6.25.1* A retroreflective stripe or combination of stripes shall be affixed to the ambulance in the following proportions:

(1) 25 percent of the width length of each of the frontcab side surfaces of the ambulance visible when approached from the front each side .

(2) 50 75 percent of the overall ambulance length patient compartment side surfaces visible when approached from eachside.

6.25.2 The stripe or combination of stripes shall be a minimum of 4 6 in. (152 mm) in total vertical width.

6.25.3 The 4 6 in. (152 mm) wide stripe or combination of stripes shall be permitted to be interrupted by objects (e.g., receptacles, cracks between slats in roll up doors), provided the full stripe is conspicuous as the ambulance is approached.

Substantiation: The task group strongly recommends maximizing conspicuity and improved specificity of the proposed language. The revised provision contains requirements that may be met and provide an adequate level of safety.

6.25.6 * At least 50 percent of the rear-facing, painted vertical surfaces, visible from the rear of the ambulance, shall be equipped with retroreflective material. striping in a chevron pattern sloping downward and away from the centerline of the vehicle at an angle of 45degrees.

A.6.25.6 Retroreflective material included in the calculationincludes any combination of graphics, lettering, a chevron pattern slopingdownward and away from the centerline of the vehicle at an angle of 45 degrees or Battenburg markings.

6.25.6.1 When chevrons are used, each stripe in the chevronshall be a single color alternating between two high contrast colors. Each stripe in the chevron shall be a single color alternating between red and either yellow, fluorescent yellow, or fluorescent yellow-green.

6.25.6.3 When Battenburg markings are used, each box in the Battenburg markings shall be XX in 2 (XX mm 2 ).


Substantiation: The task group is suggesting these changes as the back of an ambulance is configured differently than a fire truck. The AHJ has the authority to determine the design of all safety markings on the vehicle. Science has established that chevrons are not the only design that provides conspicuity. The intended desire in the existing standard to be consistent between fire & EMS may actually conflict with local culture and preferences. Scientific research and the FEMA study on conspicuity does not dictate one design or color pair, and the color red is highly inconspicuous during daylight and nighttime hours.





6.25.1*A retroreflective stripe or combination of stripes shall be affixed to theambulance in the following proportions : (1) 25 percent of the width of the front of the ambulance visible when approached from the front50 percent of the overall ambulance length visible

the length of each of the cab side surfaces when approached from each side. 75 percent of the patient compartment sidesurfaces visible when approached from each side .










Public Input No. 347-NFPA 1917-2013 [ Sections 6.25.1, 6.25.2,

6.25.3 ]

Sections 6.25.1, 6.25.2, 6.25.36.25.1 *

A retroreflective stripe or combination of stripes shall be affixed to the ambulance in the following proportions :

(1) 25 percent of the width length of the front each of the ambulance visible when cab side surfaces when approachedfrom the front each side

(2) 50 75 percent of the overall ambulance length patient compartment side surfaces visible when approached from each side

6.25.2The stripe or combination of stripes shall be a minimum of 4 6 in. ( 100 152 mm) in total vertical width.

6.25.3The 4 6 in. ( 100 152 mm) wide stripe or combination of stripes shall be permitted to be interrupted by objects (e.g., receptacles, cracks between slats in roll up doors), provided the full stripe is conspicuous as the ambulance is approached.


The task group strongly recommends maximizing conspicuity and improved specificity of the proposed language. The revised provision contains requirements that may be met and provide an adequate level of safety.







Public Input No. 467-NFPA 1917-2013 [ Sections 6.25.1, 6.25.2,

6.25.3 ]

Sections 6.25.1, 6.25.2, 6.25.36.25.1 *

A retroreflective stripe or combination of stripes shall be affixed to the ambulance in the following proportions: (1) 25 percent of the widthlength ofthe front each of the ambulance visible cab side surfaces when approached from the front50 percent of the overall ambulance length each side75 percent of the patient compartment side surfaces visible when approached from each side

6.25.2The stripe or combination of stripes shall be a minimum of 4 of 6 in. (100 mm) in total vertical width.

6.25.3The 4 The 6 in. (100 mm) wide stripe or combination of stripes shall be permitted to be interrupted by objects (e.g., receptacles, cracks between slats in roll up doors), provided the full stripe is conspicuous as the ambulance is approached.




The task group strongly recommends maximizing conspicuity and improved specificity of the proposed language. The revised provision contains requirements that may be met and provide an adequate level of safety.





6.25.2The Each front or side facing stripe or combination of stripes shall be a minimum of 4 in. (100 mm) in total vertical width.


Clarification









6.25.2The stripe or combination of stripes shall be a minimum of 4 6 in. (100 152 mm) in total vertical width.




Related Input RelationshipPublic Input No. 308-NFPA 1917-2013 [Section No. 6.25.1] Same Substantiation









6.25.3The Each front or side facing stripe or combination shall be 4 in. (100 mm) wide stripe or combination of stripes shall be permitted to be interrupted by objects (e.g., receptacles, cracks between slats in roll up doors), provided the full stripe is conspicuous as the ambulance isapproached.


Clarification









6.25.3The 4 6 in. (100 152 mm) wide stripe or combination of stripes shall be permitted to be interrupted by objects (e.g., receptacles, cracksbetween slats in roll up doors), provided the full stripe is conspicuous as the ambulance is approached.


Substantiation: The task group strongly recommends maximizing conspicuity andimproved specificity of the proposed language. The revised provision containsrequirements that may be met and provide an adequate level of safety.


Related Input RelationshipPublic Input No. 308-NFPA 1917-2013 [Section No. 6.25.1] Same Substantiation









6.25.4A graphic design shall be permitted to replace all or part of the required striping material if the design or combination thereof covers at least the same perimeter length(s) required by 6. 28 25 .1 .


Clerical error…6.28.1 is pointing to the oxygen supply, not the striping requirements.









6.25.6At least 50 percent of the rear-facing vertical surfaces, visible from the rear ofthe ambulance, shall be equipped with retroreflective striping in a chevronpattern sloping downward and away from the centerline of the vehicle at an angle of 45 degrees.6.25.6.1

Each stripe in the chevron shall be a single color alternating between red and either yellow, fluorescent yellow, or fluorescent yellow-green.

6.25.6.2Each stripe shall be 6 in. (150 mm) in width.

6.25.6 * At least 50 percent of the rear-facing, painted vertical surfaces, visible from the rear of the ambulance, shall be equipped with retroreflective material. striping in a chevron pattern sloping downward and away from the centerline of the vehicle at an angle of 45 degrees.

A.6.25.6 Retroreflective material included in the calculation includes any combination of graphics, lettering, a chevron pattern sloping downward and away from the centerline of the vehicle at an angle of 45 degrees or Battenburg markings.

6.25.6.1 When chevrons are used, each stripe in the chevron shall be a single color alternating between two high contrast colors. Each stripe in the chevron shall be a single color alternating between red and either yellow, fluorescent yellow, or fluorescent yellow-green.

6.25.6.3 When Battenburg markings are used, each box in the Battenburg markings shall be XX in 2 (XX mm 2 ).




Submitter Full Name: Ronald ThackeryOrganization: American Medical Response, IncStreet Address: City:State: Zip: Submittal Date: Tue Jul 02 11:11:28 EDT 2013




6.25.6At least 50 percent of the rear-facing vertical surfaces, visible from the rear of the ambulance, shall be equipped with retroreflective striping in a chevron pattern sloping downward and away from the centerline of the vehicle at an angle of 45 degrees.

6.25.6.1Each stripe in the chevron shall be a single color alternating between red and either yellow, fluorescent yellow, or fluorescent yellow-green.



There is not clear data that this requirement will increase safety. Rather there is data from other countries, such as Australia that the chevrons draw the eye and cause vehicles to hit emergency vehicles. Peer reviewed research by Vivian Tipend University of Queensland


Submitter Full Name: Aarron ReinertOrganization: Lakes Region EMSStreet Address: City:State: Zip: Submittal Date: Tue Jul 02 21:34:41 EDT 2013







6.25.6At least 50 percent of the rear-facing vertical surfaces, visible from the rear of the ambulance, shall be equipped with retroreflective striping in material. 6.25.6.1Retroreflective material included in the calculation includes any combination of graphics, lettering, a chevron pattern sloping downward and away from the centerline of the vehicle at an angle of 45 degrees or Battenburg markings .6.25.6.1 2

Each When chevrons are used, each stripe in the chevron shall be a single color alternating between red and either yellow, fluorescent yellow, or fluorescent yellow-green two high contrast colors .

6.25.6.2 3Each stripe shall be 6 in. (150 mm) in width When Battenburg markings are used, each box in the Battenburg markings shall be XX in2 (XXmm2) .










6.25.6At least 50 percent of the rear-facing painted vertical surfaces, visible from the rear of the ambulance, shall be equipped with retroreflective striping in a chevron pattern sloping downward and away from the centerline of the vehicle at an angle of 45 degrees material .6.25.6.1

Each When chevrons are used, each stripe in the chevron shall be a single color alternating between red and either yellow, fluorescent yellow, or fluorescent yellow-green two high contrastcolors .


6.25.6.3

When Battenburg markings are used, each box shall be a single color alternating between two high contrast colors.


The task group is suggesting these changes as the back of an ambulance is configured differently than a fire truck. The AHJ has the authority to determine the design of all safety markings on the vehicle if not regulated by the state. Science has established that chevrons are not the only design that provides conspicuity. The intended desire in the existing standard to be consistent between fire & EMS may actually conflict with local culture and preferences. Scientific research and the FEMA study on conspicuity does not dictate one design or color pair, and the color red is highly inconspicuous during daylight and nighttime hours.








6.25.6 *At least 50 percent of the rear-facing vertical , painted vertical surfaces, visible from the rear of the ambulance, shall be equipped with retroreflective striping in material.

A.6.25.6 Retroreflective material included in the calculation includes any combination of graphics, lettering, a chevron pattern sloping downward and away from the centerline of the vehicle at an angle of 45 degrees orBattenburg markings .

6.25.6.1Each When chevrons are used, each stripe in the chevron shall be a single color alternating betweenred and either yellow, fluorescent yellow, or fluorescent yellow-greentwo high contrast colors .


6.25.6.3 When Battenburg markings are used, each box in theBattenburg markings shall be XX in 2 (XX mm 2 ).




The task group is suggesting these changes as the back of an ambulance is configured differently than a fire truck. The AHJ has the authority to determine the design of all safety markings on the vehicle. Science has established that chevrons are not the only design that provides conspicuity. The intended desire in the existing standard to be consistent between fire & EMS may actually conflict with local culture and preferences. Scientific research and the FEMA study on conspicuity does not dictate one design or color pair, and the color red is highly inconspicuous during daylight and nighttime hours.





6.25.6.1Each stripe in the The chevron pattern shall be a single color two colors alternating between red and either yellow, fluorescent yellow, or fluorescent yellow-green.


Clarification that it is two colors


Submitter Full Name: Aarron ReinertOrganization: Lakes Region EMSAffilliation: Chapter 6 taskgroupStreet Address: City:State: Zip: Submittal Date: Tue Jul 02 21:31:55 EDT 2013







6.25.6.1 Each stripe in the chevron shall be a single color alternating between red and either yellow, fluorescent yellow, or fluorescent yellow-green alternating color .


The AHJ should be allowed to determine what colors are acceptable for use in their state based on their state regulations.


Submitter Full Name: John McDonaldOrganization: US General Services AdministraStreet Address:City: State: Zip:Submittal Date: Wed Feb 20 22:15:29 EST 2013


I, John McDonald, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement ofProblem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am John McDonald, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature




6.25.6.2Each rear-facing stripe shall be 6 in. (150 mm) in width.


Clarification









6.28 * Oxygen — Main Supply and Installation.6.28.1

The ambulance shall have a piped medical oxygen system capable of supplying a minimum of 3000 L of medical oxygen.

6.28.2If a compressed gas cylinder is used, a cylinder-changing wrench shall be secured within the oxygen storage compartment.

6.28.3All oxygen system controls shall be accessible from inside the vehicle.

6.28.4An oxygen-capacity indicator shall be visible from the designated primary patient care seating position.

6.28.5The oxygen outlet shall be accessible from the designated primary patient care seating position.

6.28.6The purchaser shall specify the quantity and location of oxygen outlets.

6.28.7Oxygen system shall include the following:

(1) A pressure regulator

(2) Low pressure, electrically conductive hose and fittings approved for medical oxygen

(3) Oxygen piping that is concealed and not exposed to the elements, securely supported to prevent damage, and be readily accessible for inspection and replacement

(4) Oxygen that is piped to a self-sealing oxygen outlet with a minimum flow rate of 26.4 gpm (100 L/min) at the outlet

(5) Outlet(s) that is marked and identified and does not interfere with the suction outlet

6.28.8 Oxygen Pressure Regulator.6.28.8.1

The medical oxygen pressure reducing and regulating valve system shall be provided with the following features:

(1) An inlet filter at the cylinder

(2) A line relief valve set at 200 psi (1380 kPa) maximum

(3) A gauge or digital monitor with a minimum range of 0 psi to 2500 psi (0 kPa to 17,237 kPa) graduated in not more than 100 psi (690 kPa) increments

(4) A locking adjustment preset at 50 psi ± 2 psi (345 kPa ± 14 kPa) line pressure

6.28.8.2



The regulator shall meet the performance required by 6.28.8.3 at aninlet pressure range from 150 psi to 2500 psi (1034 kPa to 17,237kPa).

6.28.8.3With the regulator set at 50 psi ± 2 psi (345 kPa ± 14 kPa), a 26.4 gpm (100 L/min) minimum flow rate shall be available at all oxygen outlets.

6.28.9 Oxygen Tank Storage.6.28.9.1

Storage for the main oxygen cylinder shall be accessible for replacement from an outside position.

6.28.9.2The oxygen compartment shall be provided with at least 9 in.2 (580mm2) of open vent to dissipate or vent leaking oxygen to the outside of the ambulance.

6.28.9.3Oxygen cylinder compartment shall not be utilized for storage of any other equipment and shall be labeled “Oxygen Storage Only.”

6.28.10 Oxygen Tank Retention.6.28.10.1

Any oxygen tank holder shall withstand a force equal to 25 times the weight of a full tank for which the tank holder was designed.

6.28.10.2The oxygen tank holder components shall not fail or separate along attachment points.

6.28.10.3The oxygen tank holder or any component thereof shall not separate from the vehicle at any attachment point.

6.28.10.4The part of the vehicle to which the oxygen tank holder is attached shall not fail or separate at any attachment point.

6.28.10.5The simulated cylinder shall not disengage from the oxygen tank holder.

6.28.10.6Compliance of the oxygen tank retention shall be validated by testing a sample retention device using a substantially similar ambulance or body structure in accordance with Section 9.3.

6.28.11 Oxygen System Integrity.6.28.11.1The oxygen system of each ambulance shall be tested prior to delivery.6.28.11.1.1

The oxygen system shall lose no more than 5 psi (34 kPa) of pressure in a 2-hour period.

6.28.11.1.2Each outlet shall be capable of delivering at least 26.4 gpm (100 L/min) of oxygen.

6.28.11.1.3Compliance of the oxygen system integrity shall be validated by testing a sample system in a substantially similar ambulance in accordance with Section 9.15.

6.28.11.2A label shall be provided near the oxygen tank stating the following: “The integrity of this oxygen system was tested in accordance with NFPA 1917 and meets the requirements thereof.”



6.28.11.3The label shall be signed and dated by an authorized representative of the ambulance manufacturer or test agency.


A star (*) is added to the section title of 6.28. This is because a new annex item is recommended to be added.









6.28.1The Unless declined by the customer, the ambulance shall have a piped medical oxygen system capable of supplying a minimum of 3000L of medical oxygen.




Depending upon transport scenarios, customers sometimes elect to use portable oxygen cylinders rather than a piped oxygen system. This being a standard for a basic ambulance, it should not compel customers to pay for a piped oxygen system if such a system is not needed or used in their application.









6.28.7.1 Compliance of the oxygen system shall be validated by testing a sample substantially similar ambulance in accordance with Section 9.15 .2


provides a testing requirement and reference









6.28.8.4 Compliance of the oxygen system pressure regulator shall bevalidated by testing a sample retention device using a substantially similarambulance in accordance with Section 9.15 .1


Provides a testing requirement and standard









6.28.10.7 Tank weightsOXYGEN CYLINDERS D M H

Outside diameter (cm/inch) 11/4.5 18/7 23/9

Overall Heights, without valve (cm/inch) 51/20 119/47 142/56

Capacity (gallons) 95 800 1,825

Capacity (liters) 360 3,000 6,900

Capacity, flow @ 10 liters/min. (minutes) 30 325 700

Capacity (cubic feet) 13 106 244

Weight, empty (kg/pounds) 5.9/13 34/75 54/119

Weight, full (kg/pounds) 6.3/14 37.6/83 61.3/135


Provides a reference









6.28.12O2 and suction ports shall be within a maximum functional reach of 26.7 in. (678 mm) to the EMSPs with height as short as 59.3 in. (1506 mm) while seated and restrained.


Providing appropriate functional reach to essential devices, equipment, tools, or ports in the patient compartment can increase the efficiency of the working environment, and result in less time that the EMSP has to spend for obtaining their work needs. 02 and suction devices and ports are critically important to patient care and frequently useds and should be easily accessible by all EMSPs. The human factors practices in MIL-STD 1472G, Design Criteria Standard Human Engineering (January 2012), have provisions for functional reach. Table B-I, Standing Body Dimensions - General Forces, of MIL-STD 1472G addresses functional reachability ranges for different size demographics.








Public Input No. 257-NFPA 1917-2013 [ Section No. 6.28.11.1

[Excluding any Sub-Sections] ]

The oxygen system of each ambulance shall be leaked tested prior to delivery as required by Section 9 .15..


Clarification









6.28.11.1.2Each outlet shall be capable of delivering at least 26.4 gpm (100 L/min) of oxygen as required by 6 .28.8.3.


Clarification








Public Input No. 119-NFPA 1917-2013 [ Sections 6.28.11.1.2,

6.28.11.1.3 ]

Sections 6.28.11.1.2, 6.28.11.1.36.28.11.1.2Each outlet shall be capable of delivering at least 26.4 gpm (100 L/min) of

oxygen.6.28.11.1.3Compliance of the oxygen system integrity shall be validated by testing a

sample system in a substantially similar ambulance in accordance with Section 9.15 .

6.28.11.2 A label shall be provided near the oxygen tank stating the following: “The integrity of this oxygen system was tested in accordance with NFPA 1917 and meets the requirements thereof.”

6.28.11.3 The label shall be signed and dated by an authorized representative of the ambulance manufacturer or test agency.


Substantiation: The labeling requirements are prescribed by AMD Standard 015 Ambulance Main Oxygen System Test which are proposed for incorporation by reference pursuant to recommendations for section 2.3.7.









6.28.11.1.3Compliance of the oxygen system integrity shall be validated by testing a sample system in a substantially similar ambulance in accordance with Section 9.15 .


Duplication









6.28.11.1.3Compliance of the oxygen system integrity shall be validated by testinga sample system in a substantially similar the manufacturer by testing each individual ambulance in accordance with Section 9.15 .




I propose that third party testing be required for the aspects of the ambulance in which testing each individual vehicle to the particular standard or specifically required test would be impractical. This test should be performed by the manufacturer for each unit produced.









Sections 6.28.11.2, 6.28.11.36.28.11.2

A label shall be provided near the oxygen tank stating the following: “The integrity of this oxygen system was tested in accordance with NFPA 1917 and meets the requirements thereof.”



Substantiation: The labeling requirements are prescribed by AMD Standard 015 Ambulance Main Oxygen System Test which are proposed for incorporation by reference pursuant to recommendations for section 2.3.7.









Sections 6.28.11.2, 6.28.11.36.28.11.2




The labeling requirements are prescribed by AMD Standard 015 Ambulance Main Oxygen System Test which are proposed for incorporation by reference pursuant to recommendations for section 2.3.7.









Sections 6.28.11.2, 6.28.11.36.28.11.2






The labeling requirements are prescribed by AMD Standard 015 Ambulance Main Oxygen System Test which are proposed for incorporation by reference pursuant to recommendations for section 2.3.7.









6.29.1An When an electrically powered suction aspirator system shall befurnished is furnished, it shall meet the requirements of this section .




Customers are increasingly favoring portable suction units over permanently installed suction systems. It is inappropriate for a standard for a basic ambulance to compel customers to pay for equipment that they do not need or use.









6.29.9.3Compliance of the aspirator system shall be validated by testing a sample the manufacturer by testing each individual aspirator system installed in a substantially similar ambulance in accordance with Section 9.21 .













7.1.1.1When printed circuits are utilized, they shall conform to IPC A-610D 610E , “Acceptability of Electronic Assemblies.”


The IPC A-610E is the current document published 04/01/2010.


Submitter Full Name: Scott BraunOrganization: Braun Industries, Inc.Street Address: City:State: Zip: Submittal Date: Fri Jun 28 09:18:54 EDT 2013


I, Scott Braun, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I herebywarrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am Scott Braun, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature




7.1.1.2Printed circuit assemblies provided shall qualify under IPC A-610D,

“Acceptability of Electronic Assemblies,” Classification 1.4.1 as Class 2 “For Commercial and Industrial Assemblies” or better.

7.1.1.2 Printed circuit assemblies provided installed by the ambulancemanufacturer shall qualify under IPC A-610D, “Acceptability of Electronic Assemblies,” Classification 1.4.1 as Class 2 “For Commercial and Industrial Assemblies” 3 “Life Support or other critical assemblies” or better.


Substantiation: This revision is necessary as Class 3 High Performance Electronic Products includes products where continued high performance or performance-on-demand is critical, equipment downtime cannot be tolerated, end-use environment may be uncommonly harsh, and the equipment must function when required such as life support or other critical systems. The proposed language restores the caliber of the circuit assemblies as it has been established by the KKK specifications. A higher rate of failure is not acceptable in an ambulance.









7.1.1.2Printed circuit assemblies provided shall used in life saving systems shall qualify under IPC A- 610D 610E , “Acceptability of Electronic Assemblies,” Classification 1.4.1 as Class 2 “For Commercial and Industrial Assemblies” Classification 1.3 as Class 3 “High Performance Electronic Products” or better.


Per IPC A-610E, Class 3 circuits are defined as:Includes products where continued high performance or performance-on-demand is critical, equipment downtime cannot be tolerated, end-use environment may be uncommonly harsh, and the equipment must function when required, such as life support or other critical systems.

It is this authors opinion that the electrical control systems that supply power to systems such as suction, oxygen, etc., are performing critical life supporting operations.









7.1.1.2Printed circuit assemblies provided shall assemblies installed by the ambulance manufacturer shall qualify under IPC A-610D, “Acceptability of Electronic Assemblies,” Classification 1.4.1 as Class 2 “For Commercial and Industrial Assemblies” or Class 3 "Life Support or Other Critical Assemblies" or better.


This revision is necessary as Class 3 High Performance Electronic Products includes products where continued high performance or performance-on-demand is critical, equipment downtime cannot be tolerated, end-use environment may be uncommonly harsh, and the equipment must function when required such as life support or other critical systems. The proposed language restores the caliber of the circuit assemblies as it has been established by the KKK specifications. A higher rate of failure is not acceptable in an ambulance.









7.1.1.2Printed circuit assemblies provided shall qualify under IPC A-610D, “Acceptability of Electronic Assemblies,” Classification 1.4.1 as Class 2 “For Commercial and Industrial Assemblies” or better 3 "For life saving equipment" .




Current standard practice per KKK requires Class 3 for lifesaving equipment. NFPA 1917 should classify an ambulance as life saving euqipment as opposed to a commercial or industrial assembly. Passage of appropriate IPC A 610D Class 3 defnition included.









7.1.1.2Printed circuit assemblies provided installed by the ambulance manufacturer shall qualify under IPC A-610D, “Acceptability of Electronic Assemblies,” Classification 1.4.1 as Class 2 “ForCommercial and Industrial Assemblies” or 3 "Life Support or other critical assemblies” or better.




This revision is necessary as Class 3 High Performance Electronic Products includes products where continued high performance or performance-on-demand is critical, equipment downtime cannot be tolerated, end-use environment may be uncommonly harsh, and the equipment must function when required such as life support or other critical systems. The proposed language restores the caliber of the circuit assemblies as it has been established by the KKK specifications. A higher rate of failure is not acceptable in an ambulance.









7.1.1.3Printed circuit board connections and components shall conform to all other specification requirements.


There are no "other specification requirements" identified. Suggestion is to delete this item.









any Sub-Sections] ]

All electrical circuit feeder wiring supplied and installed by the ambulance manufacturer shall meet the requirements of 7.2.1.1 through 7.2.1.6.




All added conversion wiring should be copper conductor sized for 125% of the rated current load intended. Currently the passage only requires the feeder portion of the circuit to be copper. Current AMD and KKK standards require the use of copper wiring.









7.2.1.1 *The circuit feeder wire All conversion wiring shall be stranded copper or copper alloy conductors of a gauge rated to carry 125 percent of the maximum current for which the circuit is protected. [ 1901: 13.2.1]




All added conversion wiring should be copper conductor sized for 125% of the rated current load intended. Currently the passage only requires the feeder portion of the circuit to be copper. Current AMD and KKK standards require the use of copper wiring.









7.2.1.2Voltage drops in all wiring from the power source to the using device shall not exceed 0.5 volt. 5% of the nominal source voltage.




The industry standard allowance for voltage drop in a branch circuit is 5%. (Refer to the NEC, NFPA 70.) Specifying a lower allowed voltage drop will in some cases necessitate the use of larger conductors.There is no justification for this ambulance standard to deviate from standard industry practice in a way that compels higher cost to the customer for unnecessarily large conductor.The issue should be resolved by changing the allowable drop to 5% of the source voltage.









7.2.1.3The use of star washers for circuit ground connections shall not be

permitted. [ 1901: 13.2.1.2]

7.2.1.3 The use of star washers for circuit ground connections shall not be permitted. [ 1901: 13.2.1.2]


Substantiation: The task group is suggesting this change as this type of lock washer is specifically required by some chassis manufacturers and QVM.









7.2.1.3The use of star washers for by the final stage manufactuer for circuit ground connections shall not be permitted. [ 1901: 13.2.1.2]


Some chassis manufacturers utilize star washers in their manufacturing process. The original statement would require that those chassis would not be allowed, or those connections would require replacement.









7.2.1.3The use of star washers for circuit ground connections shall not be permitted. [ 1901: 13.2.1.2]


The task group is suggesting this change as this type of lock washer is specifically required by some chassis manufacturers and QVM.













7.2.1.3 Star washers for grounding not permitted - KKK and AMD require the use of star washers for grounding. (I don't know which train of thought is correct), I checked OEM grounding and found that Mercedes-Benz is using star washers in multiple locations. Ford, GM, Chrysler, and International don't use star washer but are using some terminal ends that have the same style serrations made into the terminal as a traditional star washer.













The task group is suggesting this change as this type of lock washer is specifically required by some chassis manufacturers and QVM.









7.2.1.5Only electrical components directly , such as transducers, O2 solenoids, lifts, compartment lighting, and door sensors, directly related to the delivery of on-board oxygen shall terminate in the oxygen storage compartment.


Lighting and door sensors are a requirement of 7.11.7.1 and should not be excluded from this compartment. Electric oxygen lifts are a signifiant benefit to operator safety when changing oxygen tanks and properly designed and protected systems should be allowed.









7.2.1.5Only the required interior light and electrical components directly related to the delivery of on-board oxygen shall terminate in the oxygen storage compartment.




7.2.1.5 No electrical items in 02 compartment other than 02 equipment. Does this include the 02 compartment lighting?










All insulated wire and cable shall conform to SAE J1127, Low Voltage BatteryCable, or SAE J1128, Low Voltage Primary Cable, type SXL, GXL, or TXL. [1901:13.2.2.1]

7.2.2.1 All insulated wire and cable shall conform to SAE J1127, Low Voltage Battery Cable, or SAE J1128, Low Voltage Primary Cable, type SXL , or GXL , or TXL . [ 1901: 13.2.2.1]


Substantiation: TXL is an inferior wire compared to the current requirements in the KKK standard which is SXL or GXL. The insulation thickness on SXL is .037, GXL is .023 and TXL is .016.










All insulated wire and cable shall conform to SAE J1127, Low Voltage BatteryCable, or SAE J1128, Low Voltage Primary Cable, type SXL , or GXL, or TXL . [ 1901: 13.2.2.1]


TXL is an inferior wire compared to the current requirements in the KKK standard which is SXL or GXL. The insulation thickness on SXL is .037, GXL is .023 and TXL is .016.










All insulated wire and cable shall conform to SAE J1127, Low Voltage BatteryCable, or SAE J1128, Low Voltage Primary Cable, type SXL , GXL, or TXL. [ 1901: 13.2.2.1] GXL.




TXL is an inferior wire compared to the current requirements in the KKK standard which is SXL or GXL. The insulation thickness on SXL is .037, GXL is .023 and TXL is .016.









7.2.2.1.2Conductor materials and stranding, other than copper, shall be permitted if

all applicable requirements for physical, electrical, and environmental conditions are met as dictated by the end application. [ 1901: 13.2.2.1.2]

7.2.2.1.2 Conductor materials and stranding, other than copper, shall be permitted if all applicable requirements for physical, electrical, and environmental conditions are met as dictated by the end application. [ 1901: 13.2.2.1.2] All wiring provided by the FSAM shall be copper.


Substantiation: This change is being made as copper conductors are more reliable and efficient than aluminum, etc (that is why they quit wiring houses with aluminum) and the connections don't require special methods that aluminum does. This is also to address concerns of safety and that copper wire is the safest.









7.2.2.1.2Conductor materials and stranding, other than copper, shall be permitted if all applicable requirements for physical, electrical, andenvironmental conditions are met as dictated by the end application. [ 1901: 13.2.2.1.2]All wiring provided by the FSAM shall be copper.


This change is being made as copper conductors are more reliable and efficient than aluminum, etc (that is why they quit wiring houses with aluminum) and the connections don't require special methods that aluminum does. This is also to address concerns of safety and that copper wire is the safest.









7.2.2.1.2Conductor materials and stranding, other than copper, shall be permitted if all applicable requirements for physical, electrical, and environmental conditions are met as dictated by the end application. [ 1901: 13.2.2.1.2]




7.2.2.1.2 contradicts this passage allowing stranding other than copper (possibly I am misinterpreting what is being directed). All added conversion wiring should be copper conductor sized for 125% of the rated current load intended. Currently the passage only requires the feeder portion of the circuit to be copper. Current AMD and KKK standards require the use of copper wiring.









7.2.2.1.2Conductor materials and stranding, other than copper, shall be permitted if all applicable requirements for physical, electrical, andenvironmental conditions are met as dictated by the end application. [ 1901: 13.2.2.1.2]All wiring provided by the FSAM shall be copper.




This change is being made as copper conductors are more reliable and efficient than aluminum, etc (that is why they quit wiring houses with aluminum) and the connections don't require special methods that aluminum does. This is also to address concerns of safety and that copper wire is the safest.









7.2.2.2The overall covering of conductors shall be moisture-resistant loom or braid that has a minimum continuous rating of 194°F (90°C) except of 300° F (149° C) except where good engineering practice dictates special consideration for loom installations exposed to higher temperatures. [ 1901: 13.2.2.2]


Loom of higher heat resistance offers increased protection specifically in engine compartments and frame routing and is the current minimum requirement for GSA.









7.2.2.2The overall covering of conductors shall be moisture-resistant loom or braid that has a minimum continuous rating of 194°F (90°C) 300°F except where good engineering practice dictates special consideration for loom installations exposed to higher temperatures. [ 1901: 13.2.2.2]




7.2.2.2 Loom 194 degree rated, KKK is 300 degree rated. Many ambulances are now gasoline or DEF equipped diesels with highter temperature ranges than the older diesel units. 1000 degree or higher shielding is commonly used near the engine and exhaust. To minimize the established standard may not be viewed as a positive step.









Sections 7.2.2.2, 7.2.2.37.2.2.2The overall covering of conductors shall be moisture-resistant loom or braid

that has a minimum continuous rating of 194°F (90°C) except where good engineering practice dictates special consideration for loom installations exposed to higher temperatures. [ 1901: 13.2.2.2]

7.2.2.3The overall covering of jacketed cables shall be moisture resistant and have

a minimum continuous temperature rating of 194°F (90°C), except where good engineering practice dictates special consideration for cable installationsexposed to higher temperatures. [ 1901: 13.2.3]

7.2.2.2 The overall covering of conductors shall be moisture-resistant loom or braid that has a minimum continuous rating of 194 300°F ( 90 149 °C) except where good engineering practice dictates special consideration for loom installations exposed to higher temperatures . [ 1901: 13.2.2.2]

7.2.2.3 The overall covering of jacketed cables shall be moisture resistant and have a minimum continuous temperature rating of 194 300°F( 90 149 °C) , except where good engineering practice dictates special consideration for cable installations exposed to higher temperatures . [ 1901: 13.2.3]


Substantiation: The current KKK standard requires a 300 degree insulation covering and reducing that to 194 degrees increases the chance of high heat related issues with various harnesses within the ambulance upfit especially those in the engine compartment.








Sections 7.2.2.2, 7.2.2.37.2.2.2

The overall covering of conductors shall be moisture-resistant loom or braid that has a minimum continuous rating of 194°F300°F ( 90°C) except where good engineering practice dictates special consideration for loom installations exposed to higher temperatures. [ 1901: 13.2.2.2] 149°C).

7.2.2.3The overall covering of jacketed cables shall be moisture resistant and have a minimum continuous temperature rating of 194°F300°F ( 90°C), except where good engineering practice dictates special consideration for cable installations exposed to higher temperatures. [ 1901: 13.2.3] 149°C).


The current KKK standard requires a 300 degree insulation covering and reducing that to 194 degrees increases the chance of high heat related issues with various harnesses within the ambulance upfit especially those in the engine compartment.









Sections 7.2.2.2, 7.2.2.37.2.2.2

The overall covering of conductors shall be moisture-resistant loom or braid that has a minimum continuous rating of 194°F300°F ( 90°C) except where good engineering practice dictates special consideration for loom installations exposed to higher temperatures. [ 1901: 13.2.2.2] 149°C).

7.2.2.3The overall covering of jacketed cables shall be moisture resistant and have a minimum continuous temperature rating of 194°F300°F ( 90°C), except where good engineering practice dictates special consideration for cable installations exposed to higher temperatures. [ 1901: 13.2.3] 149°C).




The current KKK standard requires a 300 degree insulation covering and reducing that to 194 degrees increases the chance of high heat related issues with various harnesses within the ambulance upfit especially those in the engine compartment.






7.2.2.3The overall covering of jacketed cables shall be moisture resistant and have a minimum continuous temperature rating of 194°F (90°C) 300°F , except where good engineering practice dictates special consideration for cable installations exposed to higher temperatures. [ 1901: 13.2.3]




7.2.2.3 Loom 194 degree rated, KKK is 300 degree rated. Many ambulances are now gasoline or DEF equipped diesels with highter temperature ranges than the older diesel units. 1000 degree or higher shielding is commonly used near the engine and exhaust. To minimize the established standard may not be viewed as a positive step.









7.2.2.7Connections at exterior lights and fixtures shall utilize sealed connectors or

sealed splices.

7.2.2.7 Exterior C c onnections at exterior for lights and fixtures shall utilize sealed connectors or sealed splices.


Substantiation: There is no reason for the increased expense of exterior sealed connectors on devices where the connector is inside the patient compartment. The logical intent is to ensure that all connections that are potentially exposed to moisture are properly protected against moisture. Many exterior light connections are interior connections that are not exposed to moisture and therefore do not need such protection. Conversely, there are connections for devices other than exterior lights and fixtures that are exterior connections that do need to utilize sealed connectors or sealed splices.









7.2.2.7Connections at Connectors, exposed to the elements, of exteriorlights and fixtures shall utilize sealed connectors or sealed splices.


Sealed connectors for exterior lights or devices that are not exposed to exterior environments add unnecessary complexity and cost.









7.2.2.7Connections at exterior Exterior connections for lights and fixtures shall utilize sealed connectors or sealed splices.


There is no reason for the increased expense of exterior sealed connectors on devices where the connector is inside the patient compartment. The logical intent is to ensure that all connections that are potentially exposed to moisture are properly protected against moisture. Many exterior light connections are interior connections that are not exposed to moisture and therefore do not need such protection. Conversely, there are connections for devices other than exterior lights and fixtures that are exterior connections that do need to utilize sealed connectors or sealed splices.









7.2.2.7Connections Exterior connections at exterior lights and fixtures shall utilize sealed connectors or sealed splices.




7.2.2.7 Connections at exterior lights shall utilize sealed connectors. (I assume the intent is actually exterior connections for lighting). Many of the ambulance body lights actually have the connection made inside the vehicle. Interior connections would not benefit from sealed connectors and would add unnecessary expense. Other exterior lighting should have sealed connectors because the connection is made outside of the body.









7.2.2.7Connections at exterior Exterior connections for lights and fixtures shall utilize sealed connectors or sealed splices.




There is no reason for the increased expense of exterior sealed connectors on devices where the connector is inside the patient compartment. The logical intent is to ensure that all connections that are potentially exposed to moisture are properly protected against moisture. Many exterior light connections are interior connections that are not exposed to moisture and therefore do not need such protection. Conversely, there are connections for devices other than exterior lights and fixtures that are exterior connections that do need to utilize sealed connectors or sealed splices.









7.3.1A 12 volt or greater An electrical alternator (s) of proper voltage and output rating shall be provided. [ 1901: 13.3.1]


Clarification and prevention of use of a 12v alternator in an 24v or 36v application.









7.3.2 * Low Idle Alternator Output.7.3.2.1The alternator shall have a minimum output at low idle to meet the minimum

electrical load test conditions of the ambulance between 60°F and 110°F (15°C and 43°C) ambient temperature.

7.3.2.1.1Minimum electrical load test conditions, which are tested under low-idle

conditions, shall consist of the following:

(1) The propulsion engine and transmission

(2) All legally required clearance and marker lights, headlights, and other electrical devices except windshield wipers and four-way hazardflashers

(3) The radio(s) at a duty cycle of 10-percent transmit and 90-percent receive (for calculation and testing purposes, a default value of 5 amperes continuous)

(4) Cab air conditioning (at coldest setting with highest blower speed)

(5) Patient compartment air conditioning (at coldest setting with highest blower speed)

(6) The lighting necessary to illuminate walking surfaces at entry points

7.3.2.2Compliance of the minimum electrical load test conditions shall be

validated by testing a substantially similar ambulance in accordance with 9.5.3.3 .

7.3.2* Low Idle Alternator Output.7.3.2.1 The alternator shall have a minimum output at low idle to meet

the minimum electrical load test conditions of the ambulance between 60°F and 110°F (15°C and 43°C) ambient temperature.

7.3.2.1.1 Minimum electrical load test conditions, which are tested under low-idle conditions, shall consist of the following:

(1) The propulsion engine and transmission(2) All legally required clearance and marker lights, headlights, and

other electrical devices except windshield wipers and four-way hazardflashers




(6) The lighting necessary to illuminate walking surfaces at entrypoints



7.3.2.2 Compliance of the minimum electrical load test conditions shall be validated by testing a substantially similar ambulance in accordance with9.5.3.3 .


Substantiation: This change is being suggested as current and next year commercial ambulance chassis cannot meet this requirement and upgrading the alternator is infeasible. The requirement in sections 5.4 and 7.5.3 for a high idle function both acknowledges and accommodates this reality.









7.3.2 * Low Idle Alternator Output.7.3.2.1

The alternator shall have a minimum output at low idle to meet the minimum electrical load test conditions of the ambulance between 60°F and 110°F (15°C and 43°C) ambient temperature.

7.3.2.1.1Minimum electrical load test conditions, which are tested under low-idle conditions, shall consist of the following:


(2) All legally required clearance and marker lights, headlights, and other electrical devices except windshield wipers and four-way hazard flashers

(3) The radio(s) at a duty cycle of 10-percent transmit and 90-percent receive (for calculation and testing purposes, a default value of 5amperes continuous)




7.3.2.2Compliance of the minimum electrical load test conditions shall be validated by testing a substantially similar ambulance in accordance with 9.5.3.3 .


This change is being suggested as current and next year commercial ambulance chassis cannot meet this requirement and upgrading the alternator is infeasible. The requirement in sections 5.4 and 7.5.3 for a high idle function both acknowledges and accommodates this reality.







7.3.2* Low Idle Alternator Output

.

7.3.2.1


7.3.2.1.1Minimum electrical load test conditions, which are

tested under low-idle conditions, shall consist of the following:


(2) All legally required clearance and marker lights, headlights, and other electrical devices except windshield wipers and four-way hazardflashers





7.3.2.2Compliance of the minimum electrical load test

conditions shall be validated by testing a substantially similar ambulance in accordance with 9.5.3.3 .






7.3.2 Low idle alternator output requirement. Most OEM alternators will not meet the output demand at idle. Annex item 7.3.2 already states this problem. I think this requirement should be deleted because it is not practical to risk OEM warranty coverage and possible end user reliability due to removing and replacing OEM alternators.









7.3.2 * Low Idle Alternator Output.7.3.2.1




(2) All legally required clearance and marker lights, headlights, and other electrical devices except windshield wipers and four-way hazard flashers

(3) The radio(s) at a duty cycle of 10-percent transmit and 90-percent receive (for calculation and testing purposes, a default value of 5amperes continuous)








This change is being suggested as current and next year commercial ambulance chassis cannot meet this requirement and upgrading the alternator is infeasible. The requirement in sections 5.4 and 7.5.3 for a high idle function both acknowledges and accommodates this reality.






(1) The propulsion engine and transmission(2) All legally required clearance and marker lights, headlights, and

other electrical devices except windshield wipers and four-way hazard flashers


(4) Cab air conditioning (at coldest setting with highest blowerspeed)


(6) The lighting necessary to illuminate walking surfaces at entrypoints










7.3.2.2Compliance of the minimum electrical load test conditions shall be validated by testing a substantially similar each ambulance in accordance with 9.5.3.3 .


Testing of each ambulance as opposed to a substantially similar ambulance ensures each ambulance is operational and configured properly.









7.3.4.1The alternator shall have a minimum output at high idle to power the operational electrical load test conditions between 60°F and 110°F (15°C and 43°C) ambient temperature .




7.3.4.1 High idle test at ambient temperature 60°F to 110°F - 9.5.2 requires the same temperature. (This will require indoor testing facilities for manufacturer during winter months is that the intention?)









7.3.4.2Compliance of the high-idle alternator output shall be validated by testing a substantially similar each ambulance in accordance with 9.5.3.4 .











7.3.4.2Compliance of the high-idle alternator output shall be validated by testing a substantially similar ambulance the manufacturer on each unit produced in accordance with 9.5.3.4 .




The alternator testing needs to be verified by the manufacturer on each unit produced prior to the vehicle being placed into service.









7.4.2If the ambulance is equipped to tow a trailer, an additional 45 amperes shall be added to the minimum continuous electrical load to provide electrical power for the federally required clearance and marker lighting and the optical warning devices mounted on the trailer.


Ambulances should not be utilized as towing devices as the towed device would hinder the mission of the ambulance by blocking the rear doors.









7.4.2If the ambulance is equipped to tow a trailer, an additional 45 20 amperes shall be added to the minimum continuous electrical load to provide electrical power for the federally required clearance and marker lighting and the optical warning devices mounted on the trailer.




The 45-amp requirement of this section far exceeds the actual load for a fully-compliant trailer. In the same way that this ambulance standard should specify minimum requirements for a basic ambulance, electrical load allowance for a trailer should be based upon a realistic, basic trailer rather than a worst case trailer electrical load. Typical load requirements for an FMVSS-compliant trailer would total less than 15 amperes as shown below.The electrical load allowance for a trailer should be reduced to 20 amperes (which provides a 7A or 35% capacity margin).

Light Description and Quantity Total Electrical LoadTail Lamps, 2 ea @ 0.03A = 0.06AStop Lamps, 2 ea @ 0.38A = 0.76ATurn Lamps, 2 ea @ 0.38A = 0.76ALicense Plate Lamp, 1 ea @ 0.5A = 0.50ARear Side Marker Lamps, 2 ea @ 0.05A = 0.10AFront Side Marker Lamps, 2 ea @ 0.05A = 0.10ARear Clearance Lamps, 2 ea @ 0.05A = 0.10ARear Identification Lamps, 3 ea @ 0.05A = 0.15AFront Clearance Lamps, 2 ea @ 0.05A = 0.10ASide Flashers, 4 ea @ 0.60A = 2.40ARear Flashers, 2 ea @ 0.60A = 1.20ADome lights, 4 ea @ 1.5A = 6.00A

Total of all above loads = 12.23A

Reference to FMVSS 108 lighting requirements for trailers: http://www.nhtsa.gov/cars/rules/standards/conspicuity/trlrpstr.html






7.4.3.2.2Compliance of the voltage alarm shall be validated by testing a substantially similar ambulance in accordance with 9.5. 3 4 .


The reference to in 7.4.3.2.2 to section 9.5.3 is incorrect, the Low voltage alarm testing is section 9.5.4


Submitter Full Name: STEPHEN WILDEOrganization: Certified Fleet Services, Inc.Affilliation: EVT CERTIFICATION COMM INCStreet Address:City: State: Zip:Submittal Date: Thu Apr 11 12:05:35 EDT 2013


I, STEPHEN WILDE, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement ofProblem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am STEPHEN WILDE, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature




7.4.3.2.2Compliance of the voltage alarm shall be validated by testing asubstantially similar every ambulance in accordance with 9.5.3 .











7.4.3.2.2Compliance of the voltage alarm shall be validated by testing a substantially similar ambulance the manufacturer for each unit produced in accordance with 9.5.3 .




Each individual unit should be tested prior to placing the unit into service. THe testing sequence of 9.5.3 needs to be modified to eliminate the unnecessary idle testing listed in passages 9.5.3.3.7.4.3.2.2 Voltage alarm, I think this needs to be tested on every vehicle not type tested.









7.5.3.1An engine speed auxiliary control device (high-idle switch or throttle) shall be installed to allow an increase in the engine speed when the , not to exceed the chassis manufacturer's recommendations or a maximum of 1,600 RPM, when the ambulanceis parked.


Extended operation of an engine at elevated idle in order to comply with this section outside of the manufacturer's recommendations could shorten the life of the engine.









7.5.3.1An engine speed auxiliary control device (high-idle switch or throttle) shall be installed to allow an that will increase in theengine speed to between 1500 and 1600 RPM when the ambulance is parked.




7.5.3.1 Maximum RPM must be established. Next KKK revision may recomend 1600 RPM currently 1500 RPM. This is consistent with the RPM regulation already mandated in 9.12 (16) and (26).









7.6.7 *A master load disconnect shall be provided between the startersolenoid(s) main power source and the patient compartment electricalloads.


Requiring that power must be taken from the starter solenoid is not a recommended practice by some chassis manufacturer's and is not necessary when wiring can directly be connected to the battery system.









7.6.8.1The starter solenoids shall be connected directly to the chassis batteries.


This should be a chassis manufacturer's engineering determination not a minimum requirement for an ambulance specification.









7.6.9 The alternator shall be wired directly to the batteries through the ammeter shunt(s), if one is provided, and not through the master Delete or

Alternators shall not be wired through the master load disconnect switch.

[ 1901: 13.4.6.3]


Ammeter shunts, as opposed to a more modern Hall-effect sensor, should not be a requirement for taking amp readings of an alternator if requested. Alternators should not be required to be wired directly to batteries as many chassis manufacturers wire them to power distribution centers.









any Sub-Sections] ]

Two automotive power point type connectors shall be furnished in the patient compartment for charging all portable battery–powered devices (e.g., suction units, hand lights, defibrillators, and portable radios).


The word "all" over reaches the intention of the requirement for the two outlets.









7.6.12An additional tagged, identified lead shall be furnished in both the cab and the module for connection of additional (future) portable equipment that requiresrecharging.


Without a defined load, prewiring for any unknown device is unsafe and can not be designed to ensure proper breaker size or 125% of the rated capacity. or Define the maximum amperage load of the prewire, i.e. 20 Amps.









7.6.12An additional A 15 amp tagged, identified lead shall be furnished in both the cab and the module for connection of additional (future) portable equipment that requires recharging .




7.6.12 additional lead for portable equipment. We need to determine the amperage requirement.









7.9.3.2The four zones shall be designated A, B, C, and D in a clockwise direction, with zone A to the front of the ambulance, as shown in Figure 7.9.3.2 .Figure 7.9.3.2 Warning Zones for Optical Warning Devices.


Suggestion to use an image of an ambulance as opposed to a fire truck or rescue.









7.9.7.1When the master optical warning system switch is closedenabled and the parking brake is released or the automatic transmission is not in park, the warning devices signaling the call for the right-of-way shall be energized. [ 1901: 13.8.7.1]


Clarification to aid in interpretation.









7.9.7.2When the master optical warning system switch is closedenabled and the parking brake is on or the automatic transmission is in park, the warning devices signaling the blockage of the right-of-way shall be energized. [ 1901: 13.8.7.2]


Clarification to aid in interpretation.









7.9.10 *The optical sources on each level shall be of sufficient number and arranged so that failure of a single optical source does not create a measurement point in any zone on the same level as the failed optical source without a warning signal at a distance of Failure of a single optical device should not impede the visibility of the vehicle at 100 ft (30 m) from the geometric center of the ambulance.


Simplified requirement. Originally stated, it appears that an additional warning device/signal is required to identify if an optical source has failed.










The minimum flash rate of any optical source shall be 75 flashes per minute, and the minimum maximum number of flashes at any measurement point shall be 150 flashes per minute. [1901:13.8.11.1]




Correct typo.









7.9.11.1.2The Only the optical energy provided by nonflashing optical sources shall not the warning light should be included in the calculations of the zone's total optical power. [ 1901: 13.8.11.1.2]


Clarification.









7.9.11.2The flasher of any current-interrupted flashing device shall otherwise meet the requirements of SAE J1690, Flashers. [ 1901: 13.8.11.2]


SAE J1690 is not current with today's more common lightheads with integrated flashing circuitry.

“The SAE J1690 document assumes the flasher is external to the light and does not address if the flashers are integral to the light. This document has not been updated since 1996, and has not kept pace with many lightheads now incorporating internal flash circuitry.”Source - http://autoparts-standard.org/index/images/userfiles/media/SAE J887-2011.pdf









7.9.12.1Permissible colors or combinations of colors in each zone, within the constraints imposed by applicable laws and regulations, shall be as shown in Table 7.9.12.1 . [ 1901: 13.8.12.1]Table 7.9.12.1 Zone Colors

Color Calling for Right-of-Way Blocking Right-of-WayRed Any zone Any zoneBlue Any zone Any zoneYellowAmber Any zone except A Any zoneWhiteClear Any zone except C Not permitted

[ 1901: Table 13.8.12.1]


There are several references to Clear and Amber lights in section 7.9.17.2, 7.9.17.2.3, 7.9.17.2.5, and figure 7.9.17.2.1. the committee needs to decide on which terminology to use.









7.9.17.1.2The ambulance standard warning light system shall not impose a continuous average electrical load exceeding 40 amperes at 14.2 volts.


A maximum ampere limit should not be imposed if the vehicle is designed for and capable of supporting the necessary load.










The ambulance standard emergency warning light system shall contain 12 fixed red lights, 1 fixed clear fixed white light, and 1 or more fixed amber fixed yellow light(s).


In Table 7.9.12.1 the word yellow and white are used and in section 7.9.12.2 the word yellow and white are used. The committee needs to decide what Terminology to use.



Yellow and white are used instead of amber and clear.








Public Input No. 49-NFPA 1917-2013 [ Section No. 7.9.17.2.3.1 ]

7.9.17.2.3.1If due to limited body dimensions and physical size of the outboard forward-facing lights, the lights shall also may alternatively be mounted in dedicated housings on the cab roof.


Clarification









7.9.17.2.7The lateral-facing intersection lights shall be mounted as close as possible to the front upper edge of each front fender and shallmay be able angled forward up to be angled forward a maximum maximum of 30 degrees.


Clarification









7.10.3Audible warning equipment shall not be mounted on the roof , front of the module, or behind the ambulance operator .


Audible warning devices above or behind the vehicle operator could impare the hearing of the vehicle operator and create long term hearing damage.









7.11.3.4Load lights shall turn on whenever the rear patient entry doors areopened , battery disconnect switch is enabled, and module power is on .


Clarification. Currently stated, the lights would be hot at all times and could potentially drain the vehicle batteries.









7.11.4.2The lower front and rear side marker lights shall flash in conjunction with the directional signals.




This would require modifying the OEM flashing systems that are already FMVVS compliant. Chrysler and International will operate as currently written in this passage. Ford, GM, and Mercedes-Benz will not comply as the front marker lights and the turn signal are separate bulbs and do not flash in conjunction. Mercedes rear lights are also independent.









7.11.5 Ground Lighting.7.11.5.1The ambulance shall be equipped with lighting that is capable of providing

illumination at a minimum level of 0.3 fc on ground areas within 30 in. (800 mm) of the edge of the ambulance in areas designed for personnel to climb into or onto the ambulance or descend from the ambulance to the groundlevel.

7.11.5.2Lighting designed to provide illumination on areas under the driver and crew

riding area exits shall be switchable but activated automatically when the exit doors are opened.

7.11.5.3All other ground area lighting shall be switchable.

7.11.5 Ground Lighting.7.11.5.1 The ambulance shall be equipped with lighting that is capable

of providing illumination at a minimum level of 0.3 fc on ground areas within 30 in. (800 mm) of the edge of the ambulance in areas designed for personnel to climb into or onto the ambulance or descend from the ambulance to the ground level.

7.11.5.2 Lighting designed to provide illumination on areas under the driver and crew riding area exits shall be switchable but activated automatically when the exit doors are opened.

7.11.5.3 All other ground area lighting shall be switchable.


Substantiation: It is believed that this should either be moved to the annex or deleted as they believe that existing exterior and scene lighting provides sufficient illumination for the vast majority of ambulance applications. If desired, annex information could prompt consideration of ground lighting for ambulances that regularly operate in areas with little or no ambient illumination. Given the option, most customers elect not to add ground lighting.







7.11.5 Ground Lighting.7.11.5.1

The ambulance shall be equipped with lighting that is capable of providing illumination at a minimum level of 0.3 fc on ground areas within 30 in. (800 mm) of the edge of the ambulance in areas designed for personnel to climb into or onto the ambulance or descend from the ambulance to the ground level.

7.11.5.2Lighting designed to provide illumination on areas under the driver and crew riding area exits shall be switchable but activated automatically when the exit doors are opened.



This should either be moved to the annex or deleted; existing exterior and scene lighting provides sufficient illumination for the vast majority of ambulance applications. If desired, annex information could prompt consideration of ground lighting for ambulances that regularly operate in areas with little or no ambient illumination. Given the option, most customers elect not to add ground lighting.









7.11.5 Ground Lighting.7.11.5.1

The ambulance shall be equipped with lighting that is capable of providing illumination at a minimum level of 0.3 fc on ground areas within 30 in. (800 mm) of the edge of the ambulance in areas designed for personnel to climb into or onto the ambulance or descend from the ambulance to the ground level.

7.11.5.2Lighting designed to provide illumination on areas under the driver and crew riding area exits shall be switchable but activated automatically when the exit doors are opened.





It is believed that this should either be moved to the annex or deleted as they believe that existing exterior and scene lighting provides sufficient illumination for the vast majority of ambulance applications. If desired, annex information could prompt consideration of ground lighting for ambulances that regularly operate in areas with little or no ambient illumination. Given the option, most customers elect not to add ground lighting.








7.11.6.1 *The ambulance shall have sufficient lighting to provide an average level of 1

fc at each seating surface in the driving compartments.

7.11.6.1* If not equipped with an OEM dome light, T the ambulance FSAM shall have install sufficient lighting to provide an average level of 1 fc at each seating surface in the driving compartments.


Substantiation: The majority of all ambulance chassis are equipped with OEM door activated dome lights. Any additional driver compartment lighting requirements should be the purchaser’s decision.









7.11.6.1 *The ambulance shall have If not equipeed with an OEM dome light, the FSAM shall install sufficient lighting to provide an average level of 1 fc at each seating surface in the driving compartments.


The majority of all ambulance chassis are equipped with OEM door activated dome lights. Any additional driver compartment lighting requirements should be the purchaser’s decision.









7.11.6.1 *The ambulance shall have If not equipped with an OEM dome light, the FSAM shall install sufficient lighting to provide an average level of 1 fc at each seating surface in the driving compartments.




The majority of all ambulance chassis are equipped with OEM door activated dome lights. Any additional driver compartment lighting requirements should be the purchaser’s decision.









7.11.6.3.2Any lighting circuit shall not consume more than 25 amperes and shall have separately protected and controlled circuits.


If a lighting circuit is properly designed and the vehicle electrical system is capable of supporting it, it should not have a maximum limit.









7.11.6.3.3All interior lighting fixtures, excluding overhead lights, shall not protrude more than 1 1⁄2 in. (38 mm) from the mounting surface. Overhead lights shall be recessed to eliminate a striking hazard.


Intrusions into the working environment can come across as obstructions and striking hazards for individuals in the patient compartment. Taking steps to avoid such cases is necessary, as they can either cause injuries through coming into inadvertent contact with them or decrease working efficiency for the EMSP. Having this in mind, overhead lights should also be required to be recessed so that they don’t pose as a striking hazard.








Public Input No. 159-NFPA 1917-2013 [ Section No. 7.11.6.3.4


7.11.6.3.4 The patient compartment lighting system shall have the two levels of lighting, high and low, at a minumum include the capability to dim thelights .


Proper, suitable lighting conditions are necessary for EMSPs to perform their operations. The amount of lighting an EMSP needs may differ from one situation to another. With the capability to dim lights, EMSPs can adjust the lights to brightness levels that is suitable for their working conditions.









7.11.6.3.5The patient compartment lighting shall be automatically activated in the low setting when the side entry or rear entry patient compartment doors are opened , battery disconnect switch is enabled, and the module power is on .


Clarification. Currently stated, these lights would be hot all the time and could unintentionally drain the batteries if the door was left open.









7.11.7.1Each exterior compartment used for Oxygen storage, enclosedtool and equipment compartment , or equipment storage that is greater than 4 ft 3 (0.1 m 3 ) in volume and having an opening greater than 144 in. 2 (92,900 mm 2 ) shall have sufficient compartment lighting to provide a minimum of 1 fc at any location on the floor of the compartment without any shelves, dividers, or equipment in thecompartment.




7.11.7.1 Compartment lighting reference needs clarification.7.2.1.5 requires modification to include a light.









7.11.7.2Switches for all compartment Compartment lighting shall be automatically enabled when the compartment door is opened, battery disconnect switch is enabled, and module power is on; or a switch should be readily accessible by the operator .


Clarification. Allows for automation and identifies whom the switch is accessible by.









7.12.1 *A red flashing or rotating light or electronic display within the forward view of

the driver shall be illuminated automatically whenever the ambulance's ignition switch is in the run position, the parking brake is not fully engaged, and any of the following conditions exist:

(1) Any passenger, patient entry, or equipment compartment door is notclosed.

(2) Any equipment rack is not in the stowed position.

(3) Any other device permanently attached to the ambulance is open, extended, or deployed in a manner that is likely to cause damage to the ambulance if the ambulance is moved.

7.12.1* A red flashing or rotating light or electronic display within the forward view of the driver shall be illuminated automatically whenever the ambulance's ignition switch is in the run position, the parking brake is not fully engaged, and any of the following conditions exist:

(1) Any passenger, patient entry, or equipment compartment door is not closed.(2) Any external equipment rack is not in the stowed position.(3) Any other device permanently attached to the ambulance is open,

extended, or deployed in a manner that is likely to cause damage to the ambulance if the ambulance is moved.


Substantiation: Internal equipment may or may not be stowed while the ambulance is being driven based on patient care demands and AHJ policies. An electronic display in the view of the driver in these cases is an unnecessary distraction.








7.12.1 *A red flashing or rotating light or electronic display within the forward view of the driver shall be illuminated automatically whenever the ambulance's ignition switch is in the run position, the parking brake is not fully engaged, and any of the following conditions exist:

(1) Any passenger, patient entry, or equipment compartment door is not closed.

(2) Any exterior equipment rack is not in the stowed position.



Internal equipment may or may not be stowed while the ambulance is being driven based on patient care demands and AHJ policies. An electronic display in the view of the driver in these cases is an unnecessary distraction to the driver which poses a safety hazard.











(2) Any equipment rack is not in the stowed position.Any

(3) other device permanently attached to the ambulance is open, extended, or deployed in a manner that is likely to cause damage to the ambulance if the ambulance is moved.




7.12.1 Do not move ambulance light needs clarifications. Items #2 is open to interpretation this could be interpreted or construed as meaning cots, portable 02 cylinders, etc. Line #1 and #3 are OK as written.









(2) Any external equipment rack is not in the stowed position.





Internal equipment may or may not be stowed while the ambulance is being driven based on patient care demands and AHJ policies. An electronic display in the view of the driver in these cases is an unnecessary distraction.









7.13.2The backup alarm shall not have capacity to be turned off or disconnected.




Contrary to popular belief, OSHA does not require backup alarms on all trucks. Backup alarms are typically required only on construction sites. Even in cases where backup protection is required, the use of a spotter is allowed as an alternative to an audible alarm.Ambulances often operate in noise-restricted or noise-sensitive areas where the operation of a backup alarm is objectionable.While we support the installation of a backup alarm on all ambulances, the prohibition of a momentary disable switch is inappropriate.This section should be deleted as it inappropriately restricts the freedom of ambulance operators to employ alternate backing protocol in lieu of a backup alarm.









7.13.2The backup alarm shall not have capacity to be turned off or disconnected be enabled anytime the vehicle is in reverse and shall not be disabled .


Clarification on the intention of the device operation. Requireing that the backup alarm not be able to be disconnected is not possible. Any device can be disconnected.









7.14 Stop, Tail, and Directional Lights.7.14.1

The ambulance shall be equipped with all FMVSS 108 legally required stop, tail, and directional lights.

7.14.2Directional lights shall be visible according to FMVSS 108.

7.14.3On ambulances 30 ft (10 m) or longer in length, a turn signal shall be mounted approximately midway along the ambulance at approximately running board height.

7.14.4Equipment shall not be mounted in a manner that obscures the stop, tail, or directional lights.




There is no justification for repeating FMVSS requirements in this standard. The ambulance cannot be legally operated on the highway unless it complies with all applicable FMVSS requirements.Duplicating any portion of the FMVSS in this standard creates a bad precedent that should be avoided.This section should be deleted from the 1917 standard.








7.14.5Emergency warning lights shall not be used as brake lights, tail lights or turn signals if they exceed the FMVSS maximum candela output requirements of FMVSS 571 Standard No. 108.


Safety concern where warning lights are being used as brake lights and causing a visual impairment of following motorists.









7.14.6Warning lights that do not exceed the maximum candela rating of FMVSS 108 and are used as primary or auxiliary brake lights shall not be mounted higher than 72" above the ground nor lower than 15" from the ground.


Brake lights mounted over 72" are not permitted per FMVSS 108 and pose a visability safety concern for some following motorists such as semi's and RV's.









7.15 * Communications Equipment.7.15.1

Any two-way radio equipment shall be installed in accordance with the requirements of the radio equipment manufacturer.

7.15.2 *Sufficient ventilated space for a two-way radio, including convenience

features, antenna openings, ground plane, terminal wiring for 12-volt power, and ground, shall be provided.











7.15.3*Communication devices installed in the patient compartment shall be secured within a maximum functional reach of 26.7 in. (678 mm) to the EMSPs with height as short as 59.3 in. (1506 mm) from a restrained position.


Communication mechanisms and devices in the patient compartment are frequently sought for use by EMSPs to be in contact with the emergency medical services dispatcher, hospital, or ambulance driver. By accommodating the reachability of communication devices to a shorter demographic with a smaller reach, EMS providers will have fewer difficulties in reaching them. This will enhance their safety by allowing them to stay restrained and will also increase working efficiency. The human factors practices in MIL-STD 1472G have provisions for functional reach. Table B-I, Standing Body Dimensions –General Forces, of MIL-STD 1472G addresses functional reachability ranges for different size demographics. Added asterisk to correspond with additional material provided in annex.


Submitter Full Name: [ Not Specified ]Organization: [ Not Specified ]Street Address: City:State: Zip: Submittal Date: Tue Jul 02 11:04:54 EDT 2013


I, [ Not Specified ], hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. Ihereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am [ Not Specified ], and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature




8.2.2.8 When more than one shoreline receptacle is connected to a given load, relay(s) or transfer switch(es) shall be used to de-energize the unused shoreline receptacle.




Customers sometimes elect to install redundant shoreline receptacles to accommodate varying shorepower source locations. When that is done, a relay or transfer switch is needed to prevent possible electrocution from contact with the live contact beneath the cover of the unused shoreline connector.A new section should be added to ensure that this protection is provided.









8.2.3 Receptacle.8.2.3.1

The shoreline receptacle shall energize the vehicle’s internal line voltage circuit from an external power source such as utility power.

8.2.3.2A proper-mating, weatherproof, minimum 15-ampere connector body conforming to the NEMA configuration shall also be furnished without cableand tagged specifying the size, the type of wire necessary, and the polarity ofthe future hookup.




These sections should be deleted as they are redundant with section 8.2.2.4 and 8.2.2.5.









8.2.4.3Any fixed line voltage power source shall produce a maximum voltage output of no more than 10 110 percent of the power source's full rated voltage.




Correct typo.









8.3.1.7Any Except for the ground-to-neutral bond at an electrical power source such as an inverter or generator, a ny bonding screws, straps, or buses in the distribution panelboard or in other system components between the neutral and equipment-grounding conductor shall beremoved and discarded.




The essential requirement here is that there must be one and only one point of connection between the neutral and ground. This connection normally occurs at the power distribution panel that supplies shorepower to the ambulance. However, when AC power is provided from an inverter or generator, it is imperative that the inverter or generator provide a bond between ground and neutral.An exception should be added to this section to clarify that the ground-to-neutral bond should not be removed from the inverter or generator.









8.3.2.2.5Cord- Except for distinctively marked, double-insulated tools and appliance supplied with a two-wire cord and plug, cord- connectedappliances shall be grounded by means of an approved cord with anequipment-grounding conductor and grounding attachment plug.




NEC section 250.114 provides an exception for double-insulated tools and appliances. It would be inappropriate for the ambulance standard to require modification of tools and appliances by installing a 3-wire cord and plug on devices that are legitimately and properly supplied with a 2-wire cord and plug.An exception should be added to make this section consistent with the NEC.









8.3.3.3.5The ambulance body and exterior covering shall be considered bonded when the following criteria have been met:

(1) The metal panels overlap or are welded to one another and are securely attached to the metal frame parts by metal fasteners or welding.

(2) The lower panel of the metal exterior covering is secured by metal fasteners at each cross member of the chassis, or the lower panel is bonded to the chassis by a metal strap.




The intent of this section is to ensure proper electrical bonding. Because welding panels to one another provides a bond equal or superior to overlapping, the option of welding should be added to item (1) of this section.The intent of item (2) of this section is unclear, and the language is confusing. Ambulance exterior metal walls are typically one piece from top to bottom; there is not a separate lower panel. The cross members of the chassis (presuming that this is referring to the chassis frame cross members as opposed to the module support laterals) have no bearing whatsoever upon fastener location.Item (2) appears to have no clear relevance and therefore should be eliminated.








8.3.3.3.6Metal circulating air ducts shall be bonded to the chassis.




Metal circulating air ducts are rarely used in ambulances. When they are used, they are typically integrated into the module construction or bonded to the module which is in turn bonded to the chassis.Because there is no justification for bonding ducts to the chassis as opposed to bonding them to the module, this section should be deleted.









8.4 * Ground-Fault Circuit Interrupters.All line voltage ac circuits receptacles of the ambulance shall be protected by listed ground-fault circuit interrupters in accordance with ANSI/UL 498, Standard for Safety Attachment Plugs and Receptacles.




Except for underwater pool lights, the NEC calls for GFCI protection only for receptacles. Because the intent of this ambulance standard is to compel compliance with the NEC, the NEC requirements should not be altered by this standard.The language of this section should be revised to bring it into conformity with NEC section 210.8.









8.5 Power Source General Requirements.The requirements in 8.5.1 through 8.5.10 shall apply to all line voltage power sources. [1901:22.4]8.5.1

All power source system mechanical and electrical components shall be sized to support the continuous duty nameplate rating of the power source. [ 1901: 22.4.1]

8.5.2The power source shall be shielded from contamination that would

prevent the power source from operating within its design specifications. [ 1901: 22.4.2]

8.5.3 Generators.If the power source is mechanically driven and mounted on the vehicle, it

shall comply with Article 445, “Generators,” of NFPA 70 .

8.5.4 Power Source Rating. 8.5.4.1 *

For power sources of 8 kW or larger, the power source manufacturer shall declare the continuous duty rating that the power source can provide when installed on the ambulance according to the manufacturer's instructions and run at 120°F (49°C) air intake temperature at 2000 ft (600 m) above sea level.

8.5.4.2 The rating on the power source specification label shall not exceed the declared rating from the power source manufacturer. [ 1901: 22.4.

3.2] 8.5.5

Access shall be provided to permit both routine maintenance and removal of the power source for major servicing. [ 1901: 22.4.4]

8.5.6The power source shall be located such that neither it nor its mounting brackets interfere with the routine maintenance of the ambulance.8.5.7 Instrumentation.

8.5.7.1

If the power source is rated at less than 3 kW, a “Power On” indicator shall be provided. [ 1901: 22.4.6.1]

8.5.7.2If the power source is rated at 3 kW or more but less than 8 kW, a voltmeter shall be provided. [ 1901: 22.4.6.2]

8.5.7.3 *If the power source is rated at 8 kW or more, the following instrumentation shall be provided at an operator's panel:



(1) Voltmeter

(2) Current meters for each ungrounded leg

(3) Frequency (Hz) meter

(4) Power source hourmeter

[ 1901: 22.4.6.3]8.5.7.4

The instrumentation shall be permanently mounted at an operator's panel. [ 1901: 22.4.6.4]

8.5.7.4.1The instruments shall be located in a plane facing the operator. [ 1901: 22.4.6.4.1]

8.5.7.4.2Gauges, switches, or other instruments on this panel shall each have a label to indicate their function. [ 1901: 22.4.6.4.2]

8.5.7.4.3The instruments and other line voltage equipment and controls shall be protected from mechanical damage and not obstructed by tool mounting or equipment storage. [ 1901: 22.4.6.4.3]

8.5.8An instruction plate(s) that provides the operator with the essential power source operating instructions, including the power-up and power-down sequence, shall be permanently attached to the ambulance at any point where such operations can take place. [ 1901: 22.4.7]8.5.9 Operation.

8.5.9.1Provisions shall be made for placing the generator drive system in operation using controls and switches that are identified and within reach of the operator while seated in the driver's seat or standing upright on the ground.

8.5.9.2Where the generator is driven by the chassis engine and engine compression brakes or engine exhaust brakes are furnished, they shall be automatically disengaged for generator operations. [ 1901: 22.4.8.2]

8.5.9.3 *Any control device used in the generator system power train between the engine and the generator shall be equipped with a means to prevent unintentional movement of the control device from its set position in the power generation mode. [ 1901: 22.4.8.3]

8.5.10If there is permanent wiring on the ambulance that is designed to be connected to the power source, a power source specification label that is permanently attached to the ambulance at the operator's control station shall provide the operator with the information detailed in Figure 8.5.10 .Figure 8.5.10 Power Source Specification Label. [1901:Figure 22.4.9]

8.5.11



The power source, at any load, shall not produce a noise level that exceeds 90 dBA in any driving compartment, crew compartment, or onboard command area with windows and doors closed or at any operator's station on the ambulance.

When the FSAM furnishes a generator below 8 kW they shall follow generator manufacturer’s installation and operation instructions, over 8 kW follow NFPA 1901.


It is extremely rare for an ambulance to be equipped with a generator larger than 8kW. Inclusion of this large section of text for an application that is inapplicable to ambulances cannot be justified as part of an ambulance standard. Further, the new language provides clarity on which installation and operation instructions are to be followed based on the generator output.









8.5.3.1 When the FSAM furnishes a generator below 8 kW they shall follow generator manufacturer’s installation and operation instructions, over 8 kW follow NFPA 1901.


Substandtiation: It is extremely rare for an ambulance to be equipped with a generator larger that 8kW. Inclusion of this large section of text for an appliaction that is inapplicable to ambulances cannot be justified as part of an ambulance standard.








Public Input No. 480-NFPA 1917-2013 [ Sections 8.5.3, 8.5.4, 8.5.5,

8.5.6, 8.5.7, 8.5.8, 8.5.9, 8... ]

Sections 8.5.3, 8.5.4, 8.5.5, 8.5.6, 8.5.7, 8.5.8, 8.5.9, 8.5.10, 8.5.118.5.3 Generators.

If the power source is mechanically driven and mounted on the vehicle, it shall comply with Article 445, “Generators,” of NFPA 70.

8.5.4 Power Source Rating. 8.5.4.1 *

For power sources of 8 kW or larger, the power source manufacturer shall declare the continuous duty rating that the power source can provide when installed on the ambulance according to the manufacturer's instructions and run at 120°F (49°C) air intake temperature at 2000 ft (600 m) above sea level.

8.5.4.2 The rating on the power source specification label shall not exceed the declared rating from the power source manufacturer. [ 1901: 22.4.

3.2] 8.5.5

Access shall be provided to permit both routine maintenance and removal of the power source for major servicing. [ 1901: 22.4.4]

8.5.6The power source shall be located such that neither it nor its mounting brackets interfere with the routine maintenance of the ambulance.8.5.7 Instrumentation.

8.5.7.1If the power source is rated at less than 3 kW, a “Power On” indicator shall be provided. [ 1901: 22.4.6.1]

8.5.7.2If the power source is rated at 3 kW or more but less than 8 kW, a voltmeter shall be provided. [ 1901: 22.4.6.2]

8.5.7.3 *If the power source is rated at 8 kW or more, the following instrumentation shall be provided at an operator's panel:

(1) Voltmeter




[ 1901: 22.4.6.3]8.5.7.4

The instrumentation shall be permanently mounted at an operator's panel. [ 1901: 22.4.6.4]

8.5.7.4.1The instruments shall be located in a plane facing the operator. [ 1901: 22.4.6.4.1]

8.5.7.4.2



Gauges, switches, or other instruments on this panel shall each have a label to indicate their function. [ 1901: 22.4.6.4.2]

8.5.7.4.3The instruments and other line voltage equipment and controls shall be protected from mechanical damage and not obstructed by tool mounting or equipment storage. [ 1901: 22.4.6.4.3]

8.5.8An instruction plate(s) that provides the operator with the essential power source operating instructions, including the power-up and power-down sequence, shall be permanently attached to the ambulance at any point where such operations can take place. [ 1901: 22.4.7]8.5.9 Operation.

8.5.9.1Provisions shall be made for placing the generator drive system in operation using controls and switches that are identified and within reach of the operator while seated in the driver's seat or standing upright on the ground.

8.5.9.2Where the generator is driven by the chassis engine and engine compression brakes or engine exhaust brakes are furnished, they shall be automatically disengaged for generator operations. [ 1901: 22.4.8.2]

8.5.9.3 *Any control device used in the generator system power train between the engine and the generator shall be equipped with a means to prevent unintentional movement of the control device from its set position in the power generation mode. [ 1901: 22.4.8.3]

8.5.10If there is permanent wiring on the ambulance that is designed to be connected to the power source, a power source specification label that is permanently attached to the ambulance at the operator's control station shall provide the operator with the information detailed in Figure 8.5.10 .Figure 8.5.10 Power Source Specification Label. [1901:Figure 22.4.9]

8.5.11The power source, at any load, shall not produce a noise level that exceeds 90 dBA in any driving compartment, crew compartment, or onboard command area with windows and doors closed or at any operator's station on the ambulance.1 When the FSAM furnishes a generator below 8 kW they shall follow generator manufacturer’s installation and operation instructions, over 8 kW follow NFPA 1901.






It is extremely rare for an ambulance to be equipped with a generator larger than 8kW. Inclusion of this large section of text for an application that is inapplicable to ambulances cannot be justified as part of an ambulance standard.








Public Input No. 131-NFPA 1917-2013 [ Sections 8.5.4, 8.5.5, 8.5.6,

8.5.7, 8.5.8, 8.5.9, 8.5.10, ... ]

Sections 8.5.4, 8.5.5, 8.5.6, 8.5.7, 8.5.8, 8.5.9, 8.5.10, 8.5.118.5.4 Power Source Rating.8.5.4.1 *For power sources of 8 kW or larger, the power source manufacturer shall

declare the continuous duty rating that the power source can provide when installed on the ambulance according to the manufacturer's instructions and run at 120°F (49°C) air intake temperature at 2000 ft (600 m) above sea level.

8.5.4.2The rating on the power source specification label shall not exceed the

declared rating from the power source manufacturer. [ 1901: 22.4.3.2]8.5.5Access shall be provided to permit both routine maintenance and removal

of the power source for major servicing. [ 1901: 22.4.4]8.5.6The power source shall be located such that neither it nor its mounting

brackets interfere with the routine maintenance of the ambulance.8.5.7 Instrumentation.8.5.7.1If the power source is rated at less than 3 kW, a “Power On” indicator

shall be provided. [ 1901: 22.4.6.1]8.5.7.2If the power source is rated at 3 kW or more but less than 8 kW, a

voltmeter shall be provided. [ 1901: 22.4.6.2]8.5.7.3 *If the power source is rated at 8 kW or more, the following

instrumentation shall be provided at an operator's panel:

(1) Voltmeter




[ 1901: 22.4.6.3]8.5.7.4The instrumentation shall be permanently mounted at an operator's

panel. [ 1901: 22.4.6.4]8.5.7.4.1



The instruments shall be located in a plane facing the operator. [ 1901: 22.4.6.4.1]

8.5.7.4.2Gauges, switches, or other instruments on this panel shall each

have a label to indicate their function. [ 1901: 22.4.6.4.2]8.5.7.4.3The instruments and other line voltage equipment and controls

shall be protected from mechanical damage and not obstructed by tool mounting or equipment storage. [ 1901: 22.4.6.4.3]

8.5.8An instruction plate(s) that provides the operator with the

essential power source operating instructions, including the power-up and power-down sequence, shall be permanently attached to the ambulance at any point where such operations can take place. [ 1901: 22.4.7]

8.5.9 Operation.8.5.9.1Provisions shall be made for placing the generator drive system

in operation using controls and switches that are identified and within reach of the operator while seated in the driver's seat or standing upright on the ground.

8.5.9.2Where the generator is driven by the chassis engine and

engine compression brakes or engine exhaust brakes are furnished, they shall be automatically disengaged for generator operations. [ 1901: 22.4.8.2]

8.5.9.3 *Any control device used in the generator system power train

between the engine and the generator shall be equipped with a means to prevent unintentional movement of the control device from its set position in the power generation mode. [ 1901: 22.4.8.3]

8.5.10If there is permanent wiring on the ambulance that is

designed to be connected to the power source, a power source specification label that is permanently attached to the ambulance at the operator's control station shall provide the operator with the information detailed in Figure8.5.10 .

Figure 8.5.10 Power Source Specification Label. [1901:Figure 22.4.9]

8.5.11The power source, at any load, shall not produce a noise

level that exceeds 90 dBA in any driving compartment, crew compartment, or onboard command area with windows and doors closed or at any operator's station on the ambulance.

8.5.4 Power Source Rating.



8.5.4.1* For power sources of 8 kW or larger, the powersource manufacturer shall declare the continuous duty rating that the powersource can provide when installed on the ambulance according to themanufacturer's instructions and run at 120°F (49°C) air intake temperature at2000 ft (600 m) above sea level.

8.5.4.2 The rating on the power source specificationlabel shall not exceed the declared rating from the power source manufacturer. [ 1901: 22.4.3.2]

8.5.5 Access shall be provided to permit both routinemaintenance and removal of the power source for major servicing.[ 1901: 22.4.4]

8.5.6 The power source shall be located such thatneither it nor its mounting brackets interfere with the routine maintenance ofthe ambulance.

8.5.7 Instrumentation.8.5.7.1 If the power source is rated at less than 3 kW, a

“Power On” indicator shall be provided. [ 1901: 22.4.6.1]8.5.7.2 If the power source is rated at 3 kW or more but

less than 8 kW, a voltmeter shall be provided. [ 1901: 22.4.6.2]

8.5.7.3* If the power source is rated at 8 kW or more, the following instrumentation shall be provided at an operator'spanel:

(1) Voltmeter(2) Current meters for each ungrounded

leg(3) Frequency (Hz) meter(4) Power source hourmeter

[ 1901: 22.4.6.3]8.5.7.4 The instrumentation shall be permanently

mounted at an operator's panel. [ 1901: 22.4.6.4]8.5.7.4.1 The instruments shall be located in a plane

facing the operator. [ 1901: 22.4.6.4.1]8.5.7.4.2 Gauges, switches, or other instruments on this

panel shall each have a label to indicate their function. [ 1901: 22.4.6.4.2]

8.5.7.4.3 The instruments and other line voltageequipment and controls shall be protected from mechanical damage and notobstructed by tool mounting or equipment storage. [ 1901: 22.4.6.4.3]

8.5.8 An instruction plate(s) that provides the operator with the essential power source operating instructions, including the power-up and power-down sequence, shall be permanently attached to the ambulanceat any point where such operations can take place. [ 1901: 22.4.7]

8.5.9 Operation.8.5.9.1 Provisions shall be made for placing the

generator drive system in operation using controls and switches that areidentified and within reach of the operator while seated in the driver's seat orstanding upright on the ground.



8.5.9.2 Where the generator is driven by the chassisengine and engine compression brakes or engine exhaust brakes are furnished, they shall be automatically disengaged for generator operations.[ 1901: 22.4.8.2]

8.5.9.3* Any control device used in the generator systempower train between the engine and the generator shall be equipped with a means to prevent unintentional movement of the control device from its set position in the power generation mode. [ 1901: 22.4.8.3]

8.5.10 If there is permanent wiring on the ambulancethat is designed to be connected to the power source, a power sourcespecification label that is permanently attached to the ambulance at theoperator's control station shall provide the operator with the informationdetailed in Figure 8.5.10 .

****INSERT FIGURE HERE****FIGURE 8.5.10 Power Source Specification Label.

[1901:Figure 22.4.9]8.5.11 The power source, at any load, shall not produce

a noise level that exceeds 90 dBA in any driving compartment, crewcompartment, or onboard command area with windows and doors closed or at any operator's station on the ambulance.


Substantiation: It is extremely rare for an ambulance to be equipped with a generator larger than 8kW. Inclusion of this large section of text for an application that is inapplicable to ambulances cannot be justified as part of an ambulance standard.









8.5.11The power source, at any load, shall not produce a noise level that exceeds 90 dBA in any driving compartment, crew compartment, or onboard command area with windows and doors closed or at any operator's station on the ambulance.

8.5.11 The power source, at any load, shall not produce a noise level that exceeds 90 dBA in any driving compartment, crew compartment, or onboard command area with windows and doors closed or at any operator's station on the ambulance.











8.6 Power Source–Type Specific Requirements.8.6.1 * Direct Drive (PTO) Generators.If the generator is driven by any type of PTO, it shall meet the requirements of 8.6.1.1 through 8.6.1.3.8.6.1.1The transmission's PTO port and PTO, or the split shaft PTO, and all

associated driveshaft components shall be rated to support the continuous duty torque requirements of the generator's continuous duty rating as stated on the power source nameplate. [ 1901: 22.5.1.1]

8.6.1.2The direct drive generator shall be mounted so that it does not change the

ramp breakover angle, angle of departure, or angle of approach as defined by other components, and it shall not extend into the ground clearance area. [ 1901: 22.5.1.4]

8.6.1.3The direct drive generator shall be mounted away from exhaust and

muffler areas or provided with a heat shield to reduce operating temperatures in the generator area. [ 1901: 22.5.1.5]

8.6.2 * Hydraulically Driven Generators.If the generator is driven using hydraulic components, it shall meet the

requirements of 8.6.2.1 through 8.6.2.3.4 .8.6.2.1 *A means shall be provided to activate the hydraulic generator system.

[ 1901: 22.5.2.1]8.6.2.2If the hydraulic generator system is not capable of output as stated on

the power source specification label at all engine speeds, an automatic engine speed control system shall be provided. [ 1901: 22.5.2.2]

8.6.2.3 Hydraulic Components.8.6.2.3.1A hydraulic system filter and strainer shall be provided and shall be

located in a readily accessible area. [ 1901: 22.5.2.4.1]8.6.2.3.2Hydraulic hose shall meet the hydraulic pump manufacturer's

recommendations for pressure, size, vacuum, and abrasion resistance. [ 1901: 22.5.2.4.2]

8.6.2.3.3Hydraulic fittings shall meet the hydraulic pump manufacturer's

recommendations for pressure, size, and the type of hose used. [ 1901: 22.5.2.4.3]

8.6.2.3.4Where the hydraulic hose comes into contact with other surfaces,

the hose shall be protected from chafing. [ 1901: 22.5.2.5]8.6.3 * Fixed Auxiliary Engine–Driven Generators.If the generator is driven by a fixed auxiliary engine, it shall meet the

requirements of 8.6.3.1 through 8.6.3.9.4 .8.6.3.1



The generator shall be installed so that fumes, vapors, heat, and vibrations do not enter the driving or patient compartment.

8.6.3.2 *Generators rated at 8 kW or more shall be equipped with a high

temperature automatic shutdown system and a low oil (pressure or level) automatic shutdown system. [ 1901: 22.5.3.2]

8.6.3.3The generator shall be installed in accordance with the generator

manufacturer's requirements for ventilation and service accessibility. [ 1901: 22.5.3.3]

8.6.3.4If the generator is installed in a compartment and the

compartment doors need to be open during its operation, the generator shall be equipped with an interlock system to prevent its operation if the doors are not open, or the compartment shall be equipped with a high temperature alarm. [ 1901: 22.5.3.4]

8.6.3.5If the generator is installed in a compartment on a slide tray and

the slide tray must be in the extended or out position during operation, an interlock shall be provided to prevent operation unless the tray is in the correct position, or the compartment shall be equipped with a high temperature alarm. [ 1901: 22.5.3.5]

8.6.3.6Permanently installed generators shall have readily accessible

engine oil drain provisions or piping to a remote location for oil changing. [ 1901: 22.5.3.6]

8.6.3.7If the generator is located in a position on the ambulance

where the operator cannot see the instrumentation and operate the controls while standing at ground level or positioned at a specifically designated operator station, an operating panel with the required instrumentation, start and stop controls, and other controls necessary for safe operation shall be provided at a remote operator’s panel.

8.6.3.7.1A visual and audible warning shall be provided in the

ambulance cab, visible from the operator’s seat to do the following:

(1) Visually indicate that the generator engine is operating

(2) Visually and audibly indicate that the generator engine is in operation when the ambulance ignition is off

8.6.3.7.2The audible warning shall be permitted to be equipped with

an override function that resets automatically when the ignition is cycled on.

8.6.3.7.3The generator engine shall shut down and be prevented

from restarting automatically when connection to an external source of electrical power (“shore power”) is established.

8.6.3.8 Fuel System.8.6.3.8.1Fuel lines shall be protected from chafing at all wear

points. [ 1901: 22.5.3.8.1]8.6.3.8.2



If the fuel source is shared with the ambulance engine, a separate fuel pickup system shall be provided that is arranged to ensure that the generator cannot utilize more than 75 percent of the fuel tank's capacity.

8.6.3.9 Exhaust System.8.6.3.9.1 *The exhaust piping and discharge shall be located or

shielded to prevent thermal damage to the ambulance or equipment.

8.6.3.9.2The exhaust shall be piped to the exterior of the

vehicle and discharged at a location away from any operator's position. [ 1901: 22.5.3.9.2]

8.6.3.9.2.1The exhaust system for the generator shall comply

with Section 5.6 .8.6.3.9.3Where parts of the exhaust system are exposed so

that they can cause injury to operating personnel, protective guards shall be provided. [ 1901: 22.5.3.9.3]

8.6.3.9.4Silencing devices shall be provided and shall not

create exhaust backpressure that exceeds the limits specified by the engine manufacturer. [ 1901: 22.5.3.9.4]

8.6.4 * Line Voltage Power Derived from the Ambulance Low Voltage Power Supply Systems.

If the power source derives its input energy from the ambulance low voltage electrical system, it shall meet the requirements of 8.6.4.1 and 8.6.4.2 .

8.6.4.1The low voltage power supply system shall be

installed in compliance with the requirements of Chapter 7 .

8.6.4.2 *The alternator and/or battery system shall be

adequate to provide power for continuous operation for a minimum of 2 hours at full output. [ 1901: 22.5.5.2]

8.6.5 Power Sources Requiring Elevated Engine Speed.

If the power source requires the chassis engine to be operating at a specific fixed speed or a specific speed range, it shall meet the requirements of 8.6.5.1 through 8.6.5.3 .

8.6.5.1The main propulsion engine shall have a

governor capable of maintaining the engine speed within the limits required by the power source to meet the frequency control, voltage control, and power output specifications. [ 1901: 22.5.6.1]

8.6.5.2An interlock shall prevent engagement of the

generator unless the parking brake is engaged and the transmission is in neutral or not connected to the drive wheels.[ 1901: 22.5.6.2]

8.6.5.3 *



Where the chassis engine drives the generator and electronic engine throttle controls are provided, an interlock shall prevent engine speed control from any other source that would interfere with the generator while the generator is operating.[ 1901: 22.5.6.3]

8.6.6 * Waveform Created Electronically.

If the power output waveform is electronically created (as with invertors and some generators), the purchaser shall specify whether modified sine wave or pure sine wave output is required.

8.6 Power Source–Type SpecificRequirements.

8.6.1* Direct Drive (PTO) Generators. If the generator is driven by any type of PTO, it shall meet the requirements of8.6.1.1 through 8.6.1.3 .

8.6.1.1 The transmission's PTO port and PTO, or the split shaft PTO, and all associated driveshaft components shall be rated to support the continuous duty torque requirements of the generator's continuous duty rating as stated on the power source nameplate. [ 1901: 22.5.1.1]

8.6.1.2 The direct drive generator shall be mounted so that it does not change the ramp breakover angle, angle of departure, or angle of approach as defined by other components, and it shall not extend into the ground clearance area. [ 1901: 22.5.1.4]

8.6.1.3 The direct drive generator shall be mounted away from exhaust and muffler areas or provided with a heat shield to reduce operating temperatures in the generator area. [ 1901: 22.5.1.5]

8.6.2* Hydraulically Driven Generators.If the generator is driven using hydraulic components, it shall meet the requirements of 8.6.2.1 through8.6.2.3.4 .

8.6.2.1* A means shall be provided to activate the hydraulic generator system. [ 1901: 22.5.2.1]

8.6.2.2 If the hydraulic generator system is not capable of output as stated on the power source specification label at all engine speeds, an automatic engine speed control system shall be provided. [ 1901: 22.5.2.2]

8.6.2.3 Hydraulic Components.

8.6.2.3.1 A hydraulic system filter and strainer shall be provided and shall be located in a readily accessible area. [ 1901: 22.5.2.4.1]

8.6.2.3.2 Hydraulic hose shall meet the hydraulic pump manufacturer's recommendations for pressure, size, vacuum, and abrasion resistance. [ 1901: 22.5.2.4.2]

8.6.2.3.3 Hydraulic fittings shall meet the hydraulic pump manufacturer's recommendations for pressure, size, and the type of hose used. [ 1901: 22.5.2.4.3]



8.6.2.3.4 Where the hydraulic hose comes into contact with other surfaces, the hose shall be protected from chafing. [ 1901: 22.5.2.5]

8.6.3* Fixed Auxiliary Engine–Driven Generators. If the generator is driven by a fixed auxiliary engine, it shall meet the requirements of 8.6.3.1 through8.6.3.9.4 .

8.6.3.1 The generator shall be installed so that fumes, vapors, heat, and vibrations do not enter the driving or patientcompartment.

8.6.3.2* Generators rated at 8 kW or more shall be equipped with a high temperature automatic shutdown system and a low oil (pressure or level) automatic shutdown system. [ 1901: 22.5.3.2]

8.6.3.3 The generator shall be installed in accordance with the generator manufacturer's requirements for ventilation and service accessibility. [ 1901: 22.5.3.3]

8.6.3.4 If the generator is installed in a compartment and the compartment doors need to be open during its operation, the generator shall be equipped with an interlock system to prevent its operation if the doors are not open, or the compartment shall be equipped with a high temperature alarm. [ 1901: 22.5.3.4]

8.6.3.5 If the generator is installed in a compartment on a slide tray and the slide tray must be in the extended or out position during operation, an interlock shall be provided to prevent operation unless the tray is in the correct position, or the compartment shall be equipped with a high temperature alarm. [ 1901: 22.5.3.5]

8.6.3.6 Permanently installed generators shall have readily accessible engine oil drain provisions or piping to a remote location for oil changing. [ 1901: 22.5.3.6]

8.6.3.7 If the generator is located in a position on the ambulance where the operator cannot see the instrumentation and operate the controls while standing at ground level or positioned at a specifically designated operator station, an operating panel with the requiredinstrumentation, start and stop controls, and other controls necessary for safeoperation shall be provided at a remote operator’s panel.

8.6.3.7.1 A visual and audible warning shall be provided in the ambulance cab, visible from the operator’s seat to do the following:



8.6.3.7.2 The audible warning shall be permitted to be equipped with an override function that resets automatically when the ignition is cycled on.

8.6.3.7.3 The generator engine shall shut down and be prevented from restarting automatically when connection to an external source of electrical power (“shore power”) isestablished.



8.6.3.8 Fuel System.

8.6.3.8.1 Fuel lines shall be protected from chafing at all wear points. [ 1901: 22.5.3.8.1]

8.6.3.8.2 If the fuel source is shared with the ambulance engine, a separate fuel pickup system shall be provided that is arranged to ensure that the generator cannot utilize more than 75 percent of the fuel tank's capacity.

8.6.3.9 Exhaust System.

8.6.3.9.1* The exhaust piping and discharge shall be located or shielded to prevent thermal damage to the ambulance or equipment.

8.6.3.9.2 The exhaust shall be piped to the exterior of the vehicle and discharged at a location away from any operator's position. [ 1901: 22.5.3.9.2]

8.6.3.9.2.1 The exhaust system for the generator shall comply with Section 5.6 .

8.6.3.9.3 Where parts of the exhaust system are exposed so that they can cause injury to operating personnel, protective guards shall be provided. [ 1901: 22.5.3.9.3]

8.6.3.9.4 Silencing devices shall be provided and shall not create exhaust backpressure that exceeds the limits specified by the engine manufacturer. [ 1901: 22.5.3.9.4]

8.6.4* Line Voltage Power Derived from the Ambulance Low Voltage Power Supply Systems. If the power source derives its input energy from the ambulance low voltage electrical system, it shall meet the requirements of 8.6.4.1 and8.6.4.2 .

8.6.4.1 The low voltage power supply system shall be installed in compliance with the requirements of Chapter7 .

8.6.4.2* The alternator and/or battery system shall be adequate to provide power for continuous operation for a minimum of 2 hours at full output. [ 1901: 22.5.5.2]

8.6.5 Power Sources Requiring Elevated Engine Speed. If the power source requires the chassis engine to be operating at a specific fixed speed or a specific speed range, it shall meet the requirements of 8.6.5.1 through8.6.5.3 .

8.6.5.1 The main propulsion engine shall have a governor capable of maintaining the engine speed within the limits required by the power source to meet the frequency control, voltage control, and power output specifications. [ 1901: 22.5.6.1]

8.6.5.2 An interlock shall prevent engagement of the generator unless the parking brake is engaged and the transmission is in neutral or not connected to the drive wheels. [ 1901: 22.5.6.2]



8.6.5.3* Where the chassis engine drives the generator and electronic engine throttle controls are provided, an interlock shall prevent engine speed control from any other source that would interfere with the generator while the generator is operating. [ 1901: 22.5.6.3]

8.6.6* Waveform Created Electronically.If the power output waveform is electronically created (as with invertors and some generators), the purchaser shall specify whether modified sine wave or pure sine wave output is required.











8.6 Power Source–Type Specific Requirements.8.6.1 * Direct Drive (PTO) Generators.If the generator is driven by any type of PTO, it shall meet the requirements of 8.6.1.1 through 8.6.1.3 .

8.6.1.1The transmission's PTO port and PTO, or the split shaft PTO, and all associated driveshaft components shall be rated to support the continuous duty torque requirements of the generator's continuous duty rating as stated on the power source nameplate. [ 1901: 22.5.1.1]

8.6.1.2The direct drive generator shall be mounted so that it does not change the ramp breakover angle, angle of departure, or angle of approach as defined by other components, and it shall not extend into the ground clearance area. [ 1901: 22.5.1.4]

8.6.1.3The direct drive generator shall be mounted away from exhaust and muffler areas or provided with a heat shield to reduce operating temperatures in the generator area. [ 1901: 22.5.1.5]8.6.2 * Hydraulically Driven Generators.If the generator is driven using hydraulic components, it shall meet the requirements of 8.6.2.1 through 8.6.2.3.4 .

8.6.2.1 *A means shall be provided to activate the hydraulic generator system. [ 1901: 22.5.2.1]

8.6.2.2If the hydraulic generator system is not capable of output as stated on the power source specification label at all engine speeds, an automatic engine speed control system shall be provided. [ 1901: 22.5.2.2]8.6.2.3 Hydraulic Components.

8.6.2.3.1A hydraulic system filter and strainer shall be provided and shall be located in a readily accessible area. [ 1901: 22.5.2.4.1]

8.6.2.3.2Hydraulic hose shall meet the hydraulic pump manufacturer's recommendations for pressure, size, vacuum, and abrasion resistance. [ 1901: 22.5.2.4.2]

8.6.2.3.3Hydraulic fittings shall meet the hydraulic pump manufacturer's recommendations for pressure, size, and the type of hose used.[ 1901: 22.5.2.4.3]

8.6.2.3.4Where the hydraulic hose comes into contact with other surfaces, the hose shall be protected from chafing. [ 1901: 22.5.2.5]8.6.3 * Fixed Auxiliary Engine–Driven Generators.If the generator is driven by a fixed auxiliary engine, it shall meet the requirements of 8.6.3.1 through 8.6.3.9.4 .

8.6.3.1




8.6.3.2 *Generators rated at 8 kW or more shall be equipped with a high temperature automatic shutdown system and a low oil (pressure or level) automatic shutdown system. [ 1901: 22.5.3.2]

8.6.3.3The generator shall be installed in accordance with the generator manufacturer's requirements for ventilation and service accessibility.[ 1901: 22.5.3.3]

8.6.3.4If the generator is installed in a compartment and the compartment doors need to be open during its operation, the generator shall be equipped with an interlock system to prevent its operation if the doors are not open, or the compartment shall be equipped with a high temperature alarm.[ 1901: 22.5.3.4]

8.6.3.5If the generator is installed in a compartment on a slide tray and the slide tray must be in the extended or out position during operation, an interlock shall be provided to prevent operation unless the tray is in the correct position, or the compartment shall be equipped with a high temperature alarm. [ 1901: 22.5.3.5]

8.6.3.6Permanently installed generators shall have readily accessible engine oil drain provisions or piping to a remote location for oil changing. [ 1901: 22.5.3.6]

8.6.3.7If the generator is located in a position on the ambulance where the operator cannot see the instrumentation and operate the controls while standing at ground level or positioned at a specifically designated operator station, an operating panel with the required instrumentation, start and stop controls, and other controls necessary for safe operation shall be provided at a remote operator’s panel.

8.6.3.7.1A visual and audible warning shall be provided in the ambulance cab, visible from the operator’s seat to do the following:



8.6.3.7.2The audible warning shall be permitted to be equipped with an override function that resets automatically when the ignition is cycled on.

8.6.3.7.3The generator engine shall shut down and be prevented from restarting automatically when connection to an external source of electrical power (“shore power”) is established. 8.6.3.8 Fuel System.

8.6.3.8.1Fuel lines shall be protected from chafing at all wear points. [ 1901: 22.5.3.8.1]

8.6.3.8.2If the fuel source is shared with the ambulance engine, a separate fuel pickup system shall be provided that is arranged to ensure that the generator cannot utilize more than 75 percent of the fuel tank's capacity.



8.6.3.9 Exhaust System.8.6.3.9.1 *

The exhaust piping and discharge shall be located or shielded to prevent thermal damage to the ambulance or equipment.

8.6.3.9.2The exhaust shall be piped to the exterior of the vehicle and discharged at a location away from any operator's position. [ 1901: 22.5.3.9.2]

8.6.3.9.2.1The exhaust system for the generator shall comply with Section 5.6 .

8.6.3.9.3Where parts of the exhaust system are exposed so that they can cause injury to operating personnel, protective guards shall be provided.[ 1901: 22.5.3.9.3]

8.6.3.9.4Silencing devices shall be provided and shall not create exhaust backpressure that exceeds the limits specified by the engine manufacturer. [ 1901: 22.5.3.9.4]8.6.4 * Line Voltage Power Derived from the Ambulance Low Voltage Power Supply Systems.If the power source derives its input energy from the ambulance low voltage electrical system, it shall meet the requirements of 8.6.4.1 and 8.6.4.2 .

8.6.4.1The low voltage power supply system shall be installed in compliance with the requirements of Chapter 7 .

8.6.4.2 *The alternator and/or battery system shall be adequate to provide power for continuous operation for a minimum of 2 hours at full output. [ 1901: 22.5.5.2]8.6.5 Power Sources Requiring Elevated Engine Speed.If the power source requires the chassis engine to be operating at a specific fixed speed or a specific speed range, it shall meet the requirements of 8.6.5.1 through 8.6.5.3 .

8.6.5.1The main propulsion engine shall have a governor capable of maintaining the engine speed within the limits required by the power source to meet the frequency control, voltage control, and power output specifications.[ 1901: 22.5.6.1]

8.6.5.2An interlock shall prevent engagement of the generator unless the parking brake is engaged and the transmission is in neutral or not connected to the drive wheels. [ 1901: 22.5.6.2]

8.6.5.3 *Where the chassis engine drives the generator and electronic engine throttle controls are provided, an interlock shall prevent engine speed control from any other source that would interfere with the generator while the generator is operating. [ 1901: 22.5.6.3]8.6.6 * Waveform Created Electronically.






8.6 Power Source–Type Specific Requirements.8.6.1 * Direct Drive (PTO) Generators.If the generator is driven by any type of PTO, it shall meet the requirements of 8.6.1.1 through 8.6.1.3 .

8.6.1.1The transmission's PTO port and PTO, or the split shaft PTO, and all associated driveshaft components shall be rated to support the continuous duty torque requirements of the generator's continuous duty rating as stated on the power source nameplate. [ 1901: 22.5.1.1]

8.6.1.2The direct drive generator shall be mounted so that it does not change the ramp breakover angle, angle of departure, or angle of approach as defined by other components, and it shall not extend into the ground clearance area. [ 1901: 22.5.1.4]

8.6.1.3The direct drive generator shall be mounted away from exhaust and muffler areas or provided with a heat shield to reduce operating temperatures in the generator area. [ 1901: 22.5.1.5]8.6.2 * Hydraulically Driven Generators.If the generator is driven using hydraulic components, it shall meet the requirements of 8.6.2.1 through 8.6.2.3.4 .

8.6.2.1 *A means shall be provided to activate the hydraulic generator system. [ 1901: 22.5.2.1]

8.6.2.2If the hydraulic generator system is not capable of output as stated on the power source specification label at all engine speeds, an automatic engine speed control system shall be provided. [ 1901: 22.5.2.2]8.6.2.3 Hydraulic Components.

8.6.2.3.1A hydraulic system filter and strainer shall be provided and shall be located in a readily accessible area. [ 1901: 22.5.2.4.1]

8.6.2.3.2Hydraulic hose shall meet the hydraulic pump manufacturer's recommendations for pressure, size, vacuum, and abrasion resistance. [ 1901: 22.5.2.4.2]

8.6.2.3.3Hydraulic fittings shall meet the hydraulic pump manufacturer's recommendations for pressure, size, and the type of hose used.[ 1901: 22.5.2.4.3]

8.6.2.3.4Where the hydraulic hose comes into contact with other surfaces, the hose shall be protected from chafing. [ 1901: 22.5.2.5]8.6.3 * Fixed Auxiliary Engine–Driven Generators.If the generator is driven by a fixed auxiliary engine, it shall meet the requirements of 8.6.3.1 through 8.6.3.9.4 .

8.6.3.1




8.6.3.2 *Generators rated at 8 kW or more shall be equipped with a high temperature automatic shutdown system and a low oil (pressure or level) automatic shutdown system. [ 1901: 22.5.3.2]

8.6.3.3The generator shall be installed in accordance with the generator manufacturer's requirements for ventilation and service accessibility.[ 1901: 22.5.3.3]

8.6.3.4If the generator is installed in a compartment and the compartment doors need to be open during its operation, the generator shall be equipped with an interlock system to prevent its operation if the doors are not open, or the compartment shall be equipped with a high temperature alarm.[ 1901: 22.5.3.4]

8.6.3.5If the generator is installed in a compartment on a slide tray and the slide tray must be in the extended or out position during operation, an interlock shall be provided to prevent operation unless the tray is in the correct position, or the compartment shall be equipped with a high temperature alarm. [ 1901: 22.5.3.5]

8.6.3.6Permanently installed generators shall have readily accessible engine oil drain provisions or piping to a remote location for oil changing. [ 1901: 22.5.3.6]

8.6.3.7If the generator is located in a position on the ambulance where the operator cannot see the instrumentation and operate the controls while standing at ground level or positioned at a specifically designated operator station, an operating panel with the required instrumentation, start and stop controls, and other controls necessary for safe operation shall be provided at a remote operator’s panel.

8.6.3.7.1A visual and audible warning shall be provided in the ambulance cab, visible from the operator’s seat to do the following:



8.6.3.7.2The audible warning shall be permitted to be equipped with an override function that resets automatically when the ignition is cycled on.

8.6.3.7.3The generator engine shall shut down and be prevented from restarting automatically when connection to an external source of electrical power (“shore power”) is established. 8.6.3.8 Fuel System.

8.6.3.8.1Fuel lines shall be protected from chafing at all wear points. [ 1901: 22.5.3.8.1]

8.6.3.8.2If the fuel source is shared with the ambulance engine, a separate fuel pickup system shall be provided that is arranged to ensure that the generator cannot utilize more than 75 percent of the fuel tank's capacity.



8.6.3.9 Exhaust System.8.6.3.9.1 *

The exhaust piping and discharge shall be located or shielded to prevent thermal damage to the ambulance or equipment.

8.6.3.9.2The exhaust shall be piped to the exterior of the vehicle and discharged at a location away from any operator's position. [ 1901: 22.5.3.9.2]

8.6.3.9.2.1The exhaust system for the generator shall comply with Section 5.6 .

8.6.3.9.3Where parts of the exhaust system are exposed so that they can cause injury to operating personnel, protective guards shall be provided.[ 1901: 22.5.3.9.3]

8.6.3.9.4Silencing devices shall be provided and shall not create exhaust backpressure that exceeds the limits specified by the engine manufacturer. [ 1901: 22.5.3.9.4]8.6.4 * Line Voltage Power Derived from the Ambulance Low Voltage Power Supply Systems.If the power source derives its input energy from the ambulance low voltage electrical system, it shall meet the requirements of 8.6.4.1 and 8.6.4.2 .

8.6.4.1The low voltage power supply system shall be installed in compliance with the requirements of Chapter 7 .

8.6.4.2 *The alternator and/or battery system shall be adequate to provide power for continuous operation for a minimum of 2 hours at full output. [ 1901: 22.5.5.2]8.6.5 Power Sources Requiring Elevated Engine Speed.If the power source requires the chassis engine to be operating at a specific fixed speed or a specific speed range, it shall meet the requirements of 8.6.5.1 through 8.6.5.3 .

8.6.5.1The main propulsion engine shall have a governor capable of maintaining the engine speed within the limits required by the power source to meet the frequency control, voltage control, and power output specifications.[ 1901: 22.5.6.1]

8.6.5.2An interlock shall prevent engagement of the generator unless the parking brake is engaged and the transmission is in neutral or not connected to the drive wheels. [ 1901: 22.5.6.2]

8.6.5.3 *Where the chassis engine drives the generator and electronic engine throttle controls are provided, an interlock shall prevent engine speed control from any other source that would interfere with the generator while the generator is operating. [ 1901: 22.5.6.3]8.6.6 * Waveform Created Electronically.







8.6.3.7.3The generator engine shall shut down and be prevented from restarting automatically when connection to an external source of electrical power (“shore power”) is established.

The purchaser shall be resposible for training end users to turn off the genset and chassis engine when the ambulance is parked in an enclosed area such as a fire station or garage where the build up of CO is a danger.


This section is dangerous and should be removed. Shore power is an inherently unreliable indicator that a condition exists that would require shut down of a genset. Several problems that would compromise this approach are 1. failing to plug in shore power 2. a power outage or brown out at the station and 3. a tripped breaker on the shore power circuit. The ambulance operator will come to rely on the shore power signal to shut off the genset just as some have come to rely on auto-eject devices to prevent them from driving off with shore power still plugged in. When auto-eject systems fail you only lose a plug and some cable. When the shore power system fails for any of the reasons listed above you run the risk of losing lives.

A simple alarm (as defined in an earlier section) that reminds the operator to turn off the genset if ignition is off paired with training is more than adequate and far safer than this proposal.


Submitter Full Name: TOM RICHARDSONOrganization: [ Not Specified ]Street Address: City:State: Zip: Submittal Date: Mon Jul 08 17:23:29 EDT 2013


I, TOM RICHARDSON, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement ofProblem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am TOM RICHARDSON, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature




8.6.4.2 *The alternator and /or battery system shall be adequate to provide power for continuous operation for a minimum of 2 hours at full output. [ 1901: 22.5.5.2]


Clarification. It is unrealistic to require the battery system to operate an inverter at full output for two hours.









8.7 * Portable Generator Installations.The generator shall comply with Article 445, “Generators,” of NFPA 70. [1901:22.6]8.7.1Any portable generator that can be operated while mounted on the

ambulance shall be as follows:

(1) Installed so that fumes, vapors, heat, excessive noise, and vibrations do not enter interior driving or crew compartments or damage the generator during operation

(2) Have the exhaust outlet located so that exhaust is directed away from any operator station located on the ambulance and guarded to protect the operator

(3) Installed in a location that directs the exhaust and heat at least 12 in. (300 mm) away from the fuel fill, oxygen system, entry doors, and ventilation inlets

8.7.2If the portable generator is remotely mounted, it shall have a remote

operator's control station that shall provide a means for starting and stopping the generator and monitoring the same instrumentation as is required for fixed power sources. [ 1901: 22.6.2]

8.7.3 Wiring for Portable Generator Installations.Wiring installed for the purpose of facilitating the distribution of power from

a portable generator installation to fixed wiring on the ambulance shall conform to the additional requirements of 8.7.3.1 through 8.7.3.5 .

8.7.3.1Circuit conductors shall be sized in relation to the power source

specification label rating and shall be protected by an overcurrent device commensurate with their amperage capacities. [ 1901: 22.6.3.1]

8.7.3.2There shall be a single output connector cord with all of the conductors in

the cord sized to carry a minimum of 115 percent of the nameplate amperage. [ 1901: 22.6.3.2]

8.7.3.3If there is not an overcurrent protection device at the power source, the

output connector cord shall not exceed 72 in. (1830 mm) in length and shall be connected to an overcurrent protection device. [ 1901: 22.6.3.3]

8.7.3.4The rating of an external main overcurrent protection device shall equal

the rated amperage on the power source specification label or the next larger available size overcurrent protection device where so recommended by the power source manufacturer. [ 1901: 22.6.3.4]

8.7.3.5If a connecting plug is required, it shall be sized in relation to the

system and conform to NEMA configurations for plugs. [ 1901: 22.6.3.5]

8.7* Portable Generator Installations. The generator shall comply with Article 445, “Generators,” of NFPA 70 . [ 1901: 22.6]



8.7.1 Any portable generator that can be operated while mounted on the ambulance shall be as follows:




8.7.2 If the portable generator is remotely mounted, it shall have a remote operator's control station that shall provide a means for starting and stopping the generator and monitoring the same instrumentation as is required for fixed power sources. [ 1901: 22.6.2]

8.7.3 Wiring for Portable Generator Installations. Wiringinstalled for the purpose of facilitating the distribution of power from a portable generator installation to fixed wiring on the ambulance shall conform to the additional requirements of 8.7.3.1 through 8.7.3.5 .

8.7.3.1 Circuit conductors shall be sized in relation to the power source specification label rating and shall be protected by an overcurrent device commensurate with their amperage capacities.[ 1901: 22.6.3.1]

8.7.3.2 There shall be a single output connector cord with all of the conductors in the cord sized to carry a minimum of 115 percent of the nameplate amperage. [ 1901: 22.6.3.2]

8.7.3.3 If there is not an overcurrent protection device at the power source, the output connector cord shall not exceed 72 in. (1830 mm) in length and shall be connected to an overcurrent protection device.[ 1901: 22.6.3.3]

8.7.3.4 The rating of an external main overcurrent protection device shall equal the rated amperage on the power source specification label or the next larger available size overcurrent protection device where so recommended by the power source manufacturer. [ 1901: 22.6.3.4]

8.7.3.5 If a connecting plug is required, it shall be sized in relation to the system and conform to NEMA configurations for plugs.[ 1901: 22.6.3.5]







8.7 * Portable Generator Installations.The generator shall comply with Article 445, “Generators,” of NFPA 70 . [ 1901: 22.6]

8.7.1Any portable generator that can be operated while mounted on the ambulance shall be as follows:




8.7.2If the portable generator is remotely mounted, it shall have a remote operator's control station that shall provide a means for starting and stopping the generator and monitoring the same instrumentation as is required for fixed power sources. [ 1901: 22.6.2]8.7.3 Wiring for Portable Generator Installations.Wiring installed for the purpose of facilitating the distribution of power from a portable generator installation to fixed wiring on the ambulance shall conform to the additional requirements of 8.7.3.1 through 8.7.3.5 .

8.7.3.1Circuit conductors shall be sized in relation to the power source specification label rating and shall be protected by an overcurrent device commensurate with their amperage capacities. [ 1901: 22.6.3.1]

8.7.3.2There shall be a single output connector cord with all of the conductors in the cord sized to carry a minimum of 115 percent of the nameplate amperage. [ 1901: 22.6.3.2]

8.7.3.3If there is not an overcurrent protection device at the power source, the output connector cord shall not exceed 72 in. (1830 mm) in length and shall be connected to an overcurrent protection device. [ 1901: 22.6.3.3]

8.7.3.4The rating of an external main overcurrent protection device shall equal the rated amperage on the power source specification label or the next larger available size overcurrent protection device where so recommended by the power source manufacturer. [ 1901: 22.6.3.4]

8.7.3.5If a connecting plug is required, it shall be sized in relation to the system and conform to NEMA configurations for plugs. [ 1901: 22.6.3.5]




8.8 Transfer Switch Applications.8.8.1A transfer switch shall be required to isolate one power source from the other

where a circuit(s) is intended to be supplied from more than one power source. [ 1901: 22.7.2.1]

8.8.2Transfer equipment, including transfer switches, shall operate such that all

ungrounded conductors of one power source are disconnected before any ungrounded conductors of the second power source are connected. [ 1901: 22.7.2.2]

8.8.3The neutral conductor shall be switched through the transfer switch.

[ 1901: 22.7.2.3]

8.8 Transfer Switch Applications.8.8.1 A transfer switch shall be required to isolate one power source

from the other where a circuit(s) is intended to be supplied from more than one power source. [ 1901: 22.7.2.1]

8.8.2 Transfer equipment, including transfer switches, shall operate such that all ungrounded conductors of one power source are disconnected before any ungrounded conductors of the second power source areconnected. [ 1901: 22.7.2.2]

8.8.3 The neutral conductor shall be switched through the transfer switch. [ 1901: 22.7.2.3]

.


Substantiation: It is extremely rare for an ambulance to be equipped with a generator larger than 8kW. Inclusion of this large section of text for an application that is inapplicable to ambulances cannot be justified as part of an ambulance standard







8.8 Transfer Switch Applications.8.8.1

A transfer switch shall be required to isolate one power source from the other where a circuit(s) is intended to be supplied from more than one power source. [ 1901: 22.7.2.1]

8.8.2Transfer equipment, including transfer switches, shall operate such that all ungrounded conductors of one power source are disconnected before any ungrounded conductors of the second power source are connected.[ 1901: 22.7.2.2]

8.8.3The neutral conductor shall be switched through the transfer switch. [ 1901: 22.7.2.3]











8.9 Power Supply Assembly.8.9.1The conductors used in the power supply assembly between the output

terminals of the power source and the main overcurrent protection device shall not exceed 12 ft (4 m) in length. [ 1901: 22.8.1]

8.9.2All power supply assembly conductors, including neutral and grounding

conductors, shall have an equivalent amperage rating and shall be sized to carry not less than 115 percent of the amperage of the nameplate current rating of the power source. [ 1901: 22.8.2]

8.9.3 *If the power supply assembly connects to the vibrating part of a generator

(not a connection on the base), the conductors shall be flexible cord or otherfine-stranded conductors enclosed in metallic or nonmetallic liquidtight flexible conduit rated for wet locations and temperatures not less than 194°F (90°C). [ 1901: 22.8.3]

8.9 Power Supply Assembly.8.9.1 The conductors used in the power supply assembly between the

output terminals of the power source and the main overcurrent protection device shall not exceed 12 ft (4 m) in length. [ 1901: 22.8.1]

8.9.2 All power supply assembly conductors, including neutral and grounding conductors, shall have an equivalent amperage rating and shall be sized to carry not less than 115 percent of the amperage of the nameplate current rating of the power source. [ 1901: 22.8.2]

8.9.3* If the power supply assembly connects to the vibrating part of a generator (not a connection on the base), the conductors shall be flexible cord or other fine-stranded conductors enclosed in metallic or nonmetallic liquidtight flexible conduit rated for wet locations and temperatures not less than 194°F (90°C). [ 1901: 22.8.3]








8.9 Power Supply Assembly.8.9.1

The conductors used in the power supply assembly between the output terminals of the power source and the main overcurrent protection device shall not exceed 12 ft (4 m) in length. [ 1901: 22.8.1]

8.9.2All power supply assembly conductors, including neutral and grounding conductors, shall have an equivalent amperage rating and shall be sized to carry not less than 115 percent of the amperage of the nameplate current rating of the power source. [ 1901: 22.8.2]

8.9.3 *If the power supply assembly connects to the vibrating part of a generator (not a connection on the base), the conductors shall be flexible cord or other fine-stranded conductors enclosed in metallic or nonmetallic liquidtight flexible conduit rated for wet locations and temperatures not less than 194°F (90°C). [ 1901: 22.8.3]











8.10 Overcurrent Protection.Manually resettable overcurrent devices shall be installed to protect the line voltage electrical system components. [1901:22.9]8.10.1 Power Source Protection.A main overcurrent protection device shall be provided that is either incorporated in the power source or connected to the power source by a power supply assembly. [1901:22.9.1]8.10.1.1The size of the main overcurrent protection device shall not exceed 100

percent of the rated amperage stated on the power source specification label or the rating of the next larger available size overcurrent protection device, where so recommended by the power source manufacturer. [ 1901: 22.9.1.1]

8.10.1.2If the main overcurrent protection device is subject to road spray, the unit

shall be housed in a Type 4–rated enclosure. [ 1901: 22.9.1.2]8.10.2 Branch Circuit Overcurrent Protection.Overcurrent protection devices shall be provided for each individual circuit

and shall be sized at not less than 15 amperes in accordance with 240.4, “Protection of Conductors,” of NFPA 70 . [ 1901: 22.9.2]

8.10.2.1Any panelboard shall have a main breaker where the panel has six or

more individual branch circuits or the power source is rated 8 kW or larger. [ 1901: 22.9.2.1]

8.10.2.2Each overcurrent protection device shall be marked with a label to identify

the function of the circuit it protects. [ 1901: 22.9.2.2]8.10.2.3Dedicated circuits shall be provided for any large appliance or device

that requires 60 percent or more of the rated capacity of the circuit to which it is connected, and that circuit shall serve no other purpose. [ 1901: 22.9.2.3]

8.10.3 Panelboards.All fixed power sources shall be hardwired to a permanently mounted

panelboard unless one of the following conditions exists:

(1) All line voltage power connections are made through receptacles on the power source, and the receptacles are protected by integrated overcurrent devices.

(2) Only one circuit is hardwired to the power source, which is protected by an integrated overcurrent device.

[ 1901: 22.9.3]



8.10.3.1The panel shall be visible and located so that there is unimpeded

access to the panelboard controls. [ 1901: 22.9.3.1]8.10.3.2All panelboards shall be designed for use in their intended location.

[ 1901: 22.9.3.2]8.10.3.3The panel(s) shall be protected from mechanical damage, tool

mounting, and equipment storage. [ 1901: 22.9.3.3]8.10.3.4 *Where the power source is 120/240 volts, and 120-volt loads are

connected, the ambulance manufacturer or line voltage system installer shall consider load balancing to the extent that it is possible.

8.10 Overcurrent Protection. Manually resettable overcurrent devices shall be installed to protect the line voltage electrical system components. [ 1901: 22.9]

8.10.1 Power Source Protection. A main overcurrent protection device shall be provided that is either incorporated in the power source or connected to the power source by a power supply assembly. [ 1901: 22.9.1]

8.10.1.1 The size of the main overcurrent protection device shall not exceed 100 percent of the rated amperage stated on the power source specification label or the rating of the next larger available size overcurrent protection device, where so recommended by the power sourcemanufacturer. [ 1901: 22.9.1.1]

8.10.1.2 If the main overcurrent protection device is subject to road spray, the unit shall be housed in a Type 4–rated enclosure.[ 1901: 22.9.1.2]

8.10.2 Branch Circuit Overcurrent Protection. Overcurrentprotection devices shall be provided for each individual circuit and shall besized at not less than 15 amperes in accordance with 240.4, “Protection ofConductors,” of NFPA 70 . [ 1901: 22.9.2]

8.10.2.1 Any panelboard shall have a main breaker where the panel has six or more individual branch circuits or the power source is rated 8 kW or larger. [ 1901: 22.9.2.1]

8.10.2.2 Each overcurrent protection device shall be marked with a label to identify the function of the circuit it protects.[ 1901: 22.9.2.2]

8.10.2.3 Dedicated circuits shall be provided for any large appliance or device that requires 60 percent or more of the rated capacity of the circuit to which it is connected, and that circuit shall serve no otherpurpose. [ 1901: 22.9.2.3]

8.10.3 Panelboards. All fixed power sources shall be hardwired to a permanently mounted panelboard unless one of the following conditions exists:



[ 1901: 22.9.3]8.10.3.1 The panel shall be visible and located so that there is

unimpeded access to the panelboard controls. [ 1901: 22.9.3.1]



8.10.3.2 All panelboards shall be designed for use in their intended location. [ 1901: 22.9.3.2]

8.10.3.3 The panel(s) shall be protected from mechanicaldamage, tool mounting, and equipment storage. [ 1901: 22.9.3.3]

8.10.3.4* Where the power source is 120/240 volts, and 120-volt loads are connected, the ambulance manufacturer or line voltage systeminstaller shall consider load balancing to the extent that it ispossible.











8.10 Overcurrent Protection.Manually resettable overcurrent devices shall be installed to protect the line voltage electrical system components. [ 1901: 22.9]8.10.1 Power Source Protection.A main overcurrent protection device shall be provided that is either incorporated in the power source or connected to the power source by a power supply assembly. [ 1901: 22.9.1]

8.10.1.1The size of the main overcurrent protection device shall not exceed 100 percent of the rated amperage stated on the power source specification label or the rating of the next larger available size overcurrent protection device, where so recommended by the power source manufacturer. [ 1901: 22.9.1.1]

8.10.1.2If the main overcurrent protection device is subject to road spray, the unit shall be housed in a Type 4–rated enclosure. [ 1901: 22.9.1.2]8.10.2 Branch Circuit Overcurrent Protection.Overcurrent protection devices shall be provided for each individual circuit and shall be sized at not less than 15 amperes in accordance with 240.4, “Protection of Conductors,” of NFPA 70 . [ 1901: 22.9.2]

8.10.2.1Any panelboard shall have a main breaker where the panel has six or more individual branch circuits or the power source is rated 8 kW or larger. [ 1901: 22.9.2.1]

8.10.2.2Each overcurrent protection device shall be marked with a label to identify the function of the circuit it protects. [ 1901: 22.9.2.2]

8.10.2.3Dedicated circuits shall be provided for any large appliance or device that requires 60 percent or more of the rated capacity of the circuit to which it is connected, and that circuit shall serve no other purpose. [ 1901: 22.9.2.3]8.10.3 Panelboards.All fixed power sources shall be hardwired to a permanently mounted panelboard unless one of the following conditions exists:



[ 1901: 22.9.3]

8.10.3.1The panel shall be visible and located so that there is unimpeded access to the panelboard controls. [ 1901: 22.9.3.1]

8.10.3.2All panelboards shall be designed for use in their intended location. [ 1901: 22.9.3.2]



8.10.3.3The panel(s) shall be protected from mechanical damage, tool mounting, and equipment storage. [ 1901: 22.9.3.3]

8.10.3.4 *Where the power source is 120/240 volts, and 120-volt loads are connected, the ambulance manufacturer or line voltage system installer shall consider load balancing to the extent that it is possible.











8.10 Overcurrent Protection.Manually resettable overcurrent devices shall be installed to protect the line voltage electrical system components. [ 1901: 22.9]8.10.1 Power Source Protection.A main overcurrent protection device shall be provided that is either incorporated in the power source or connected to the power source by a power supply assembly. [ 1901: 22.9.1]

8.10.1.1The size of the main overcurrent protection device shall not exceed 100 percent of the rated amperage stated on the power source specification label or the rating of the next larger available size overcurrent protection device, where so recommended by the power source manufacturer. [ 1901: 22.9.1.1]

8.10.1.2If the main overcurrent protection device is subject to road spray, the unit shall be housed in a Type 4–rated enclosure. [ 1901: 22.9.1.2]8.10.2 Branch Circuit Overcurrent Protection.Overcurrent protection devices shall be provided for each individual circuit and shall be sized at not less than 15 amperes in accordance with 240.4, “Protection of Conductors,” of NFPA 70 . [ 1901: 22.9.2]

8.10.2.1Any panelboard shall have a main breaker where the panel has six or more individual branch circuits or the power source is rated 8 kW or larger. [ 1901: 22.9.2.1]

8.10.2.2Each overcurrent protection device shall be marked with a label to identify the function of the circuit it protects. [ 1901: 22.9.2.2]

8.10.2.3Dedicated circuits shall be provided for any large appliance or device that requires 60 percent or more of the rated capacity of the circuit to which it is connected, and that circuit shall serve no other purpose. [ 1901: 22.9.2.3]8.10.3 Panelboards.All fixed power sources shall be hardwired to a permanently mounted panelboard unless one of the following conditions exists:



[ 1901: 22.9.3]

8.10.3.1The panel shall be visible and located so that there is unimpeded access to the panelboard controls. [ 1901: 22.9.3.1]

8.10.3.2All panelboards shall be designed for use in their intended location. [ 1901: 22.9.3.2]



8.10.3.3The panel(s) shall be protected from mechanical damage, tool mounting, and equipment storage. [ 1901: 22.9.3.3]

8.10.3.4 *Where the power source is 120/240 volts, and 120-volt loads are connected, the ambulance manufacturer or line voltage system installer shall consider load balancing to the extent that it is possible.













any Sub-Sections] ]

Each switch shall indicate the position of its contact points (i.e., open or closed) and shall be rated for the continuous operation of the load being controlled. [1901:22.11.4]




The intent of this section is unclear. The important information for the user is identification of the switch function as required by section 8.12.4.1. For relay-controlled circuits, there is no reason why a user should be concerned about whether a switch performs its intended function by opening normally closed contacts or closing normally open contacts.The requirement for a switch to indicate the position of its contacts should be eliminated.









8.12.5.2Receptacles in the ambulance module shall be flush or nearflush , vertically mounted.




When customers require receptacles behind the cab seats, the use of a handy box for surface mounting is preferred. The standard should not prohibit that practice.There is no basis for requiring vertical orientation. NEC does not specify a mounting orientation. In the last few NEC revision cycles, proposals to specify the mounting orientation were all rejected. Ambulance receptacles are almost always mounted vertically, but there are instances where they need to be rotated, and there is no basis for this standard to restrict that option.









8.12.5.10.2If the receptacle is dc DC or other than single phase, that information shall also be marked on the label. [ 1901: 22.11.5.5.2]


Clarification and consistency.









8.12.5.12Receptacles used for dc DC voltages shall be rated for dc DC service. [ 1901: 22.11.5.7]


Clarification and consistency.









8.13 Cord Reels

.

8.13.1

All permanently mounted cord reels shall be rated for continuous duty and installed to be accessible for removal, cord access, maintenance, and servicing. [ 1901: 22.12]

8.13.2The power rewind cord reel spool area shall be visible

to the operator during the rewind operation, or the reel spool shall be encapsulated to prevent cord fromspooling off the reel. [ 1901: 22.12.1]

8.13.3Rollers or guides shall be provided, where required,

to prevent damage to the cord at reel spools or compartment openings. [ 1901: 22.12.2]

8.13.4 Rewind Provision.

8.13.4.1Manually operated reels shall have a hand crank.

[ 1901: 22.12.3.1]

8.13.4.2Power rewind–type reels shall have the control in a

position where the operator can observe the rewinding operation.

8.13.4.3If a reel is in an enclosure or out of direct view, the

cord entry point to the enclosure shall be visible to the operator of the reel control.

8.13.4.4The rewind control or crank shall not be more than

72 in. (1830 mm) above the operator's standing position. [ 1901: 22.12.3.3]

8.13.4.5



The rewind control shall be marked with a label indicating its function and shall be guarded to prevent accidental operation. [ 1901: 22.12.3.4]

8.13.5 *The reel shall be designed to hold 110 percent of

the capacity needed for the intended cord length. [ 1901: 22.12.4]

8.13.6 *The wire size shall be in accordance with NFPA

70 , Table 400.5(A), but in no case shall it be smaller than 12 AWG. [ 1901: 22.12.5]

8.13.7 *Electrical cord shall be Type SEOOW, Type

SOOW, or Type STOOW. [ 1901: 22.12.6]

8.13.8 *A label that indicates the following information

shall be provided in a visible location adjacent to anypermanently connected reel:

(1) Current rating

(2) Current type

(3) Phase

(4) Voltage

(5) Total cord length

[ 1901: 22.12.7]

8.13.9

Where a power distribution box is hardwired to the end of a cord that is stored on a fixed cord reel or other fixed storage means, the requirements in 8.13.9.1 through 8.13.9.6 shall apply. [ 1901: 22.12.8]

8.13.9.1The remote power distribution box shall be

listed for use in a wet location.[ 1901: 22.12.8.1]

8.13.9.2 *The distribution box shall be as

follows:

(1) Protected from corrosion



(2) Capable of being carried with a gloved hand

(3) Designed to keep the exterior electrical components above 2 in. (51 mm) of standingwater

[ 1901: 22.12.8.2]

8.13.9.3Inlets, receptacles, circuit breakers, or GFCI

devices shall not be mounted on the top surface of the horizontal plane. [ 1901: 22.12.8.3]

8.13.9.4Branch circuit breakers shall be installed in the

remote power distribution box if the overcurrent device protecting the feed cord to the box is too large to protect the wiring supplying the devices plugged onto the distribution box. [ 1901: 22.12.8.4]

8.13.9.5 *

Remote power distribution boxes shall have a light on the box to indicate the power is on. [ 1901: 22.12.8.5]

8.13.9.5.1 *The light shall be visible in a 360-degree

plane from a minimum of 200 ft (60 m) in complete darkness. [ 1901: 22.12.8.5.1]

8.13.9.5.2The light shall be mechanically protected to

prevent damage. [ 1901: 22.12.8.5.2]

8.13.9.6The hardwired portable cord connection to

the box shall have strain relief and meet the intended usage requirements. [ 1901: 22.12.8.6]






This section should be eliminated from the ambulance standard on the basis that it is extremely rare for an ambulance to have a cord reel.If, for some reason it is deemed necessary to include standards for a cord reel, it would be better to simply stipulate compliance with the applicable section of NFPA 1901.








Public Input No. 367-NFPA 1917-2013 [ Chapter 9 ]

Chapter 9 Test Methods9.1 Ambulance Body Structure Test.9.1.1 Roof Crush Test.

9.1.1.1The following steps shall be performed during the roof crush test:

(1) Support the ambulance on a rigid fixture independent of the vehiclesuspension.

(2) Remove any components that extend upward from the vehicle roof.

(3) Measure and record the distance from the mounting surface to each of the four corners of the roof.

(4) Employ a rectangular force application plate fitted as near as possible to the contour of the ambulance roof.

(5) Position the force application plate so that it is centered on the roof.

(6) Close all ambulance doors.

(7) Load the application plate to 500 lb (227 kg) at a deflection rate less than 0.5 in. (13 mm) per second.

(8) Record elevation readings of all four corners of the roof.

(9) Load the application plate to 50 percent of the final load at a deflection rate less than 0.5 in. (13 mm) per second.




(13) Verify that patient compartment doors are capable of being opened and closed.

(14) Remove load.

(15) Verify that patient compartment doors are capable of being opened andclosed.

9.1.1.2The application plate required in 9.1.1.1 (4) shall be a minimum of 5 in. (127 mm) longer and 5 in. (127 mm) wider than the vehicle roof of the patient’scompartment.

9.1.1.3For the purposes of the measurements in 9.1.1.2 , the ambulance roof shall be that structure, seen in the top projected view, that coincides with the patient compartment of the ambulance, as shown in Figure 9.1.1.3(a) and Figure 9.1.1.3(b) .Figure 9.1.1.3(a) Type I and Type III Ambulance Patient Compartment Roof Measurement.



Figure 9.1.1.3(b) Type II Ambulance Patient Compartment Roof Measurement.

9.1.2 Side Crush Test (Type I and Type III Only).9.1.2.1

The following steps shall be performed during the side crush test:

(1) Place either side of the body of the ambulance on a rigid horizontal surface so that the body of the ambulance is entirely supported.

(2) Measure and record the distance from the mounting surface to each of the four top corners of the body side.

(3) Employ a rigid, rectangular force application plate fitted as near as possible to the contour of the ambulance side.

(4) Position the force application plate so that it is centered on the patient compartment side.



(7) Record elevation readings of all four corners of the body side.





(12) Verify that the rear patient compartment doors are capable of being opened and closed.

(13) Remove load.


9.1.2.2



The application plate required in 9.1.2.1 (3) shall be a minimum of 5 in. (127 mm) longer and 5 in. (127 mm) wider than the vehicle side of the patient’scompartment.9.2 Body Door Test (Type I and Type III Only).

9.2.1The following steps shall be performed during the body door test:

(1) Position the test structure or ambulance on a level, horizontal surface.

(2) Employ force application fixtures in such a manner that the opposing forces are supported by the body structure.

(3) Apply force for 10 seconds in all required directions and/or positions after the installation of associated body door retention components.

(4) Apply force for 10 seconds to a continuous hinge so that the load will be distributed equally from top to bottom.

(5) Apply force for 10 seconds to individual (strap-type) hinges so that the load will be distributed proportionally on each hinge.

(6) Apply force so that it will be equally distributed as near the latch or hinge as practical.

9.2.2The patient compartment shall be structurally complete but need not include interior panels or cabinet installation.

9.2.3Employ force application fixtures in such a manner that the opposing forces shall be supported by the body structure.

9.2.4Apply force for 10 seconds in all required directions and/or positions after the installation of associated body door retention components.

9.2.5Apply force for 10 seconds to a continuous hinge so that the load will be distributed equally from top to bottom.

9.2.6Apply force for 10 seconds to individual (strap type) hinges so that the load will be distributed proportionally on each hinge.

9.2.7Apply force so that it will be equally distributed as near the latch or hinge as practical.9.3 Oxygen Tank Retention System Static Test.

9.3.1The following steps shall be performed during the oxygen tank retention system static test as shown in Figure 9.3.1 :

(1) Test the retention system in a substantially similar ambulance or mounted to a structure that is substantially similar to the ambulance.

(2) Apply forces using a rigid simulated cylinder having the same physical dimensions as the oxygen tank for which the tank holder was designed as shown in Figure 9.3.1

(3) Apply each force so that it passes through the location that corresponds to the center of gravity of a full tank.

(4) Apply the test force for 10 seconds in the direction of cylinder extraction and in both axial directions.



Figure 9.3.1 Oxygen Tank Retention Test.

9.4 Patient Cot Retention System Static Test.The following actions shall be performed during the patient cot retention system static test:

(1) Test the retention system in a substantially similar ambulance or mounted to a structure that is substantially similar to the ambulance floor.

(2) Employ a test fixture that simulates the cot for which the retention system is designed.

(3) Install the test fixture in the retention system in such a manner that will preclude contact friction with the floor or cabinet surfaces.

(4) Apply each force so that it passes through the location that corresponds to the center of gravity of a loaded patient cot.

(5) Apply the test force for 10 seconds in the fore, aft, side-to-side, and vertical directions relative to the direction of vehicle travel.

(6)

9.5 Low Voltage Electrical System Test.9.5.1 *

The ambulance's low voltage electrical system shall be tested as required by this section, the test results shall be certified by the ambulance manufacturer, and the certified test results shall be delivered with the ambulance.

9.5.2Tests shall be performed when the ambient air temperature is between 60°F and 110°F (15°C and 43°C).9.5.3 Test Sequence.

9.5.3.1The three tests defined in 9.5.3.2 through 9.5.3.4.4 shall be performed in the order in which they appear.

9.5.3.1.1Before each test, the batteries shall be fully charged until the voltage stabilizes at the voltage regulator set point and the lowest charge current is maintained for 10 minutes.

9.5.3.1.2Failure of any of these tests shall require a repeat of the sequence.9.5.3.2 Reserve Capacity Test.

9.5.3.2.1The engine shall be started and kept running until the engine and engine compartment temperatures are stabilized at normal operating temperatures and the battery system is fully charged.

9.5.3.2.2

* Replace any damaged parts after each application of force.



The engine shall be shut off, and the minimum continuous electrical load shall be activated for 10 minutes.

9.5.3.2.3All electrical loads shall be turned off prior to attempting to restart the engine.

9.5.3.2.4The battery system shall then be capable of restarting the engine.

9.5.3.2.5Failure to restart the engine shall be considered a test failure of the battery system.9.5.3.3 Alternator Performance Test at Idle.

9.5.3.3.1The minimum electrical load test conditions as stated in 7.3.2.1.1 shall beactivated with the engine running at idle speed.

9.5.3.3.2The engine temperature shall be stabilized at normal operating temperature.

9.5.3.3.3The battery system shall be tested to detect the presence of battery discharge current.

9.5.3.3.4The detection of battery discharge current shall be considered a test failure.9.5.3.4 Alternator Performance Test at High Idle.

9.5.3.4.1The operational electrical load test conditions as stated in 7.4.1 shall beactivated with the engine running at high idle.

9.5.3.4.2The test duration shall be a minimum of 30 minutes.

9.5.3.4.3Activation of the load management system shall be permitted during this test.

9.5.3.4.4An alarm sounded by excessive battery discharge, as detected by the warning system required in Chapter 7 , or a system voltage of less than 11.8 volts dc for a 12-volt nominal system, 23.6 volts dc for a 24-volt nominal system, or 35.4 volts dc for a 42-volt nominal system for more than 120 seconds shall be considered a test failure.9.5.4 Low Voltage Alarm Test.

9.5.4.1The following test shall be started with the engine off and the battery voltage at or above 12 volts for a 12-volt nominal system, 24 volts for a 24-volt nominal system, or 36 volts for a 42-volt nominal system.

9.5.4.2With the engine shut off, the total continuous electrical load shall be activated and shall continue to be applied until the excessive battery discharge alarm activates.

9.5.4.3The battery voltage shall be measured at the battery terminals.

9.5.4.4The test shall be considered a failure if the alarm does not sound in less than 140 seconds after the voltage drops to 11.70 volts for a 12-volt nominal system, 23.4 volts dc for a 24-volt nominal system, or 35.1 volts for a 42-volt nominal system.

9.5.4.5The battery system shall then be able to restart the engine.

9.5.4.6Failure to restart the engine shall be considered a test failure.



9.6 Patient Compartment Sound Level Test.9.6.1

This test shall be performed during the following environmental conditions:

(1) Temperature not to exceed 95°F (35°C)

(2) Humidity not to exceed 75 percent relative humidity

(3) Wind velocity not to exceed 12 mph (19 km/hr)

(4) Barometric pressure 29 in. Hg to 31 in. Hg (98.2 kPa to 104.9 kPa)

9.6.2The following steps shall be performed during the patient compartment sound level test:

(1) Measure sound level using a meter that meets the requirements of ANSI S1.4, Specification for Sound Level Meters , for Type II meters with the meter set to A for a weighting network, “fast” meter response.

(2) Suspend the microphone 23 in. (584 mm) above the vehicle floor, centered laterally and longitudinally on the expected center of the patient cot as it will be secured in the patient compartment.

(3) Park the ambulance on a concrete or asphalt surface, at a location so that no large reflecting surfaces, such as other vehicles, signboards, buildings, or hills, are within 50 ft (15.2 m) of the vehicle being tested.

(4) Close all ambulance doors, windows, and vents.

(5) Run air conditioner and heater blower fans in patient compartment at the highest speed.

(6) Set vehicle transmission in neutral gear and set the engine speed to the rpm obtained by the ambulance when operating on level ground at 55 mph (88 km/hr).

(7) Turn on all warning lights.

(8) Operate siren in the loudest mode.(9) Measure and record the highest sound level.

(10) Decrease the engine speed to idle and then back to the 55 mph (88 km/hr) rpm.

(11) Measure and record the highest sound level.

(12) Repeat until two maximum sound levels within 2 decibels (dB) of each other are recorded.

(13) Numerically average these two maximum sound level readings.

9.7 Reserved.9.8 Handrail Static Load Test.

The following steps shall be performed during the handrail static load test:

(1) Apply force to handrail at the midpoint between every location where the handrail fastens to the vehicle body structure and as near as possible to the ends of the handrail, as shown in Figure 9.8(a) .

(2) Apply the force perpendicular to the mounting surface.

(3) Apply the force parallel to the mounting surface.



(4) Apply the force diagonal to the mounting surface at an angle midway between the perpendicular and the parallel pulls, as shown in Figure9.8(b) .

(5) Maintain each force application for 2 minutes.

Figure 9.8(a) Location of Force Application on Handrail.

Figure 9.8(b) Direction of Force Application on Handrail.

9.9 * Line Voltage Electrical Systems Test.9.9.1

The wiring and associated equipment shall be tested by the ambulance manufacturer or the installer of the line voltage system.

9.9.2 *The electrical polarity of all permanently wired equipment, cord reels, and receptacles shall be tested to verify that wiring connections have been properly made.

9.9.3Electrical continuity shall be verified from the chassis or the body to all line voltage electrical enclosures, light housings, motor housings, light poles, switch boxes, and receptacle ground connections that are accessible to personnel in normal operations.

9.9.4If the ambulance is equipped with a transfer switch, it shall be tested to verify operation and that all nongrounded conductors are switched.

9.9.5Electrical light towers, floodlights, motors, fixed appliances, and portable generators shall be operated at their full rating or capacity for 30 minutes to ensure proper operation.9.9.6 * Certification Test of Power Source.

9.9.6.1



The ambulance manufacturer or installer of the power source shall perform a certification test on each power source.

9.9.6.2The testing of any power source greater than 3 kW shall be witnessed, and the results of the tests of the power source shall be certified by an independent third-party certification organization.9.9.6.3 Test Procedure.

9.9.6.3.1The prime mover shall be started from a cold start condition, and the unloaded voltage and frequency shall be recorded.

9.9.6.3.2The line voltage electrical system shall be loaded to at least 100 percent of the continuous rated wattage stated on the power source specification label.

9.9.6.3.3Testing with a resistive load bank shall be permitted.

9.9.6.3.4The power source shall be operated in the manner specified by the ambulance manufacturer as documented on instruction plates or in operation manuals.

9.9.6.3.5The power source shall be operated at a minimum of 100 percent of the continuous rated wattage as stated on the power source specification label for a minimum of 2 hours.

9.9.6.3.5.1The load shall be adjusted to maintain the output wattage at or above the continuous rated wattage during the entire 2-hour test.

9.9.6.3.5.2The following conditions shall be recorded at least every 30 minutes during the test:

(1) The power source output voltage, frequency, and amperage

(2) The prime mover's oil pressure, water temperature, and transmission temperature, if applicable

(3) The power source hydraulic fluid temperature, if applicable

(4) The ambient temperature and power source air inlet temperature

9.9.6.3.5.3The following conditions shall be recorded once during the test for power sources driven by dedicated auxiliary internal combustion engines:

(1) Altitude

(2) Barometric pressure

(3) Relative humidity

9.9.6.3.6If the generator is driven by the chassis engine and the generator allows for operation at variable speeds, the chassis engine speed shall be reduced to the lowest rpm allowed for generator operation, and the voltage and frequency shall be recorded.

9.9.6.3.7The load shall be removed, and the unloaded voltage and frequency shall be recorded.



9.9.6.3.8Voltage shall be maintained within ±10 percent of the voltage stated on the power source specification label during the entire test.

9.9.6.3.9Frequency shall be maintained within ±3 Hz of the frequency stated on the power source specification label during the entire test.9.10 Water Leak Test.The water leak test shall be performed during the following environmental conditions:

(1) Temperature above 40°F (4°C)


9.10.1The following steps shall be performed during the water leak test:

(1) Close all windows and doors.

(2) Turn off heating, ventilating, and air conditioning (HVAC) systems.

(3) Drench the entire roof, sides, front, and back of the vehicle evenly with water spray from a nozzle or combination of nozzles.

(4) Continue spraying until a minimum of 40 gal (151 L) of water has been used.

(5) Start engine and operate the cab and patient compartment ventilation systems at maximum ventilation rates.

(6) Continue spraying until an additional minimum of 40 gal (151 L) of water has been used.

(7) Inspect the interior of the cab and patient compartment for water leaks during the duration of the test.

(8) At the conclusion of the test, examine all exterior lights and exterior compartments for leakage.

9.11 Equipment Temperature Test.The following steps shall be performed during the equipment temperature test:

(1) Locate the test vehicle in an environmental chamber capable of maintaining a temperature within ±4°F (2°C).

(2) Turn off all vehicle power.

(3) Open all patient compartment entry doors, cabinet doors, cab door windows, and exterior compartment doors.

(4) Maintain an air velocity over the vehicle of at least 5 mph (8 km/hr) throughout the entire test.

(5) Cool the chamber to 32°F (0°C) and soak the vehicle at this temperature for a minimum of 3 hours.

(6) Start the engine.

(7) Operate all vehicle systems for 1 hour while maintaining 32°F (0°C) chamber temperature.



(8) Shut off the engine.

(9) Heat the chamber to 95°F (35°C) and soak the vehicle at this temperature for a minimum of 3 hours.




9.12 Interior Climate Control Test.The following steps shall be performed during the interior climate control test:


(2) Locate three thermocouples 7 in. (178 mm) off the floor along the patient compartment centerline and equally spaced from front to back.

(3) Locate three thermocouples 7 in. (178 mm) below the ceiling along the patient compartment centerline and equally spaced from front to back.

(4) Locate three thermocouples midway between the floor and the ceiling along the patient compartment centerline and equally spaced from front to back.

(5) Locate three thermocouples in the cab horizontally positioned 24 in. (600 mm) above the seat cushion and located 12 in. (300) in front of the headrest.

(6) Locate the first and third thermocouples along the centerline of the driver’s and passenger’s seats and center the second between the first and third.



(9) Open engine hood.


(11) Cool the chamber to 32°F ± 4°F (0° C ± 2°C) and soak the vehicle at this temperature for a minimum of 3 hours.

(12) Close all doors and hood with the exception of partition doors (if present) and patient compartment/cab partition window (if present).

(13) Set heaters in cab and patient compartment to maximum heating setting (maximum temperature, maximum blower speed, recirculating air).

(14) Record the thermocouple temperatures.

(15) Shut off patient compartment dome lights.

(16) Start engine and maintain transmission in neutral or park and engine high idle on with a maximum engine speed of 1500 rpm.

(17) Record thermocouple temperatures at 5-minute intervals up to 30 minutes.





(20) Open the engine hood.

(21) Heat the chamber to 95°F (35°C) with a minimum of 40 percent relative humidity and soak the vehicle at this temperature for aminimum of 3 hours.

(22) Close the hood; all doors, with the exception of partition doors (if present); and all windows, with the exception of the patient compartment/cab partition window (if present).

(23) Set the air conditioners in the cab and the patient compartment to maximum cooling setting (maximum blower speed, coldest temperature setting, recirculating air).


(25) Shut off the patient compartment dome lights.(26) Start the engine and maintain the transmission in neutral or park and

engine high idle on with a maximum engine speed of 1500 rpm.



9.13 Reserved.9.14 Engine Cooling System Test.

The following steps shall be performed during the engine cooling system test:






(6) Close all doors, cab door windows, hood, partition door (if present), and patient compartment/cab partition window (if present).


(8) Set air conditioners in cab and patient compartment to maximum cooling setting (maximum blower speed, coldest temperature setting,recirculating air).

(9) With all other ambulance equipment off, operate the engine at high idle for 1 hour.

9.15 Ambulance Main Oxygen System Test.



9.15.1 Pressure Test.The following steps shall be performed during the engine cooling system test:

(1) Ensure that the ambulance temperature has stabilized in an environment between 34°F and 110°F (1°C and 43°C).

(2) Charge the system with approximately 200 psi (1380 kPa) of test gas.(3) Close system valves to trap pressure in the lines that contain the vent

valve.

(4) Record the system pressure with an accuracy of ±0.1 psi (0.7 kPa).

(5) Allow the system to rest without disturbance for 2 hours.

(6) Record the system pressure.

9.15.2 Flow Test.The following steps shall be performed for the flow test:


(2) Charge the system with test gas regulated to 50 psi ± 2 psi (345 kPa ±14 kPa).

(3) Plug all outlets other than the one being tested.

(4)

(5) Check the electrical continuity between the oxygen system piping and the vehicle to verify that it is grounded.

9.16 Patient Compartment Lighting Level Test.The following steps shall be performed for the patient compartment lighting level test:

(1) Prepare the ambulance or locate it in an environment to prevent light from penetrating into the patient compartment.

(2) Remove the patient cot.


(4) Turn on dome lights to highest setting.

(5) Measure and record the light intensity along the longitudinal centerline of the patient compartment floor every 10 in. (254 mm).

(6) Turn on the lights that come on with the side entry door or rear entry door.


(8) Measure and record the light intensity in the center of the side entry step well and record the reading.

* Measure and record the flow of gas from each outlet using a flowmeter with an accuracy of ±0.07 ft 3 /min (±2 L/min).



(9) Install the patient cot test grid shown in Figure 9.16 , 17 in. (432 mm) above the patient compartment floor, centered laterally and longitudinally on the expected center of the patient cot as it will be secured in the patient compartment.

(10) Measure and record the light intensity in the center of each 5 in. 2

(322 mm 2 ) area on the test grid.

Figure 9.16 Patient Cot Test Grid, Top View.

9.17 Reserved.9.18 Rear Stepping Surface Load Test.

The following steps shall be performed during the rear stepping surface load test:

(1) Support the ambulance or substantially similar structure to negate the effect of the vehicle suspension.

(2) Apply a vertical load on the stepping surface using a fixture that distributes the load over a circular area 5 in. (127 mm) in diameter.

(3) Apply 500 lb (227 kg) of load to the lateral and longitudinal center of the stepping surface.

(4) Record deflection during the load application.

(5) Release the load.

(6) Measure and record any permanent deformation after the load is released.

(7) Apply 500 lb (227 kg) of load to the longitudinal center of the stepping surface as close to each of the lateral extremes as the test fixture will allow.




9.19 Reserved.9.20 Reserved.9.21 Aspirator System Test.The following steps shall be performed during the aspirator system test:


(2) Run the vehicle engine at high idle speed for duration of the test.



9.21.1 Vacuum Test.The following steps shall be performed during the vacuum test:

(1) Install a 120 in. (3 m) length of transparent or translucent, nonkinking suction tubing on the collection bottle.

(2) Install a vacuum-measuring instrument capable of an accuracy of ±5 mm Hg (0.666 kPa) to measure the vacuum in the collection bottle.

(3) Open the vacuum control valve and the shutoff valve to their full open position.

(4) Turn on the vacuum pump.

(5) Clamp or plug the end of the suction tubing.

(6) Measure and record the vacuum 4 seconds after plugging the tubing.

9.21.2 Flow Test.The following steps shall be performed during the flow test:

(1) Install a flow-measuring instrument capable of an accuracy of ±0.035 ft 3 /min (1 L/min) to measure the flow in the suction tubing.


(3) Turn on vacuum pump.

(4) Measure and record the flow.

9.22 Reserved.9.23 Reserved.9.24 Perimeter Illumination Test.

The following steps shall be performed during the perimeter illumination test:

(1) Place the ambulance in a dark environment.

(2) Ensure that the vehicle batteries are fully charged.

(3) Record the light intensity with a meter capable of measuring to an accuracy of ±0.01 fc.

(4) Construct a grid of test points off the sides and rear of the test ambulance, as shown in Figure 9.24 .

(5) Locate lines parallel with the exterior walls of the patient compartment 60 in. and 120 in. (1524 mm and 3048 mm) from the test unit.

(6) Intersect these lines with lines perpendicular to the exterior walls emanating from each corner and the midpoint of the patientcompartment.

(7) Construct additional perpendicular lines emanating from the center of each scene light.



(8) Measure and record the light intensity at each point in the grid.

(9) Turn on all exterior scene lights.

(10) Measure and record the light intensity at each point 3 in. (76 mm) above the grid.

(11) Subtract the ambient light readings from the scene light readings.

Figure 9.24 Perimeter Illumination Test Grid.

9.25 Occupant Head Clearance Zones Test.9.25.1

The following steps shall be performed during the occupant head clearance zones test:

(1) Construct a rigid rectangular test box 43 in. (1092 mm) high, 24 in. (457 mm) wide, and 15 in. (381 mm) deep.

(2) Place the test box in each seating position, centered laterally on the seat cushion, with the bottom edge resting against the seat back.

(3) Align the test box so that the sides of the box are perpendicular to the patient compartment floor.

9.25.2The maximum weight for the test fixture shall not exceed 60 lb (27 kg).

9.25.3No permanent objects shall protrude into the test box zone.


Substantiation: Chapter 9 should be deleted in its entirety. The AMD standards for testing should be incorporated by reference into NFPA 1917 as they have an established process for updating and revision that is more than satisfactory. By incorporating by reference the AMD standards, as they are revised they would immediately update NFPA 1917. Finally, Chapter 9 consists of the AMD standards which are redundant. Deleting this text will create consistency with Public Input 64.




Public Input No. 5-NFPA 1917-2013 [ Chapter 9 ]

Chapter 9 Test Methods The initial testing and inspections required for certification shall be performed by:1. A Nationally recognized testing laboratory, recognized by OSHA under Appendix A to 29 CFR 1910.7Or2. An ISO/IEC 17025 accredited laboratory by an accreditation body that is recognized by the National Cooperation for LaboratoryAccreditation (NACLA) or is a signatory to the International LaboratoryAccreditation Cooperation (ILAC) Mutual Recognition Arrangement (MRA). The scope of accreditation shall include all tests in chapter 9.The individual certifications shall remain valid for seven years as long as the type of ambulance tested remains in production. Design changes during the seven year certification period must be tested at the time of production release. Certifications that appear on the ambulance need not be re-submitted (i.e.; DOT, EPA, etc.). Certification(s) will be acceptable in lieu of actual verification test during inspections providing supporting verifying data complying with this section is on file for examination. Certification from OEM and individual equipment manufacturers are acceptable providing they are not part of a system(s) or altered and in accordance with the certification letter format required in this document. Type certifications of individual components and equipment products are acceptable.Each ambulance constructed shall be tested by the FSAM to demonstrate compliance with:

12-VOLT DC ELECTRICAL SYSTEM TEST•125-VOLT AC ELECTRICAL SYSTEMS TEST•WATER SPRAY TEST•AMBULANCE MAIN OXYGEN SYSTEM TEST•ASPIRATOR SYSTEM TEST, PRIMARY PATIENT•MEASURING GUIDELINES: OCCUPANT HEAD CLEARANCEZONES

•

This is in addition to the initial type testing certification required.

9. 1 Ambulance Body Structure Test. 9.1.1 Roof Crush Test. 9.1.1.1 The following steps shall be performed during the roof crush test:

(1) Support the ambulance on a rigid fixture independent of the vehicle suspension.

(2) Remove any components that extend upward from the vehicle roof.



(3) Measure and record the distance from the mounting surface to each of the four corners of the roof.

(4) Employ a rectangular force application plate fitted as near as possible to the contour of the ambulance roof.

(5) Position the force application plate so that it is centered on the roof.

(6) Close all ambulance doors.(7) Load the application plate to 500 lb (227 kg) at a deflection rate less

than 0.5 in. (13 mm) per second.





(12) Record elevation readings of all four corners of the roof.(13) Verify that patient compartment doors are capable of being opened

and closed.

(14) Remove load.

(15) Verify that patient compartment doors are capable of being opened and closed.

9.1.1.2 The application plate required in 9.1.1.1 (4) shall be a minimum of 5 in. (127 mm) longer and 5 in. (127 mm) wider than the vehicle roof of the patient’s compartment.9.1.1.3 For the purposes of the measurements in 9.1.1.2 , the ambulance roof shall be that structure, seen in the top projected view, that coincides with the patient compartment of the ambulance, as shown in Figure 9.1.1.3(a) and Figure 9.1.1.3(b) .Figure 9.1.1.3(a) Type I and Type III Ambulance Patient Compartment Roof Measurement.

Figure 9.1.1.3(b) Type II Ambulance Patient Compartment Roof Measurement.

9.1.2 Side Crush Test (Type I and Type III Only).



9.1.2.1 The following steps shall be performed during the side crush test:

(1) Place either side of the body of the ambulance on a rigid horizontal surface so that the body of the ambulance is entirely supported.

(2) Measure and record the distance from the mounting surface to each of the four top corners of the body side.

(3) Employ a rigid, rectangular force application plate fitted as near as possible to the contour of the ambulance side.

(4) Position the force application plate so that it is centered on the patient compartment side.









(13) Remove load.


9.1.2.2 The application plate required in 9.1.2.1 (3) shall be a minimum of 5 in. (127 mm) longer and 5 in. (127 mm) wider than the vehicle side of the patient’s compartment.9.2 Body Door Test (Type I and Type III Only). 9.2.1 The following steps shall be performed during the body door test:

(1) Position the test structure or ambulance on a level, horizontal surface.

(2) Employ force application fixtures in such a manner that the opposing forces are supported by the body structure.

(3) Apply force for 10 seconds in all required directions and/or positions after the installation of associated body door retention components.

(4) Apply force for 10 seconds to a continuous hinge so that the load will be distributed equally from top to bottom.

(5) Apply force for 10 seconds to individual (strap-type) hinges so that the load will be distributed proportionally on each hinge.

(6) Apply force so that it will be equally distributed as near the latch or hinge as practical.

9.2.2 The patient compartment shall be structurally complete but need not include interior panels or cabinet installation.9.2.3



Employ force application fixtures in such a manner that the opposing forces shall be supported by the body structure.9.2.4 Apply force for 10 seconds in all required directions and/or positions after the installation of associated body door retention components.9.2.5 Apply force for 10 seconds to a continuous hinge so that the load will be distributed equally from top to bottom.9.2.6 Apply force for 10 seconds to individual (strap type) hinges so that the load will be distributed proportionally on each hinge.9.2.7 Apply force so that it will be equally distributed as near the latch or hinge aspractical.9.3 Oxygen Tank Retention System Static Test. 9.3.1 The following steps shall be performed during the oxygen tank retention system static test as shown in Figure 9.3.1 :

(1) Test the retention system in a substantially similar ambulance or mounted to a structure that is substantially similar to the ambulance.

(2) Apply forces using a rigid simulated cylinder having the same physical dimensions as the oxygen tank for which the tank holder was designedas shown in Figure 9.3.1

(3) Apply each force so that it passes through the location that corresponds to the center of gravity of a full tank.

(4) Apply the test force for 10 seconds in the direction of cylinder extraction and in both axial directions.

Figure 9.3.1 Oxygen Tank Retention Test.

9.4 Patient Cot Retention System Static Test. The following actions shall be performed during the patient cot retention system static test:




(4) Apply each force so that it passes through the location thatcorresponds to the center of gravity of a loaded patient cot.


(6)

9.5 Low Voltage Electrical System Test. 9.5.1*




The ambulance's low voltage electrical system shall be tested as required by this section, the test results shall be certified by the ambulance manufacturer, and the certified test results shall be delivered with theambulance.9.5.2 Tests shall be performed when the ambient air temperature is between 60°F and 110°F (15°C and 43°C).9.5.3 Test Sequence. 9.5.3.1 The three tests defined in 9.5.3.2 through 9.5.3.4.4 shall be performed in the order in which they appear.9.5.3.1.1 Before each test, the batteries shall be fully charged until the voltage stabilizes at the voltage regulator set point and the lowest charge current is maintained for 10 minutes.9.5.3.1.2 Failure of any of these tests shall require a repeat of the sequence.9.5.3.2 Reserve Capacity Test. 9.5.3.2.1 The engine shall be started and kept running until the engine and engine compartment temperatures are stabilized at normal operating temperatures and the battery system is fully charged.9.5.3.2.2 The engine shall be shut off, and the minimum continuous electrical load shall be activated for 10 minutes.9.5.3.2.3 All electrical loads shall be turned off prior to attempting to restart theengine.9.5.3.2.4 The battery system shall then be capable of restarting the engine.9.5.3.2.5 Failure to restart the engine shall be considered a test failure of the battery system.9.5.3.3 Alternator Performance Test at Idle. 9.5.3.3.1 The minimum electrical load test conditions as stated in 7.3.2.1.1 shall be activated with the engine running at idle speed.9.5.3.3.2 The engine temperature shall be stabilized at normal operating temperature.9.5.3.3.3 The battery system shall be tested to detect the presence of battery discharge current.9.5.3.3.4 The detection of battery discharge current shall be considered a test failure.9.5.3.4 Alternator Performance Test at High Idle. 9.5.3.4.1 The operational electrical load test conditions as stated in 7.4.1 shall be activated with the engine running at high idle.9.5.3.4.2 The test duration shall be a minimum of 30 minutes.9.5.3.4.3



Activation of the load management system shall be permitted during this test.9.5.3.4.4 An alarm sounded by excessive battery discharge, as detected by the warning system required in Chapter 7 , or a system voltage of less than 11.8 volts dc for a 12-volt nominal system, 23.6 volts dc for a 24-volt nominal system, or 35.4 volts dc for a 42-volt nominal system for more than 120 seconds shall be considered a test failure.9.5.4 Low Voltage Alarm Test. 9.5.4.1 The following test shall be started with the engine off and the battery voltage at or above 12 volts for a 12-volt nominal system, 24 volts for a 24-volt nominal system, or 36 volts for a 42-volt nominal system.9.5.4.2 With the engine shut off, the total continuous electrical load shall be activated and shall continue to be applied until the excessive battery discharge alarm activates.9.5.4.3 The battery voltage shall be measured at the battery terminals.9.5.4.4 The test shall be considered a failure if the alarm does not sound in less than 140 seconds after the voltage drops to 11.70 volts for a 12-volt nominal system, 23.4 volts dc for a 24-volt nominal system, or 35.1 volts for a 42-volt nominal system.9.5.4.5 The battery system shall then be able to restart the engine.9.5.4.6 Failure to restart the engine shall be considered a test failure.9.6 Patient Compartment Sound Level Test. 9.6.1 This test shall be performed during the following environmental conditions:

(1) Temperature not to exceed 95°F (35°C)

(2) Humidity not to exceed 75 percent relative humidity

(3) Wind velocity not to exceed 12 mph (19 km/hr)(4) Barometric pressure 29 in. Hg to 31 in. Hg (98.2 kPa to 104.9 kPa)

9.6.2 The following steps shall be performed during the patient compartment sound level test:

(1) Measure sound level using a meter that meets the requirements of ANSI S1.4, Specification for Sound Level Meters , for Type II meters with the meter set to A for a weighting network, “fast” meter response.

(2) Suspend the microphone 23 in. (584 mm) above the vehicle floor, centered laterally and longitudinally on the expected center of the patient cot as it will be secured in the patient compartment.

(3) Park the ambulance on a concrete or asphalt surface, at a location so that no large reflecting surfaces, such as other vehicles, signboards, buildings, or hills, are within 50 ft (15.2 m) of the vehicle being tested.

(4) Close all ambulance doors, windows, and vents.

(5) Run air conditioner and heater blower fans in patient compartment at the highest speed.



(6) Set vehicle transmission in neutral gear and set the engine speed to the rpm obtained by the ambulance when operating on level ground at55 mph (88 km/hr).

(7) Turn on all warning lights.

(8) Operate siren in the loudest mode.

(9) Measure and record the highest sound level.(10) Decrease the engine speed to idle and then back to the 55 mph (88

km/hr) rpm.

(11) Measure and record the highest sound level.

(12) Repeat until two maximum sound levels within 2 decibels (dB) of each other are recorded.

(13) Numerically average these two maximum sound level readings.

9.7 Reserved. 9.8 Handrail Static Load Test. The following steps shall be performed during the handrail static load test:

(1) Apply force to handrail at the midpoint between every location where the handrail fastens to the vehicle body structure and as near aspossible to the ends of the handrail, as shown in Figure 9.8(a) .

(2) Apply the force perpendicular to the mounting surface.

(3) Apply the force parallel to the mounting surface.

(4) Apply the force diagonal to the mounting surface at an angle midway between the perpendicular and the parallel pulls, as shown in Figure 9.8(b) .

(5) Maintain each force application for 2 minutes.

Figure 9.8(a) Location of Force Application on Handrail.

Figure 9.8(b) Direction of Force Application on Handrail.

9.9* Line Voltage Electrical Systems Test. 9.9.1 The wiring and associated equipment shall be tested by the ambulance manufacturer or the installer of the line voltage system.



9.9.2*The electrical polarity of all permanently wired equipment, cord reels, andreceptacles shall be tested to verify that wiring connections have been properly made.9.9.3 Electrical continuity shall be verified from the chassis or the body to all line voltage electrical enclosures, light housings, motor housings, light poles, switch boxes, and receptacle ground connections that are accessible to personnel in normal operations.9.9.4 If the ambulance is equipped with a transfer switch, it shall be tested to verify operation and that all nongrounded conductors are switched.9.9.5 Electrical light towers, floodlights, motors, fixed appliances, and portable generators shall be operated at their full rating or capacity for 30 minutes to ensure proper operation.9.9.6* Certification Test of Power Source. 9.9.6.1 The ambulance manufacturer or installer of the power source shall perform acertification test on each power source.9.9.6.2 The testing of any power source greater than 3 kW shall be witnessed, and the results of the tests of the power source shall be certified by an independent third-party certification organization.9.9.6.3 Test Procedure. 9.9.6.3.1 The prime mover shall be started from a cold start condition, and the unloaded voltage and frequency shall be recorded.9.9.6.3.2 The line voltage electrical system shall be loaded to at least 100 percent of the continuous rated wattage stated on the power source specification label.9.9.6.3.3 Testing with a resistive load bank shall be permitted.9.9.6.3.4 The power source shall be operated in the manner specified by the ambulance manufacturer as documented on instruction plates or in operationmanuals.9.9.6.3.5 The power source shall be operated at a minimum of 100 percent of the continuous rated wattage as stated on the power source specification label for a minimum of 2 hours.9.9.6.3.5.1 The load shall be adjusted to maintain the output wattage at or above the continuous rated wattage during the entire 2-hour test.9.9.6.3.5.2 The following conditions shall be recorded at least every 30 minutes during the test:

(1) The power source output voltage, frequency, and amperage

(2) The prime mover's oil pressure, water temperature, and transmission temperature, if applicable

(3) The power source hydraulic fluid temperature, if applicable

(4) The ambient temperature and power source air inlet temperature



9.9.6.3.5.3 The following conditions shall be recorded once during the test for power sources driven by dedicated auxiliary internal combustion engines:

(1) Altitude

(2) Barometric pressure

(3) Relative humidity

9.9.6.3.6 If the generator is driven by the chassis engine and the generator allows foroperation at variable speeds, the chassis engine speed shall be reduced to the lowest rpm allowed for generator operation, and the voltage and frequency shall be recorded.9.9.6.3.7 The load shall be removed, and the unloaded voltage and frequency shall berecorded.9.9.6.3.8 Voltage shall be maintained within ±10 percent of the voltage stated on the power source specification label during the entire test.9.9.6.3.9 Frequency shall be maintained within ±3 Hz of the frequency stated on the power source specification label during the entire test.9.10 Water Leak Test. The water leak test shall be performed during the following environmental conditions:

(1) Temperature above 40°F (4°C)


9.10.1 The following steps shall be performed during the water leak test:


(2) Turn off heating, ventilating, and air conditioning (HVAC) systems.







9.11 Equipment Temperature Test. The following steps shall be performed during the equipment temperature test:







(5) Cool the chamber to 32°F (0°C) and soak the vehicle at thistemperature for a minimum of 3 hours.








9.12 Interior Climate Control Test. The following steps shall be performed during the interior climate control test:

(1) Locate the test vehicle in an environmental chamber capable ofmaintaining a temperature within ±4°F (2°C).

(2) Locate three thermocouples 7 in. (178 mm) off the floor along the patient compartment centerline and equally spaced from front to back.

(3) Locate three thermocouples 7 in. (178 mm) below the ceiling along the patient compartment centerline and equally spaced from front to back.

(4) Locate three thermocouples midway between the floor and the ceiling along the patient compartment centerline and equally spaced from front to back.

(5) Locate three thermocouples in the cab horizontally positioned 24 in. (600 mm) above the seat cushion and located 12 in. (300) in front of the headrest.

(6) Locate the first and third thermocouples along the centerline of the driver’s and passenger’s seats and center the second between the firstand third.



(9) Open engine hood.(10) Maintain an air velocity over the vehicle of at least 5 mph (8 km/hr)

throughout the entire test.

(11) Cool the chamber to 32°F ± 4°F (0° C ± 2°C) and soak the vehicle at this temperature for a minimum of 3 hours.

(12) Close all doors and hood with the exception of partition doors (if present) and patient compartment/cab partition window (if present).

(13) Set heaters in cab and patient compartment to maximum heating setting (maximum temperature, maximum blower speed, recirculating air).




(15) Shut off patient compartment dome lights.

(16) Start engine and maintain transmission in neutral or park and engine high idle on with a maximum engine speed of 1500 rpm.


(18) Shut off the engine.(19) Open all patient compartment entry doors, cabinet doors, cab door

windows, and exterior compartment doors.

(20) Open the engine hood.

(21) Heat the chamber to 95°F (35°C) with a minimum of 40 percent relative humidity and soak the vehicle at this temperature for a minimum of 3 hours.

(22) Close the hood; all doors, with the exception of partition doors (if present); and all windows, with the exception of the patientcompartment/cab partition window (if present).

(23) Set the air conditioners in the cab and the patient compartment to maximum cooling setting (maximum blower speed, coldesttemperature setting, recirculating air).


(25) Shut off the patient compartment dome lights.

(26) Start the engine and maintain the transmission in neutral or park and engine high idle on with a maximum engine speed of 1500 rpm.



9.13 Reserved. 9.14 Engine Cooling System Test. The following steps shall be performed during the engine cooling system test:

(1) Locate the test vehicle in an environmental chamber capable ofmaintaining a temperature within ±4°F (2°C).



(4) Heat the chamber to 95°F (35°C) and soak the vehicle at thistemperature for a minimum of 3 hours.

(5) Start the engine.(6) Close all doors, cab door windows, hood, partition door (if present),

and patient compartment/cab partition window (if present).


(8) Set air conditioners in cab and patient compartment to maximumcooling setting (maximum blower speed, coldest temperature setting,recirculating air).

(9) With all other ambulance equipment off, operate the engine at high idle for 1 hour.



9.15 Ambulance Main Oxygen System Test. 9.15.1 Pressure Test. The following steps shall be performed during the engine cooling system test:

(1) Ensure that the ambulance temperature has stabilized in anenvironment between 34°F and 110°F (1°C and 43°C).

(2) Charge the system with approximately 200 psi (1380 kPa) of test gas.

(3) Close system valves to trap pressure in the lines that contain the vent valve.




9.15.2 Flow Test. The following steps shall be performed for the flow test:


(2) Charge the system with test gas regulated to 50 psi ± 2 psi (345 kPa ±14 kPa).

(3) Plug all outlets other than the one being tested.

(4)

(5) Check the electrical continuity between the oxygen system piping and the vehicle to verify that it is grounded.

9.16 Patient Compartment Lighting Level Test. The following steps shall be performed for the patient compartment lighting level test:

(1) Prepare the ambulance or locate it in an environment to prevent light from penetrating into the patient compartment.

(2) Remove the patient cot.


(4) Turn on dome lights to highest setting.


(6) Turn on the lights that come on with the side entry door or rear entry door.


(8) Measure and record the light intensity in the center of the side entry step well and record the reading.

(9) Install the patient cot test grid shown in Figure 9.16 , 17 in. (432 mm) above the patient compartment floor, centered laterally and longitudinally on the expected center of the patient cot as it will be secured in the patient compartment.

(10) Measure and record the light intensity in the center of each 5 in.2 (322 mm2 ) area on the test grid.

* Measure and record the flow of gas from each outlet using a flowmeter with an accuracy of ±0.07 ft3 /min (±2 L/min).



Figure 9.16 Patient Cot Test Grid, Top View.

9.17 Reserved. 9.18 Rear Stepping Surface Load Test. The following steps shall be performed during the rear stepping surface load test:

(1) Support the ambulance or substantially similar structure to negate the effect of the vehicle suspension.

(2) Apply a vertical load on the stepping surface using a fixture that distributes the load over a circular area 5 in. (127 mm) in diameter.

(3) Apply 500 lb (227 kg) of load to the lateral and longitudinal center of the stepping surface.


(5) Release the load.(6) Measure and record any permanent deformation after the load is

released.

(7) Apply 500 lb (227 kg) of load to the longitudinal center of the stepping surface as close to each of the lateral extremes as the test fixture will allow.




9.19 Reserved. 9.20 Reserved. 9.21 Aspirator System Test. The following steps shall be performed during the aspirator system test:


(2) Run the vehicle engine at high idle speed for duration of the test.

9.21.1 Vacuum Test. The following steps shall be performed during the vacuum test:

(1) Install a 120 in. (3 m) length of transparent or translucent, nonkinking suction tubing on the collection bottle.

(2) Install a vacuum-measuring instrument capable of an accuracy of ±5 mm Hg (0.666 kPa) to measure the vacuum in the collection bottle.


(4) Turn on the vacuum pump.(5) Clamp or plug the end of the suction tubing.

(6) Measure and record the vacuum 4 seconds after plugging the tubing.



9.21.2 Flow Test. The following steps shall be performed during the flow test:

(1) Install a flow-measuring instrument capable of an accuracy of ±0.035 ft3 /min (1 L/min) to measure the flow in the suction tubing.


(3) Turn on vacuum pump.

(4) Measure and record the flow.

9.22 Reserved. 9.23 Reserved. 9.24 Perimeter Illumination Test. The following steps shall be performed during the perimeter illumination test:

(1) Place the ambulance in a dark environment.

(2) Ensure that the vehicle batteries are fully charged.

(3) Record the light intensity with a meter capable of measuring to an accuracy of ±0.01 fc.

(4) Construct a grid of test points off the sides and rear of the test ambulance, as shown in Figure 9.24 .

(a) Locate lines parallel with the exterior walls of the patient compartment 60 in. and 120 in. (1524 mm and 3048 mm) from the test unit.

(b) Intersect these lines with lines perpendicular to the exterior walls emanating from each corner and the midpoint of the patient compartment.

(c) Construct additional perpendicular lines emanating from the center of each scene light.

(5) Measure and record the light intensity at each point in the grid.

(6) Turn on all exterior scene lights.(7) Measure and record the light intensity at each point 3 in. (76 mm)

above the grid.

(8) Subtract the ambient light readings from the scene light readings.

Figure 9.24 Perimeter Illumination Test Grid.

9.25 Occupant Head Clearance Zones Test. 9.25.1



The following steps shall be performed during the occupant head clearance zones test:

(1) Construct a rigid rectangular test box 43 in. (1092 mm) high, 24 in. (457 mm) wide, and 15 in. (381 mm) deep.

(2) Place the test box in each seating position, centered laterally on the seat cushion, with the bottom edge resting against the seat back.

(3) Align the test box so that the sides of the box are perpendicular to the patient compartment floor.

9.25.2 The maximum weight for the test fixture shall not exceed 60 lb (27 kg).9.25.3 No permanent objects shall protrude into the test box zone.


Having the initial testing and inspections required in Chapter 9 for certification be performed by an accredited third party test lab will insure that the required tests are performed properly and that test results are valid and properly documented. The AHJ will be able to utilize the accredited test data to assist in determining if the vehicle is suitable for use as an ambulance in their state.


Submitter Full Name: John McDonaldOrganization: US General Services AdministraStreet Address:City: State: Zip:Submittal Date: Wed Feb 20 22:00:50 EST 2013


I, John McDonald, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement ofProblem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am John McDonald, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature




9.4 Patient Cot Retention System Static Test.The following actions shall be performed during the patient cot retention system static test:




(4) Apply each force so that it passes through the location that corresponds to the center of gravity of a loaded patient cot.


(6)

(1)


I am recommending the static test described in 9.4 be deleted in its entirety as I have suggested section 6.22 delete the requirement for a static test and replace it with a dynamic test.


Related Input RelationshipPublic Input No. 278-NFPA 1917-2013 [Section No. 6.22.1]

6.22 changed requirement from static to dynamic test thus rendering the test procedures outlined in 9.4 moot







9.5.2Tests shall be performed when the ambient air temperature is between 60°F and 110°F (15°C and 43°C).




9.5.2 DC testing to be conducted when ambient temperature is 60 F - 110 F this is possible but forces all testing to be done indoors during the winter weather. Is that the intent?










The three tests defined in 9.5.3.2 through 9.5.3.4.4 shall be performed in the order in which they appear.




Clarification required if low idle test is deleted.









9.5.3.3.1The minimum electrical load test conditions as stated in 7.3.2.1.1 shall beactivated with the engine running at idle speed.




9.5.3.3.1 Will not be required if we eliminate the idle testing requiremetn from section 7.3.2.









9.5.3.3.2The engine temperature shall be stabilized at normal operating temperature.




9.5.3.3.2 Will not be required if we eliminate the idle testing requirement from section 7.3.2.









9.5.3.3.3The battery system shall be tested to detect the presence of battery dischargecurrent.













9.5.3.3.4The detection of battery discharge current shall be considered a test failure.















(2) Turn off heating, ventilating, and air conditioning (HVAC)systems.


(4) Continue spraying with a minimum pressure of 25 psi until a minimum of 40 gal (151 L) of water has been used.








9.10.1(4) Water test does not specify a pressure or time duration for applying the water.









(2) Turn off heating, ventilating, and air conditioning (HVAC)systems.




(6) Continue spraying with a minimum pressure of 25 psi until an additional minimum of 40 gal (151 L) of water has been used.






9.10.1(6) Water test does not specify a pressure or time duration for applying the water.







9.15.1 Pressure Test.The following steps shall be performed during the engine cooling system test:


(2) Charge the system with approximately 200 80 psi (1380 kPa) of test gas.

(3) Close system valves to trap pressure in the lines that contain the vent valve.







9.15.1 Several of the commercial 02 components comprising the systems cannot tolerate the 200 psi requirement. AMD standards have been updated to compensate for the testing procedure error. I suggest we adopt the latest AMD 015 - 02 standard and KKK Change notice 5 dated 7/2/13.







Public Input No. 200-NFPA 1917-2013 [ New Section after A.4.8.1 ]

A.4.9Labels should be as follows:(1) orientated horizontally and read left to right(2) not be located where a control or a user's normal hand, arm position, or

any other item will obscure the label or where the label obscures any other information

(3) where the ambient illuminance is above 10 lux (0.9 foot candle), black label characters should be provided on a light background

(4) label character height should be between 0.12 in. and 0.20 in. times D/28 in. (between 3.0 mm and 5.0 mm times D/710mm), where D is the viewing distance

(5) alphanumeric characters should have a width of 0.6 in. (15.24 mm) to 0.8 in. (20.32 mm) of the height except for single stroke characters (e.g., I, 1) which should be between 0.1 in. (2.54 mm) and 0.2 in. (5.08 mm) of the height

(6) the width of numerals should preferably be 0.6 in. (15.24 mm) of the height, except for “4”, which shall be 0.8 in. (20.32 mm) of the height, and “1”, which shall be 0.2 in. (5.08 mm) of the height

(7) stroke width should meet the following:a). Normal. For black characters on a white (or light) background, the stroke width shall be 0.1667 in. (4.23 mm) to 0.1429 in. (3.63 mm) of theheight. The stroke width shall be the same for all letters and numerals of equal heightb). Transilluminated characters. For transilluminated characters, thestroke width shall be 0.1 in (2.54 mm) of the heightc). Maintain ratio. The stroke width ratios shall apply regardless of how high characters are made for distance viewing. However, for certain applications, characters with different stroke widths may be used on the same sign for emphasis. In this case, the thinnest character stroke shall be no less than 0.125 in. ( 3.175 mm) nor the thickest character stroke greater than 0.2 in. ( 5.08 mm) of the respective character heights

(8) letters and numerals should be of a plain style without serifs (i.e., sans serif fonts) except as may be necessary to distinguish between characters which would otherwise be confused (e.g., “L”, “I”, “1”, “0”, “O”)

(9) easy to read accurately from the operational reading distances and in the anticipated vibration, motion, and illumination environments.




(1) EMSPs need to read labels as quickly and easily as possible so as not to delay while treating patients. The requirement is obtained from Section 5.4.2, Orientation, of MIL-STD 1472G, which recommends the appropriate text orientation. (2) Labels should always be within EMSPs visual access, irrespective of position or posture within the patient compartment. The requirement is obtained from Section 5.4.3.2, Obscuration, of MIL-STD1472G, which specifies conditions that would otherwise prevent the EMSPs from visually accessing the labels. (3)The human eye capacity to read signs accurately and easily depends on the quantity of light incident on the object, the color of characters, and the background. The requirement to ensure that the signs can be read is obtained from Section 5.4.6.1, Black Characters, of MIL-STD- 1472, Black Characters, that determines the nature of the background for the labels when ambient illuminance exceeds a particular level. (4)The character size, spacing, and orientation should be such that the EMSPs and other occupants can easily read then accurately irrespective of location in the patient compartment. The requirement is obtained from Table XXI, Character Heights Versus Luminance and Viewing Distance, of MIL-STD-1472G, which specifies the height of characters to enable easy reading that should be adopted in the ambulance industry. (5)The character size, spacing, and orientation should be such that the EMS providers and other occupants can easily read then accurately irrespective of where they are in the patient compartment. The requirement is obtained from Section 5.4.6.3.4, Letter Width, of MIL-STD-1472G, which specifies the width of the characters to enable easy reading that should be adopted in the ambulance patient compartment. (6)The character size, spacing, and orientation should be such that the EMS providers and other occupants can easily read them accurately irrespective of where they are in the patient compartment. The requirement is obtained from section 5.4.6.3.5, Numerical Width, of MIL-STD-1472G. (7)The character size, spacing, and orientation should be such that the EMS providers and other occupants can easily read then accurately irrespective of where they are in the patient compartment. The requirement is obtained from Section 5.4.6.3.7, Stroke Width, of MIL-STD-1472G. (8) In order to avoid confusion while reading labels that can lead to errors in treatment if the characters are not read properly, letters and numerals that have similar shapes should be easily distinguished from one another. The requirement is obtained from Section 5.4.6.3.2, Plain Style, of MIL-STD-1472G. (9)The character size, spacing, and orientation should be such that the EMS providers and other occupants can easily read then accurately irrespective of where they are in the patient compartment or state of motion of the ambulance. The requirement is obtained from Section 5.4.5.5.1, Accurate Reading, of MIL-STD-1472G.







Public Input No. 167-NFPA 1917-2013 [ New Section after A.4.9.2.2 ]

A.4.9.2.3.2Controls and switches (including equipment) in the patient compartment should be operable by one hand. They should be visually or tactilely distinct from each other (i.e. can't confuse temperature controls with lights). Controls shall be designed and arranged such that the probability of reaching/using the wrong control is minimized. In addition, redundant equipment controls should be provided at all primary (most frequently used) workstations of the patient compartment.


In many instances, EMSPs are tied down to putting all their attention on one piece of equipment, device, or control function due to handling requirements of that equipment or control. Giving EMSPs the flexibility to operate equipment or controls with one hand will provide them the freedom to use their other hand for other purposes, and as a result this makes their work environment more efficient. When controls are similar to each other, it may cause confusion for the EMSP. Proper controls distinction will enhance EMSP working efficiency. Distinction amongst the controls puts emphasis on the organizational aspects of the patient compartment working environment, which can reduce visual and/or tactile search time for the EMSP to find the specific control they need to handle, change, or use. This extra time allocated from proper controls labeling distinction can be used by the EMSP for patient health care. Providing redundant controls at all primary patient care positions will allow the EMSP to perform their patient care duties and manage the work environment without having to leave their seat.


Submitter Full Name: Jennifer MarshallOrganization: NISTStreet Address:City: State: Zip:Submittal Date: Mon Jul 01 19:13:25 EDT 2013






Public Input No. 9-NFPA 1917-2013 [ Section No. A.4.12.4 ]

A.4.12.4 3Although this standard recognizes the need for the ambulance to be able to accelerate to a high speed while traveling on public roads, caution should be taken with regard to how fast the ambulance can travel.

Where the ambulance has to operate off paved roads, all-wheel drive, a two-speed rear axle, an auxiliary transmission, an automatic transmission, or any combination of these might enhance the ambulance’s off-road capability.


Note: This Proposal originates from Tentative Interim Amendment 1917-13-1 (TIA 1089) issued by the Standards Council on March 7, 2013.NASEMSO cannot support or enforce 4.12.3, and the need for this deletion remains even if the TIA related to Section 4.17 is granted. There are states where the legal speed limit is above 77 mph, including 80 and 85 mph.

Further, in some states, an ambulance operating with lights and sirens can legally exceed the posted speed limit by 10 mph. Therefore, while well intentioned for roadways with a posted speed limit of 65 mph or less, a governor set to 77 mph will actually create a safety hazard as a result of ambulances traveling at much slower speeds than the surrounding traffic. Speed should be governed by the states and the owners and operators of the ambulances. Since not every chassis manufacturer makes speed governors available, NASEMSO is also deeply concerned about the risk aversion expressed by ambulance manufacturers about aftermarket installation and device failure. Availability of this technology is extremely limited among chassis and aftermarket device

manufacturers, and only one brand has been identified that can be set at 77 mph. NASEMSO recognizes the importance of safe ambulance operations and is cognizant of other electronic means of speed monitoring, the annex content on monitoring systems, as well as local EMS agency policies related to the matter.

Emergency Nature: The requirement of a speed limiting device that places a maximum speed limit of 77 mph creates a safety hazard for operators and occupants of ambulances, especially in states that have posted speed limits above 77 mph. In some states, For example, Texas, there is a posted speed limit of 85 mph and an NFPA 1917–compliant ambulance would not be able to meet the posted speed limit, thus creating a safety hazard. This is also true in states where emergency vehicles are allowed to exceed the posted speed limit by 10 mph; with 77 mph being the maximum, in a standard that comprises minimum requirements, the posted speed limit would have to be as low as 67 mph which is not common in some states. This requirement places a restriction upon some states that would prohibit them from purchasing an NFPA 1917–compliant ambulance.






A.5.11.2.8.4Steps should be no greater than 7.8 in. (198 mm) in height with 6.5 in. - 7 in. (165 -178 mm) preferred


In a study carried out by the National Institute of Standards and Technology in 2011, it was found that many EMS providers have difficulty using the steps in current ambulances because of the large size of the step raisers at the entry/exit ways. (Reference: “Survey Report for Ambulance Patient Compartment Design,” NIST Technical Note 1772, http://nvlpubs.nist.gov/nistpubs/TechnicalNotes/NIST.TN.1772.pdf) Steps should allow EMSPs of height as short as 59.3 in. (1506 mm) enter and exit the ambulance easily without physical strain. The step size requirement is obtained from Figure 79, Stair Dimensions, of MIL-STD-1472G, Design Criteria Standard Human Engineering (January 2012).









A.6.9.2Entry doors should be wide enough to allow for loading a patient on a cot or backboard, and for EMSP ingress and egress.


EMS equipment such as cot can be available in different sizes and the EMSPs also have varying stature. Therefore, the entry doors to the patient compartment should be designed wide enough to accommodate cots in different sizes and EMSPs.









A.6.8Access handholds should be mounted immediately inside each entrance to the patient compartment.


EMSPs and other occupants need to hold onto a nonmoving, fixed object when entering the patient compartment for balance and safety. This can be done by providing access handholds near inside each entrance to the patient compartment.









A.6.9.1Handholds should be mounted on the inside of entrance doors to assist in closing the doors.


To effectively close and secure a patient compartment door from the inside requires a handhold located on the door that allows the EMSP to firmly grasp and pull.









A.6.8Handholds that minimize striking hazards should be installed over each walking path down the length of the patient compartment.


Mechanisms are needed to help EMSPs keep their balance inside the patient compartment. This is the case whenever the EMSP is reaching out for something or whether they need to stand up, and a support mechanism would help a lot to keep them from falling and potentially hurting themselves. Handholds installed over each patient compartment walking path can provide this mechanism for EMSPs.









A.6.8Ceiling handholds should run the full length of each walking path in the patient compartment.


As an EMSP traverses the patient compartment, they need a mechanism that runs the full length of the compartment to steady themselves.









A.6.11Where practical, exterior stair treads should be open, without the solid vertical risers (the portion between each tread of the step) to connect them.


EMSPs need maximum and balanced feet contact with the treads on the stairs while loading or unloading a patient. Having open risers will potentially allow for more surface area for foot contact and body balance. The requirement to design for open tread is obtained from Section 5.11.1.2.1, Stairs Treads, of MIL-STD-1472G, Design criteria standard Human Engineering (January 2012).









A.6.9.9Windows on egress doors should allow for adequate viewing to ensure that potential obstructions within the door opening or egress path can be identified.


When exiting an ambulance at a station, patient location or hospital, the EMSPs need to verify that there are no external obstructions to opening the doors due to objects outside of the ambulance. When such an incident occurs, the exit of EMSPs, accessing the patient, and unloading of the patient at the hospital could be delayed. The recommended design best practice should provide the capability to see them from inside the patient compartment.









A.6.14.2The purchaser may wish to consider the rear maximum loadheight based on the primary stretcher being utilized. Current accepted maximum load heights as stated by the cot manufacturers are 34 in. to 36 in. (863.6 mm) to 914.4 mm). The load height is dependent on the chassis chosen. Chassis withfour-wheel drive are traditionally 4 in. to 6 in. (101.6 mm to 152.4 mm) higher than a comparable 4 × 2.


This Annex item does not reference the correct section. Section 6.14.2 is a floor covering section. I could not find a load height section in the body of the document. The committee needs to either add a load height section in the body of the document, find another section to key this to or delete it.


Submitter Full Name: STEPHEN WILDEOrganization: Certified Fleet Services, inc.Affilliation: EVT CERTIFICATION COMM INCStreet Address:City: State: Zip:Submittal Date: Thu Apr 11 12:44:06 EDT 2013







A.6. 14.2 22The purchaser may wish to consider the rear maximum load height based on the primary stretcher being utilized. Current accepted maximum load heights as stated by the cot manufacturers are 34 in. to 36 in. (863.6 mm) to 914.4 mm). The load height is dependent on the chassis chosen. Chassis with four-wheel drive are traditionally 4 in. to 6 in. (101.6 mm to 152.4 mm) higher than a comparable 4 × 2.


Annex A.6.14.2 should be renumbered since it does not link to requirement 6.14.2.








Public Input No. 170-NFPA 1917-2013 [ New Section after A.6.16 ]

A.6.17.3Surface materials and their colors used in the patient compartment should allow EMSPs to distinguish clean from soiled surfaces.


The interior of the patient compartment needs to be kept clean. When surfaces get exposed to contaminants and soiling, the patient compartment’s hygiene may be detrimental to the health of incoming patients and EMSPs. A requirement to make unclean surfaces distinguishable from clean is needed. Such a requirement will enhance the patient compartment’s hygiene and cleanliness, and so the surface materials and their color should allow EMSPs to distinguish clean from soiled surfaces.









A.6.17Cords, leads, and tubing should be routed within the patient compartment so that they do not snag or cross any walking paths, present entanglement hazards, orprotrude into aisles.


Trips and falls are one of the leading causes of injury and deaths in the workplace. The ambulance patient compartment carries equipment with connecting wires, leads, and tubes that can be a major cause of tripping and falls, if not carefully laid out. The requirement is to design the ambulance layout whereby wires, cords, and tubes are directed away from walking paths.









A.6.18Equipment should be as follows:(1) mounted or located within a maximum functional reach of 26.7 in. (678 mm) to the EMSPs with height as short as 59.3 in. (1506 mm) from a restrained position,when requires EMSP interaction(2) not be secured where it precludes physical or visual access to common and critical equipment and supplies or their storage locations(3) secured or mounted with the equipment controls accessible to EMS provider while in a neutral restrained working position, when it requires EMSP interaction(4) required minimal steps to secure and unsecure .


: (1) Research and survey that was carried out by the National Institute of Standards and Technology showed that one of the major causes of injuries among EMSP is working while unrestrained. (Reference: “Survey Report for Ambulance Patient Compartment Design,” NIST Technical Note 1772, http://nvlpubs.nist.gov/nistpubs/TechnicalNotes/NIST.TN.1772.pdf) The placement of equipment should be such that they are accessible by EMSPs with maximum functional reach of 26.7 in. (678 mm) when restrained. This requirement is based on the requirements standards included in the Table B-I, Standing Body Dimensions – General Forces, of MIL-STD-1472G, Design Criteria standard human engineering (January 2012). (2) In order to quickly access and use critical equipment and supplies, EMSPs need to have a clear line of sight of this equipment. Therefore, it is best to remove any impediment that may obscure the EMS provider’s direct view that may lead to possible delay. The requirement is for equipment to be secured in a way that may lead to delays in treating a patient due to obstructions. (3)Most injuries to EMSPs in case of accidents have been unrestrained personnel. Secondly, research shows that EMS providers are prone to long-term musculoskeletal injuries because they assume inconvenient body postures while treating patients. The requirement is for a layout of the interior and placement of equipment to facilitate treatment from a comfortable, seating position. (Reference: “Ergonomic Evaluation of the Ambulance Interior to Reduce Paramedic Discomfort and Posture Stress”, http://www.ncbi.nlm.nih.gov/pubmed/18074701) (4)Quick response to emergencies requires that the equipment should be secured and un-secured in minimal steps.






A.6.21.3Restraint systems should be fully exposable for sanitation and cleaning.


Restraint systems have the potential to become unsanitary or even contaminated. Consequently, restraint systems need to have some sort of mechanism to enable them to be easily sanitized. Keeping the patient compartment hygienic and clean is important for avoiding the spread of disease or unsanitary work practices, and this goal can be further met by using restraint systems that should be able to become fully exposed for sanitation and cleaning.









A.6.22The cot guidance and retention system should be as follows:(1) able to accommodate specialty (e.g. bariatric) cots(2) facilitate proper placement of the cot such that the cot can be guided in and locked in one motion(3) c ot safety hook should be installed to prevent the cot from accidentally rolling out of the ambulance while being loaded.


(1) Bariatric cots are generally wider and bigger compared to ordinary/standard cots. The various studies and research carried out by the National Institute of Standards and Technology during requirements the elicitation phase showed that the number of bariatric patients is increasing. (Reference: “Survey Report for Ambulance Patient Compartment Design,” NIST Technical Note 1772, http://nvlpubs.nist.gov/nistpubs/TechnicalNotes/NIST.TN.1772.pdf) In order not to waste time to take the patient to the hospital, the requirement is for a mechanism that can be used for different cots sizes and types including those for bariatric patients.(2)The survey and literature search carried out by the National Institute of Standards and Technology showed that loading patients on the ambulance is one of the major causes of back pain and injury among EMSPs. To mitigate the risks of injury, the requirement is for a minimum number of motions to load and lock the cot. (3) When loading a cot, there should be a mechanism at the loading point to ensure that the front end of the cot does not slip off before the cot is loaded into the ambulance. This will reduce the risk of injury to the EMSP as well as the patient.






A.6.21.8Seating should be provided to allow the EMS provider access to either side of the patient's body from a seated and restrained position.


The survey, which was conducted by the National Institute of Standards and Technology in December 2011, shows that many EMSPs are reluctant to wear their seat belt because it constrains their ability to work on the patient. Being able to sufficiently access the patient from a seated, restrained position will allow the EMSP to provide healthcare to the patient without any need to put their own lives at risk. (Reference: “Survey Report for Ambulance Patient Compartment Design,” NIST Technical Note 1772, http://nvlpubs.nist.gov/nistpubs/TechnicalNotes/NIST.TN.1772.pdf)









A.6.21.7.6 The seat height should be adjustable in 1 in. (25 mm) increments from 15 in. (381 mm) to 21 in. (533 mm).


Seating height needs to be convenient for all types of EMSP heights, and adjustable seat height will help accommodate patient compartment seating for a wider range of EMSP heights. With a more ergonomic design, they will be allowed to perform work activities more efficiently, with greater comfort, and less risk of cumulative trauma injuries. The human factors practices in MIL-STD 1472G, Design Criteria Standard Human Engineering (January 2012), have provisions for an adjustable seating height for work that involves seated operations. Requirement 5.10.3.2.7, Seat Pan and Vertical Adjustment, of MIL-STD 1472G addresses the seat heights.









A.6.21.7.4 Back and head support should accommodate different sized occupants with heights between 59.3 in. and 74.3 in. (1505 mm and 1887 mm). In addition, the back support should include lumbar support.


Seats need to adhere to standard human factors practices. With a more ergonomic design, EMS providers will be allowed to perform work activities more efficiently. An ergonomic, appropriately-sized backrest and headrest that accommodate a wide range of EMSPs and patients heights will give them an extra support to comfortably stay in a seated position. The human factors practices in MIL-STD 1472G, Design Criteria Standard Human Engineering (January 2012) Table B-I, Standing Body Dimensions –General Forces, of MIL-STD 1472, have provisions for anthropometrics that are relevant to the seat backrest and headrest.In additona, a lumbar support will give EMS workers an extra provision to comfortably stay in a seated position. The human factors practices in MIL-STD 1472G, Design Criteria Standard Human Engineering (January 2012), have provisions for supporting seat backrest and lumbar supports, targeted for work that involves seated operations. Requirement 5.10.3.2.8 in this standard addresses the vehicle seating backrests.









A.6.21.7.3 Back support should be at minimum 18 in. (457 mm) in width, but up to 20 in. (508 mm) to provide support for larger EMSP.


Seats need to adhere to standard human factors practices that preclude short-term or long-term musculoskeletal injuries. With a more ergonomic design, EMS providers will be allowed to perform work activities more efficiently with less risk of injury. An ergonomic, appropriately wide backrest will give EMSP an extra provision to comfortably stay in a seated position. Although minimum back support is identified at 18 in, 20 in provides support for a large EMSP. The human factors practices in MIL-STD 1472G, Design Criteria Standard Human Engineering (January 2012), have provisions for the seat backrest. Requirement 5.6.2.1, Dimensions and Clearance, of MIL-STD 1472G, Design Criteria Standard Human Engineering (January 2012), addresses the seating backrest widths.









A.6.21.7.2 Although 15 - 19 In. (381- 482mm) is identified, ideally seats should be a maximum of 15.9 in. (405 mm) in depth to accommodate individuals with height as short as 59.3 in. (1506 mm), allowing them to sit with ease and be able to perform work activities.


The seating in the patient compartment needs to conform to different heights and sizes of occupants. The seating depth should be able to accommodate individuals with height as short as 59.3 in. (1506 mm), allowing them to sit with ease and be able to perform work activities. The human factors practices in MIL-STD 1472G, Design Criteria Standard Human Engineering (January 2012), addresses the seating depths required for work that involves seated operations. Section 5.10.3.2.4, Seating, of MIL-STD 1472G addresses the seating dimensions.









A.6.21.7.4Back and head support should accommodate different sized occupants with heights between 59.3 in. and 74.3 in. (1505 mm and 1887 mm). In addition, b ack support should include lumbar support.


Seats need to adhere to standard human factors practices. With a more ergonomic design, EMS providers will be allowed to perform work activities more efficiently. An ergonomic, appropriately-sized backrest and headrest that accommodate a wide range of EMSPs and patients heights will give them an extra support to comfortably stay in a seated position. The human factors practices in MIL-STD 1472G, Design Criteria Standard Human Engineering (January 2012) Table B-I, Standing Body Dimensions –General Forces, of MIL-STD 1472, have provisions for anthropometrics that are relevant to the seat backrest and headrest. A lumbar support will give EMS workers an extra provision to comfortably stay in a seated position. The human factors practices in MIL-STD 1472G, Design Criteria Standard Human Engineering (January 2012), have provisions for supporting seat backrest and lumbar supports, targeted for work that involves seated operations. Requirement 5.10.3.2.8 in this standard addresses the vehicle seating backrests.


Submitter Full Name: Jennifer MarshallOrganization: NISTStreet Address:City: State: Zip:Submittal Date: Fri Jul 05 12:15:29 EDT 2013







A.6.21.3Restraint systems should be as follows: (1) the restraint system's unfastening mechanism should require only one motion or click with only one hand to operate. (2) the restraint system’s fastening mechanism should require minimal steps to operate. (3) the restraint system should be adjustable to prevent pressure on the throat or other sensitive areas.


(1) It is essential for the occupants to be able to quickly and easily get out of the patient compartment seats. Allowing the occupants to unfasten their restraint system with only one motion or click using only one hand will help them quickly exit their seat and the patient compartment. (2)It is important for the occupants to be able to quickly and easily fasten their restraint systems when the ambulance is in motion or will soon be in motion. The EMSP will want to ingress and fasten their seat’s restraint system as soon as possible. This will in turn help them be able to provide healthcare to the patient more quickly. Requiring that the restraint system’s fastening mechanism only needs minimal steps to operate will allow them more time to spend on the patient. (3) Restraint systems need to adhere to standard human factors practices. With a more ergonomic design design, EMSPs will be able to practice their healthcare skills more safely and also perform work activities more efficiently. They need to avoid pressure points and sensitive body areas.









A.6.28O2 and suction ports should be located such that the EMSP does not have to reachbehind themselves, a structure, or piece of equipment to access the ports.


Providing easy access to essential devices, equipment, tools, or ports in the patient compartment can increase the efficiency of the working environment, and result in less time that the EMSP has to spend for obtaining their work needs. 02 and suction devices and ports are critically important to patient care and frequently used. Difficult reaches behind the EMSP can also increase the risk of musculoskeletal injuries. Easing access to these two devices should be a requirement, avoiding the EMSPs from having to reach behind themselves or bypass a structure and/or piece of equipment to access the ports.









A.7.15.3Built-in communication devices should allow one handed operation.


In many instances, EMS providers need to communicate while performing patient care. Providing them with the capability to use the communications devices with just one hand will allow them to continue patient care while communicating and as a result make their work environment more efficient.









A.7.15Visual notifications, where provided, should be obvious to the EMSPs.


Visual notifications may exist in the patient compartment as a communication means for particular purposes (such as emergencies). If the visual notification devices are not installed such that they are obvious to the EMSP while the EMSP is interacting with the patient, they are ineffective. To make the visual notifications effective, they need to be in line-of-site to the EMSP from the patient compartment’s patient care seat positions.






