1981-1

Report on Comments F2006 — Copyright, NFPA NFPA 1981Report of the Committee on

Fire and Emergency Services Protective Clothing and Equipment (FAE-AAC)

Technical Correlating Committee

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

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

Rep. Compressed Gas Association

Leslie Anderson, US Department of Agriculture, MT [E]Roger L. Barker, North Carolina State University, NC [SE]Les Boord, US Department of Health & Human Services, PA [E] Steven D. Corrado, Underwriters Laboratories Incorporated, NC [RT] Nicholas J. Curtis, Lion Apparel, Incorporated, OH [M]Robert A. Freese, Globe Manufacturing Company, NH [M]Andy Gbur, Intertek, OH [RT]Bill Grilliot, Morning Pride Manufacturing, LLC /TFG, OH [M] Rep. Fire & Emergency Manufacturers & Services Association IncorporatedKimberly M. Henry, PBI Performance Products, Incorporated, NC [M]James S. Johnson, Lawrence Livermore National Laboratory, CA [RT]Cy Long, Texas Commission on Fire Protection, TX [E]David G. Matthews, Fire & Industrial (P.P.E) Limited, United Kingdom [SE] Rep. International Standards OrganizationJim Minx, Oklahoma State Firefighters Association, OK [C]Gary L. Neilson, Reno Fire Department, NV [U]Stephen R. Sanders, Safety Equipment Institute (SEI), VA [RT]Denise N. Statham, Southern Mills, Incorporated, GA [M]Jeffrey O. Stull, International Personnel Protection, Incorporated, TX [SE]David Trivette, Tyco/Scott Health & Safety, NC [M] Rep. International Safety Equipment Association Robert D. Tutterow, Jr., Charlotte Fire Department, NC [U] Rep. Fire Industry Equipment Research Organization Harry P. Winer, US Department of the Navy, MA [RT]

Alternates

Jason L. Allen, Intertek, NY [RT] (Alt. to Andy Gbur) Eric J. Beck, Mine Safety Appliances Company, PA [M] (Alt. to William M. Lambert) Janice C. Bradley, International Safety Equipment Association, VA [M] (Alt. to David Trivette) Patricia A. Freeman, Globe Manufacturing Company, Incorporated, NH [M] (Alt. to Robert A. Freese) Patricia A. Gleason, Safety Equipment Institute (SEI), VA [RT] (Alt. to Stephen R. Sanders) Mary I. Grilliot, TFG/Morning Pride Manufacturing LLC, OH [M] (Alt. to Bill Grilliot) William E. Haskell, III, US Department of Health & Human Services, MA [E] (Alt. to Les Boord) Steven B. Lumry, Oklahoma City Fire Department, OK [C] (Alt. to Jim Minx) Andrew P. Perrella, E. I. DuPont Company, DE [M] (Alt. to Kimberly M. Henry) Frank P. Taylor, Lion Apparel, Incorporated, VA [M] (Alt. to Nicholas J. Curtis)

Nonvoting

Donna P. Brehm, Virginia Beach Fire Department, VA [U] Rep. TC on Emergency Medical Services PC&E Dean W. Cox, Fairfax County Fire & Rescue Department, VA [U] Rep. TC on Special Operations PC&E Glenn P. Jirka, Miami Township Fire & EMS Division, OH [E] Rep. TC on Hazardous Materials PC&E Kirk Owen, Plano Fire Department, TX [U] Rep. TC on Structural and Proximity Fire Fighting PC&E Ray F. Reed, Dallas Fire Rescue, TX [U] Rep. TC on Respiratory Protection Equipment Bruce H. Varner, Santa Rosa Fire Department, CA [E] Rep. TC on Electronic Safety Equipment

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

Report of the Committee on

Electronic Safety Equipment (FAE-ELS)

Bruce H. Varner, ChairSanta Rosa Fire Department, CA [E]

Steven B. Lumry, SecretaryOklahoma City Fire Department, OK [C]

Rep. Oklahoma State Firefighters Association

Jason L. Allen, Intertek, NY [RT]Robert J. Athanas, SAFE-IR, Incorporated/FDNY, NY [U]Robert J. Bonahoom, Mine Safety Appliances Company, PA [M]Nelson P. Bryner, US National Institute of Standards & Technology, MD [RT]A. Paul Bull, Fairfax County Fire & Rescue Department, VA [U]John P. Campman, Grace Industries, Incorporated, PA [M]John G. Casali, Virginia Tech University, VA [SE]Richard W. Duncanson, City of Middletown Fire Department, NY [E] Rep. NFPA Fire Service Section Michael G. Feely, Boston Fire Department, MA [U] Thomas J. Fisher, US Department of Health & Human Services, PA [E] Wayne C. Haase, Summit Safety, Incorporated, MA [M] Roy R. Hari, Marion County Fire District #1, OR [E] Karen Lehtonen, Lion Apparel, Incorporated, OH [M] Michael F. McKenna, Sacramento Metropolitan Fire District, CA [U] David E. Mills, Underwriters Laboratories Incorporated, IL [RT] Lawrence M. Nyberg, Motorola, Incorporated, IL [M] Craig Parkulo, Tyco/Scott Health and Safety, NC [M] Fred H. Rascoe, International Safety Instruments, Incorporated, GA [M] Rep. International Safety Equipment Association Stephen R. Sanders, Safety Equipment Institute (SEI), VA [RT] Christina Spoons, Westmont Fire Department, IL [C] Donald H. J. Turno, Washington Savannah River Company, SC [U] Timothy W. Wolf, Scottsdale Fire Department, AZ [C]

Alternates

Donald Aldridge, Lion Apparel, Incorporated, OH [M] (Alt. to Karen Lehtonen)Francine K. Amon, US National Institute of Standards & Technology, MD [RT] (Alt. to Nelson P. Bryner)Janice C. Bradley, International Safety Equipment Association, VA [M] (Alt. to Fred H. Rascoe)Patricia A. Gleason, Safety Equipment Institute (SEI), VA [RT] (Alt. to Stephen R. Sanders)William E. Haskell, III, US Department of Health & Human Services, MA [E] (Alt. to Thomas J. Fisher)John Jarboe, Grace Industries, Incorporated, MD [M] (Alt. to John P. Campman)Richard Katz, Mine Safety Appliances Company, PA [M] (Alt. to Robert J. Bonahoom)Robert M. Knabbe, SAFE-IR, Incorporated/FDNY, NY [U] (Alt. to Robert J. Athanas)Jeff A. Lancaster, Virginia Tech University, VA [SE] (Alt. to John G. Casali)Jeffrey L. Landis, Tyco/Scott Health and Safety, NC [M] (Alt. to Craig Parkulo)Steven D. Townsend, City of Carrollton Fire Department, TX [E] (Alt. to Bruce H. Varner)

Committee Scope: This Committee shall have primary responsibility for documents on the design, performance, testing, and certification of electronic safety equipment used by fire and emergency services personnel during emergency incident operations, and shall also have primary responsibility for documents on the selection, care, and maintenance of electronic safety equipment.

1981-�

Report on Comments F2006 — Copyright, NFPA NFPA 1981Report of the Committee on

Respiratory Protection Equipment (FAE-RPE)

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

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

Edward A. Allen, III, Seminole County Sheriff’s Office, FL [U] Rep. National Tactical Officers Association Jason L. Allen, Intertek, NY [RT] Claire C. Austin, National Research Council of Canada (NRC), Canada [SE] Neal A. Baluha, Palm Beach County Fire Rescue, FL [C] Eric J. Beck, Mine Safety Appliances Company, PA [M] David T. Bernzweig, Columbus, Ohio Division of Fire, OH [L] Rep. Columbus Fire Fighters Union, IAFF Local 67 Les Boord, US Department of Health & Human Services, PA [E] A. Paul Bull, Fairfax County Fire & Rescue Department, VA [U]Brian H. Cox, Clovis Fire Department, CA [U]Edward D. Golla, TRI/Airtesting, TX [RT]A. Ira Harkness, US Department of the Navy, FL [RT]David V. Haston, US Department of Agriculture, CA [RT]John Jarboe, Grace Industries, Incorporated, MD [M]Stephen J. King, Deer Park, NY [SE]Kevin D. Lentz, City of Garland Texas Fire Department, TX [U]Ian Maxwell, Interspiro AB, Sweden [M]Stephen T. Miles, City of Virginia Beach Fire Department, VA [U] Jerry Phifer, Tyco/Scott Health & Safety, NC [M]Fred H. Rascoe, International Safety Instruments, Incorporated, GA [M]Daniel N. Rossos, City of Portland Fire Bureau, OR [U]Stephen R. Sanders, Safety Equipment Institute (SEI), VA [RT]Robert Sell, Draeger Safety, Incorporated, PA [M]Dick A. Smith, Trace Analytics, Incorporated, TX [RT]Richard S. Tobin, Jr., Fire Department City of New York, NY [U]Kenton D. Warner, KDW Consulting, LLC, FL [SE]Steven H. Weinstein, Survivair, CA [M] Rep. International Safety Equipment Association

Alternates

Marshall (Mark) J. Black, US Department of the Navy, FL [RT] (Alt. to A. Ira Harkness) John P. Campman, Grace Industries, Incorporated, PA [M] (Alt. to John Jarboe) J. Michael Carlson, TRI/Environmental, Incorporated, TX [RT] (Alt. to Edward D. Golla) Dennis K. Davis, US Department of Agriculture, MT [RT] (Alt. to David V. Haston) David Hodson, Draeger Safety UK Limited, United Kingdom [M] (Alt. to Robert Sell) Richard Hofmeister, Tyco/Scott Health & Safety, NC [M] (Alt. to Jerry Phifer) Nick Luzie, Survivair, CA [M] (Alt. to Steven H. Weinstein) John Morris, International Safety Instruments, Incorporated, GA [M] (Alt. to Fred H. Rascoe) William T. Mundy, Fire Department City of New York, NY [U] (Alt. to Richard S. Tobin, Jr.) Mark I. Piland, City of Virginia Beach Fire Administration, VA [U] (Alt. to Stephen T. Miles) Michael T. Rupert, Mine Safety Appliances Company, PA [M] (Alt. to Eric J. Beck)

Nonvoting

Matthew I. Chibbaro, US Department of Labor, DC [E] (Alt. to Nonvoting) Robert B. Bell, US Department of Labor, DC [E] (Alt. to Matthew I. Chibbaro)

Staff Liaison: Bruce W. Teele

Committee Scope: This Committee shall have primary responsibility for documents on respiratory equipment, including breathing air, for fire and emergency services personnel during incidents involving hazardous or oxygen deficient atmospheres.

This Committee shall also have primary responsibility for documents on the selection, care, and maintenance of respiratory protection equipment and systems by fire and emergency services organizations and personnel.

Report of the Committee on

Special Operations Protective Clothing and Equipment (FAE-SCE)

Dean W. Cox, ChairFairfax County Fire & Rescue Department, VA [U]

Karen Lehtonen, SecretaryLion Apparel, Incorporated, OH [M]

Steven D. Corrado, Underwriters Laboratories Incorporated, NC [RT]Keith B. Dempsey, City of Dalton Fire Department, GA [C]James A. Frank, CMC Rescue, Incorporated, CA [M]Stephen J. Geraghty, Fire Department City of New York, NY [U]Hamid M. Ghorashi, E. I. DuPont de Nemours and Company, Incorporated, VA [M]Daniel Gohlke, W. L. Gore & Associates, MD [M]William E. Haskell, III, US Department of Health & Human Services, MA [E]Diane B. Hess, PBI Performance Products, Incorporated, NC [M]Steve Hudson, Pigeon Mountain Industries, Incorporated, GA [M]H. Dean Paderick, Special Rescue International, VA [SE]Jack Reall, Columbus Fire Division, OH [U]Stephen R. Sanders, Safety Equipment Institute (SEI), VA [RT]Michael T. Stanhope, Southern Mills, Incorporated, GA [M]Doug Stephenson, Walker County Emergency Services, GA [U]Jeffrey O. Stull, International Personnel Protection, Incorporated, TX [SE]Adam R. Varley, Vartest Laboratories, Incorporated, NY [RT]Brian Wackowicz, Intertek, NY [RT]Harry P. Winer, US Department of the Navy, MA [RT]

Alternates

Jason L. Allen, Intertek, NY [RT] (Alt. to Brian Wackowicz)Nicholas J. Curtis, Lion Apparel, Incorporated, OH [M] (Alt. to Karen Lehtonen)Kimberly M. Henry, PBI Performance Products, Incorporated, NC [M] (Alt. to Diane B. Hess)Kim Klaren, Fairfax County Fire & Rescue Department, VA [U] (Alt. to Dean W. Cox)Loui (Clem) McCurley, Pigeon Mountain Industries, Incorporated, CO [M] (Alt. to Steve Hudson)Stephen G. Rasweiler, Fire Department City of New York, NY [U] (Alt. to Stephen J. Geraghty)Angie M. Shepherd, US Department of Health & Human Services, PA [E] (Alt. to William E. Haskell, III)Denise N. Statham, Southern Mills, Incorporated, GA [M] (Alt. to Michael T. Stanhope)

Staff Liaison: Bruce W. Teele

Committee Scope: This Committee shall have primary responsibility for documents on special operations protective clothing and protective equipment, except respiratory equipment, that provides hand, foot, torso, limb, head, and interface protection for fire fighters and other emergency services responders during incidents involving special operations functions including, but not limited to, structural collapse, trench rescue, confined space entry, urban search and rescue, high angle/mountain rescue, vehicular extraction, swift water or flooding rescue, contaminated water diving, and air operations.

This Committee shall also have primary responsibility for documents on station/work uniform garments that are not of themselves primary protective garments but can be combined with a primary protective garment to serve dual or multiple functions.

Additionally, this Committee shall have primary responsibility for documents on the selection, care, and maintenance of special operations protective clothing and equipment by fire and emergency services organizations and personnel.

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

The Committee on Fire and Emergency Services Protective Clothing and Equipment is presenting three Reports for adoption, as follows:

1981-�

Report on Comments F2006 — Copyright, NFPA NFPA 1981The Reports were prepared by the:

• Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment (FAE-AAC)

• Technical Committee on Electronic Safety Equipment (FAE-ELS)

• Technical Committee on Respiratory Protection Equipment (FAE-RPE)

• Technical Committee on Special Operations Protective Clothing and Equipment (FAE-SCE)

Report I of this Report on Comments was prepared by the Technical Committee on Special Operations Protective Clothing and Equipment, and documents its action on the comments received on its Report on Proposals on NFPA 1951, Standard on Protective Ensemble for USAR Operations, �001 edition, as published in the Report on Proposals for the �006 November Meeting.

When adopted the document will be redesignated as NFPA 1951, Standard on Protective Ensembles for Technical Rescue Operations.

The report on NFPA 1951 has been submitted to letter ballot of the Technical Committee on Special Operations Protective Clothing and Equipment, which consists of �0 voting members of whom 18 voted affirmatively and � abstained (Geraghty and Varley).

Mr. Geraghty abstained for the following reason:“I am a new to the committee, I do not have enough information on the

subject at this time.”

Mr. Varley abstained for the following reason:“Since I am new to the committee, I feel more comfortable abstaining

this time around.”

Ms. Lehtonen voted affirmative with the following comments:“Although I am voting affirmatively on this ballot because it

is important not to impede the progress of this standard, there are inconsistencies that need to be commented on.

1. I do not feel that the substantiation provided on 1951-101 (Log #101) is satisfactory. The action and substantiation on this comment and others is inconsistent with the direction of the TCC given in Note 4 in 1951-5 (Log #1). This note directs the TC to review all the ROP requirements for the CBRN ensemble and ensemble element properties to be sure they maintain the same requirements of performance as the non-CBRN ensembles. By setting different performance levels for THL between the CBRN ensemble (�50) and the Rescue and Recovery garment (450) the TC was in direct conflict with the TCC directive.

�. 1951-80 (Log #45) The action and the recommendation of this log do not make sense and are not consistent with the action taken at the TC meeting. The numbering of 8.9.7.1 and 8.9.7.� does not make sense as there is no 8.9.7. In addition CBRN materials and elements should be washed and dried a total of 10 cycles to be equivalent to all other 1951 materials and elements.

Editorial Comments:1. 1951-1 (Log #107) 8.47.7.�(�) in the text 8.1.� should be 8.1.��. 1951-14 (Log #16) This log is not a comment on NFPA 1951, it

was intended for NFPA 198�.�. 1951-61 (Log #9) Committee Comment should state: See 1951-�4

(Log #�4).

The report on NFPA 1951 has also been submitted to letter ballot of the Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment, which consists of �� voting members of whom �0 voted affirmatively, 1 abstained (Bradley), and 1 ballot was not returned (Johnson).

Mr. Bradley abstained stating:“The standard should include requirement for high visibility trim.”

Report II of this Report on Comments was prepared by the Technical Committee on Respiratory Protection Equipment, and documents its action on the comments received on its Report on Proposals on NFPA 1981, Standard on Open-Circuit Self-Contained Breathing Apparatus for Fire and Emergency Services, �00� edition, as published in the Report on Proposals for the �006 November Meeting.

When adopted this document will be redesignated as NFPA 1981, Standard on Open-Circuit Self-Contained Breathing Apparatus (SCBA) for Emergency Services.

The report on NFPA 1981 has been submitted to letter ballot of the Technical Committee on Respiratory Protection and Personal Alarm Equipment, which consists of �8 voting members of whom �0 voted affirmatively, 6 negatively after the circulation of negative ballots (Austin, Bernzweig, Boord, King, Reed, and Rossos), and � ballots were not returned (E. Allen and Lentz).

Ms. Austin voted negatively stating: I wish to change my vote to negative. This, after reading the

comments included with the negative ballots, particularly those of Mr. Bjord, Mr. King, and Mr. Rossos. The most important points made were:

1) NIOSH is unaware of any data that indicate that CBRN respirators provide less protection against TC, than their industrial counterparts.

�) Comport does not appear to be an issue with CBRN compliant SCBAs.

�) The terrorist threat is a reality not only in larger metropolitian areas. 4) NFPA 1500 will mandate CBRN compliant SCBAs. 5) Cost is not a valid argument against cylinder interchangeability. 6) The primary responsibility of the NFPA Technical Committee is to

the end user.

Mr. Bernzweig voted negatively stating: I wish to change my vote on the 1981 ROC. I believe that the

requirement for CBRN protection would provide a greater level of protection for responders using SCBA with little or no drawbacks.

Mr. Boord voted negatively stating:“CBRN protection should be included as a requirement for certification

of SCBA under the �007 edition of NFPA 1981. CBRN protection offers verification of enhanced protection for emergency responders which is not otherwise available. Without CBRN protection evaluation, no SCBA components are tested for permeation, penetration, corrosion resistance or other detrimental effects from exposure to hazardous chemical warfare atmospheres. NIOSH benchmark testing of non CBRN hardened NIOSH certified units against CBRN agents demonstrated that CWA agents could cause catastrophic failures within minutes of exposure.

The selection of the test challenge agents for CBRN protection was based on a comprehensive review of available technical data and consultations with other government agencies (e.g., DOD, DOJ, DOE, etc.). Various chemical data lists were analyzed, including lists from the EPA, ATSDR, NFPA 1994, U.S. Army Center for Health Promotion and Preventative Medicine (USACHPPM) Technical Guide �44, and classified sources. This review established a total of 151 toxic industrial chemicals/chemical warfare agents (TIC-CWA) as potential candidates for challenge agents. The candidate agents were evaluated for permeation (molecularly diffusing through material) and penetration (seeping through interfacing components) characteristics as part of a review of their physical properties.

One of the recommendations received by NIOSH during the public process of developing the CBRN standard was to use the CWA challenge chemicals identified in NFPA 1994, Standard for Chemical Personal Protective Clothing, as part of the NIOSH standard. The NFPA Technical Committee provided recommendations and rationale for the selection of 9 chemicals, including 4 CWA. The CWA test agents were identified as Distilled Mustard, HD; Lewisite, L; Sarin, GB; and VX), and industrial test agents were identified as Liquid TICs (Dimethyl Sulfate (DMS) and Hydrogen Cyanide) and Gaseous TICs (Ammonia, Chlorine, and Cyanogen Chloride). An evaluation was performed on the physical characteristics of the CWA listed in USACHPPM TG �44, the 151 CWA/TIC identified as part of the NIOSH/RDECOM review, and the CWA/TIC listed in NFPA 1994 to determine which of these chemicals could be selected as a representative test agent for the penetration/permeation test. This evaluation concluded that Sarin (GB) and Sulfur Mustard (HD) could be selected as the two representative agents for the penetration/permeation test for the complete listing of 151 CWA/TICs due to their physical properties and molecular structure.

Most materials used for respirator components used in CBRN-approved configurations were used previously in the traditional industrial versions. NIOSH is unaware of any data that indicates the CBRN respirators provide less protection against TICs than their industrial counterparts. The evaluation for CBRN protection provides verification and assurance that the component and material combinations in the approved SCBA configurations provide high resistance to permeation and penetration of hazardous atmospheres of toxic industrial chemicals and materials into the breathing air. This is of importance to all responders subject to extreme exposures to any hazardous industrial chemicals and materials.”

Mr. King voted negatively stating:“The following are some of the reasons that have led me to caste a

negative vote with respect to Committee Document NFPA 1981:At a TC meeting of the NFPA 1981 committee, members voted down a

motion which was made on Log #16� to leave the CBRN requirement for SCBA’s in NFPA 1981. I was unable to attend that important meeting and had I been there I would have spoken out in support of that motion and voted in the affirmative, mandating CBRN compliant SCBA in the next revision of the standard.

The role of first responders in this country has forever changed since the event which occurred in New York City on 9/11/01. If there was any doubt after the first attack on the World Trade Center, which occurred in 199�, that our world and our life as we had known it had forever changed, certainly all doubt was permanently erased after 9/11.

1981-4

Report on Comments F2006 — Copyright, NFPA NFPA 1981There can no longer be any doubt in our minds that future attacks

will inevitably occur and that these attacks will place first responders in mortal jeopardy. What we cannot be sure of is where and in what form these attacks may occur. What we can do is try to anticipate and prepare through better training and equipment to hopefully minimize the detrimental effects that these attacks will have on our first responders.

There has been much speculation that future terrorist events could involve the use of “dirty bombs” or the release of chem/bio or even radiological/nuclear agents. These events could occur almost anywhere in this country, having a widespread, devastating effect over a vast geographic area, involving hundreds to thousands of our citizens and our first responders. The ability of our first responders to have CBRN compliant SCBA would help ensure an increased basic level of protection when responding to such an event.

Of course nothing is ever black and white and there have been many issues raised to support not making CBRN compliant SCBA mandatory, but an option that departments could specify if they saw a need for it. I would like to try to address some of the issues that I have heard and make a response to them.

1. “While I can personally see a need for CBRN compliant SCBA in my department I don’t believe that it is necessary throughout the country and that individual departments should make their own determination.”Response: There is no way that anyone can predict where a future CBRN event will occur in this country. While we can (and should) priortorize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. (At the 9/11/01 event first responders came from surrounding areas that had never had to respond to New York City in the city’s entire history. First responders even came from out of state to lend support.) It is interesting to note that a couple of the first responders who voted against having mandatory CBRN compliant SCBA in this standard acknowledge that their own department insists on CBRN compliant SCBA when purchasing new equipment.�. “It would be wrong to make other departments pay so much more for their SCBA when they don’t foresee a need for them.”Response: After discussions with many SCBA manufacturers, it is apparent that most manufacturers agree that there is little or no additional cost to a department for CBRN compliant SCBA.�. “No CBRN agent will penetrate a non-CBRN compliant SCBA in the breathing time allotted by one “�0 minute” cylinder.”Response: Testing conducted by NIOSH indicate that some CBRN agents could penetrate non-CBRN compliant SCBA in as little as several seconds of exposure.4. “First responders using CBRN compliant SCBA are finding that they are uncomfortable to wear.”The reality is that first responders using CBRN compliant SCBA are not reporting any significant difference relating to the comfort of the equipment.5. “CBRN compliant SCBA will not be as durable.”

In my discussions with SCBA manufacturers there appears to be no reason to believe that CBRN compliant SCBA are any less durable than the non-CBRN compliant products on the market today.

Additionally I would like to comment that in fire districts where the fire department is not the purchasing authority (this is the case in most fire departments in this country today), if it is not required by the NFPA 1981 standard, these fire departments will never be able to get CBRN compliant SCBA even if the want it.

It is also important to keep in mind that CBRN compliant SCBA will provide improved protection against many commonly encountered household or industrial chemicals and other agents which can be routinely encountered by firefighters during the normal course of their duties. In today’s world these chemicals are increasing at an alarming rate.

Lastly, note that the new edition of NFPA 1500 which will be released in �007 states in Section 7.11.1.1 that “All open-circuit SCBA that is purchased new shall be certified as compliant with NFPA 1981 and shall also be certified by NIOSH as compliant with NIOSH Standard for Chemical, Biological, Radiological, and Nuclear (CBRN) Open Circuit Self-Contained Breathing Apparatus (SCBA).”

These are but some of my reasons for believing that it is incumbent upon us to mandate the use of CBRN compliant SCBA for safety of our first responders today.”

Mr. Reed voted negatively stating:“I am voting negatively on NFPA 1981 for a number of reasons.The primary reason is the action taken at the ROC meeting to delete

the requirement that all SCBA meeting NFPA 1981 be CBRN certified by NIOSH. When NIOSH was just developing the standards for SCBA CBRN certification, members of our committee were told by some manufacturers that the materials that would have to be used in the facepiece to pass the CBRN tests would be less comfortable than materials that were then in use. A number of us on the committee were reluctant

to require CBRN protection since the SCBA would be used 99 percent of the time for routine firefighting, and we were concerned about having firefighters’ facepieces less comfortable for routine, daily operations. Once the CBRN-certified SCBA were available, the facepiece material for most was not that much different than the previous facepieces.

The argument during ROC was that many parts of the country may not have a need for CBRN protection. Unfortunately, in the post 9/11 world, I think this is being unrealistic. While major metropolitan areas may be more likely targets of a terrorist event, we have already seen that the terrorists themselves may reside in small communities while they await their opportunity to strike. They may have the chemical, biological or nuclear material in their possession, making the possibility of exposure greater for even small, rural areas.

Both terrorist attacks aside, CBRN-certified SCBA offers greater protection for the firefighter for a very minimal cost. If this protection is not required by the standard, many jurisdictions will not specify this for their firefighters.

I was also disappointed by the misinformation that was disseminated regarding the cylinder interchangeability issue. I was hopeful that we could get meaningful feedback from the fire and emergency services communities. Instead, the vast majority of the comments the committee received cited cost as the factor for their opposition. Primarily, this was because they had been told by some manufacturers that they would not be able to purchase cylinders for their existing SCBA once the new standard came out, which meant they would have to purchase all new cylinders and SCBA that met the new standard. This was simply not true. Most of the issues concerning incompatibility within departments had been resolved prior to ROC.

In summary, the only enhancements to the standard were some changes to the communications test that will probably require manufacturers to use voice amplifiers to pass the test, which may or may not be an improvement over what is already available today, and the addition of a test to address the problem of moisture in electronics compartments.

For all of these reasons, I am voting against the standard.”

Mr. Rossos voted negatively stating:“I just completed my ballot for NFPA 1981. I disagree with the

committee’s action regarding CBRN; therefore I must vote in the negative. I believe it is our purpose and responsibility as members of the committee to strive to design SCBA standards and codes where the end user has the highest level of protection possible. I realize as an end user, that we need to strike a balance between best protection and secondary effects such as comfort, size, weight, etc. and in some regards even economics. We were given no evidence of any of the above compromises to mandating CBRN on all SCBAs. The only thing that we know for sure is that the end user would have a higher level of protection with CBRN as opposed to without.

Some members of the committee argued the point that municipalities should have a choice in what SCBA they purchase. Very few end users have a choice in this matter. Most choices are made by purchasing agents or administrators. They often base their decisions on the minimum legal standard available for the lowest price. I believe our first and most important responsibility on this committee is to who wears SCBA, not to who buys SCBA. Regretfully, when there was no cost involved or reduction in protection, we voted to give the choice to the buyer and not the user.”

Mr. Allen voted affirmative with the following comments:“1. 1981-1 (Log #69) K. Lehtonen should have mannequin covering

specified in 1981-�10 (Log #184) in Section 8.11.�. 1981-83 (Log #CC2) Technical Committee should have pass/fail

value of 80 percent in 7.10.1.”

Mr. Beck voted affirmative with the following comments:“I believe it is in the Fire Service’s best interest to launch the NFPA

1981 standard in February �007 and to have its issuance coincident with the launch of NFPA 198�.

However, I also believe strongly that CBRN protection should not be an option for SCBA that are compliant to the NFPA 1981 standard. I understand the argument that smaller user communities may feel that the risk of a terrorist attack is remote, although with today’s interstate system any town could be susceptible. And, potential attacks on large cities could well require that smaller municipalities respond. Perhaps most importantly though, CBRN certification results in an SCBA that provides better overall respiratory protection against a wider range of Toxic Industrial Chemicals that fire fighters face on a routing basis in their “normal” fire suppression duties.

The cost of CBRN protection is too small and the risk of not including it too high for it not to be a requirement. I recommend that the committee consider the processing of a TIA to the standard to address this issue separately and so as not to delay the issuance of the NFPA 1981 document in February �007.”

Mr. Birch voted affirmative with the following comments: I am keeping my vote of the affirmative, but wish to add a comment to

my previous comment.

1981-5

Report on Comments F2006 — Copyright, NFPA NFPA 1981 Comment: The reason I believe that it is proper at this point in time

to not require CBRN is because although NIOSH and other agencies make/made a good point of testing SCBAs against the list of chemical agents, there are missing tests. There are no tests to show that SCBAs as manufactured now, when altered to meet CBRN requirements, are still resistant to the ‘normal’ atmospheres and chemical agents in which they are currently used.

When additional data shows that SCBAs with altered materials and designs to meet the CBRN requirements still perform as well as or better than the old SCBA materials and designs in regular (non-CBRN) use in current applications, then is the time to reconsider the TC action. Since the majority of SCBA units are expected to be used in non-CBRN applications, it is important for the TC to be technically convinced that altering the unit doesn’t devalue its reliability in standard uses.

The report on NFPA 1981 has also been submitted to letter ballot of the Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment, which consists of �� voting members of whom 18 voted affirmatively, � negatively (Bradley, Curtis, Statham), and 1 ballot was not returned (Johnson).

Mr. Bradley voted negative stating:“There are many industrial and volunteer firefighters that have no need

or desire to pay extra for this feature when the risk of WMD attack small.Fire departments should be allowed to conduct their own risk

assessment to determine if CBRN is necessary. Adding a cost burden of CBRN for all SCBA, could preclude departments, without government funding, from purchase more modern up-to-date SCBA.

Also, since NFPA 1971 clearly allows for option CBRN protection these two documents should correlate with each other and offer CBRN as an option for both clothing and breathing apparatus.”

Mr. Curtis voted negative stating:“CBRN protection in SCBA is an option under NIOSH. The Technical

Committee voted decisively to include that option in their ROC. I believe the TCC has overstepped its authority by overruling the decision of the NFPA 1981 Technical Committee, and by forcing a mandatory requirement for CBRN certification in SCBA. At a time when this TCC is attempting to portray itself as less autocratic, more inclusive and actually capable of understanding the diverse needs of law enforcement, the medical profession, etc., it is ironic that it cannot help but inflict its own agenda on others. The agenda, as ever, is viewed from the perspective of structural fire fighting, and the cause du jour is CBRN protection against possible future acts of terrorism (in case they include C, B, R, or N which; so far, none have).

Is there any aspect of other protective values, comfort, durability, cost, operational performance, testing integrity, etc. that will not be sacrificed to further this narrow agenda; one that is funding the professional and business activities of so many TCC members through federal TSWG grants, etc? What’s next? Further dilution of the recently passed performance standards for CBRN in PPE, then conversion from optional to mandatory CBRN protection in turnouts?

Again, CBRN protection in SCBA is an available option under NIOSH certification. NFPA 1981 should permit that option as was voted by the Technical Committee.”

Ms. Statham voted negative stating:“My negative vote is meant only as sign of support for the technical

committee which had the benefit of industry input and countless hours of discussion on the matter.”

Report III of this Report on Comments was prepared by the Technical Committee on Electronic Safety Equipment, and documents its action on the comments received on its Report on Proposals on NFPA 198�, Standard on Personal Alert Safety Systems (PASS), 1998 edition, as published in the Report on Proposals for the �006 November Meeting.

The report on NFPA 198� has been submitted to letter ballot of the Technical Committee on Electronic Safety Equipment, which consists of �4 voting members of whom �1 voted affirmatively, 1 negatively after the circulation of negative ballots (Rascoe), and � ballots were not returned (Haase and Mills).

Mr. Rascoe voted negatively stating:“1. There has been no validation or verification of the testing for

the new requirement for high temperature (500˚F) @ 5 minutes. There has been no validation or verification that this new requirement can be realized. More testing should be done to study this requirement more fully and then made applicable as needed.

�. The requirement for the 500 Hz component should be removed. There has been NO testing on this feature so as to ascertain whether or not this is even relevant and worthy. We realize the theoretical application as explained by Virginia Tech but the practical application should be studied. This has not even been addressed through any type of controlled testing. We simply do not know what impact if any this new requirement will have.

�. There are many new challenging and aggressive requirements that are being mandated by this new version of the standard. With the limited or no verification or validation testing that has been done it is impractical not to allow a time extension for the development and implementation of the new technologies such as the changes required to meet the 500˚F and the 500 Hz component of the signal.”

Mr. Allen voted affirmative with the following comments:“1982-118 (Log #11) Bryner, should be AIP and have measurement

technique specified by M. Rupert 198�-40 (Log #119) and not measured within heat chamber.”

Ms. Lehtonen voted affirmative with the following comments:“1. 1982-48 (Log #47), 1982-49 (Log #48), 1982-52 (Log #54), 1982-

53 (Log #49), 1982-56 (Log #50), 1982-58 (Log #51), 1982-59 (Log #52), 1982-61 (Log #53). All of the text in these comments was revised at the ROC meeting and with the submitter present the modifications were accepted. In the ROC ballot none of the agreed upon language modifications have been made. However in 198�-�8 (Log #�0) these language modifications have been made and should be how the text in Chapter 7 is reflected.

�. 1982-64 (Log #10) This log was modified at the ROC meeting with the submitter present and the modifications were accepted. The revised text was to not create a new 7.14 but to replace the existing 7.11. In addition the performance requirements were also modified. However in 198�-�8 (Log #�0) these language modifications have been made and should be how the text in Chapter 7 is reflected.

�. 1982-111 (Log #34) The performance requirements were modified and the data logging is evaluated to this paragraph needs to remain.

4. 1982-116 (Log #37) This log was modified at the ROC meeting with the submitter present and the modifications were accepted. Additional requirements for a section 8.17.6 for reporting were added as part of this log.

5. 1982-121 (Log #121) This log was modified at the ROC meeting with the submitter present and the modifications were accepted. The term firefighters (used twice in the second line) was replaced by Emergency services personnel.”

Mr. McKenna voted affirmative with the following comments:“During my review of the document I found several instances where

changes were made during the ROC meeting and reflected in my notes, but not in the document.

I am working on putting a list together but the list is not complete.”

The report on NFPA 198� has also been submitted to letter ballot of the Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment, which consists of �� voting members of whom �0 voted affirmatively, 1 negatively (Bradley), and 1 ballot was not returned (Johnson).

Mr. Bradley voted negative stating:“The requirement for the 500˚F (5 min) test should be removed from

8.1�.5.7.”

1981-6

Report on Comments F2006 — Copyright, NFPA NFPA 1981____________________________________________________________1981-1 Log #69 FAE-RPE Final Action: Accept(Entire Document)____________________________________________________________Submitter: Karen Lehtonen, Lion ApparelComment on Proposal No: 1981-�Recommendation: Editorial corrections: �.�.� The reference for Supplied Air Respirator should be �.�.45 (replace �.�.44). �.�.7 The reference for NIOSH Certified should be �.�.�0 (replace (�.�.�9). �.�.11 The reference for Supplied Air Respirator should be �.�.45 (replace �.�.44). �.�.16 The reference for Negative Pressure SCBA should be �.�.�9 (replace �.�.�8). �.�.�4 The reference for Positive Pressure SCBA should be �.�.�� (replace �.�.��). �.�.�9 The reference for Supplied Air Respirator should be �.�.45 (replace �.�.44). �.�.40 The reference for Self Contained Breathing Apparatus should be �.�.4� (replace �.�.41). �.�.41 The reference for Self Contained Breathing Apparatus should be �.�.4� (replace �.�.41) and the reference for Supplied Air Respirator should be �.�.45. �.�.4� The reference for Supplied Air Respirator should be �.�.45 (replace �.�.44). �.�.44 The reference for Rated Service Time should be �.�.�7 (replace �.�.�6). 4.1.4 The reference at the end of the sentence should be �.�.�0 (replace �.�.�9). 8.1.� Samples. Each sample to be tested shall be as specified in 4.�.5 4.�.9. 8.�.� Samples. Each sample to be tested shall be as specified in 4.�.5 4.�.9. 8.�.� Samples. Each sample to be tested shall be as specified in 4.�.5 4.�.9. 8.7.� Samples. Each sample to be tested shall be as specified in 4.�.5 4.�.9. 8.8.� Samples. Each sample to be tested shall be as specified in 4.�.5 4.�.9. 8.10.� Samples. Each sample to be tested shall be as specified in 4.�.5 4.�.9. 8.10.5.6 The average of the score values obtained in 8.10.5.4.� 8.10.5.5.� and 8.10.5.5.4 shall be calculated. 8.11.� Samples. Each sample to be tested shall be as specified in 4.�.5 4.�.9. 8.11.4.�.1 The assembled protective covering shall consist of at least an outer shell and a thermal liner and shall have an average thermal protective performance (TPP) of not less than �5.0 when testing in accordance with 5.1.1 7.1.1 of NFPA 1971, Standard on Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting. 8.11.4.4 The test headform shall be attached to the breathing machine as specified in Figure 8.1.4.1� 8.1.4.9, with the modification... 8.11.4.5.1 The protective hood shall meet the hood requirements of NFPA 1971, Standard on Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting. 8.1�.� Samples. Each sample to be tested shall be as specified in 4.�.5 4.�.9. 8.14.� Samples. Each sample to be tested shall be as specified in 4.�.5 4.�.9. 8.14.4.� Test subjects shall wear full structural fire fighting protective ensemble, including coat, trousers, helmet, hood, gloves, and footwear, that is certified as compliant with NFPA 1971, Standard on Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting. 8.15.� Samples. Each sample to be tested shall be as specified in 4.�.5 4.�.9. 8.16.� Samples. Each sample to be tested shall be as specified in 4.�.5 4.�.9. 8.17.� Samples. Each sample to be tested shall be as specified in 4.�.5 4.�.9. 8.18.1.� Samples. Each sample to be tested shall be as specified in 4.�.5 4.�.9. 8.18.�.� Samples. Each sample to be tested shall be as specified in 4.�.5 4.�.9. 8.19.� Samples. Each sample to be tested shall be as specified in 4.�.5 4.�.9. 8.�0.� Samples. Each sample to be tested shall be as specified in 4.�.5 4.�.9. 8.�1.� Samples. Each sample to be tested shall be as specified in 4.�.5 4.�.9. 8.��.� Samples. Each sample to be tested shall be as specified in 4.�.5 4.�.9. 8.�4.�.1 One SCBA sample shall be tested with each surrogate cylinder and valve assembly as specified in 8.�4.x.x 8.�4.�.�.

8.�4.5.4 A force of �00N (45 lbf) shall be applied to the intersection point specified in 8.�4.4.� 8.�4.4.4, in the six directions shown in Figure 8.�4.5.4. The force shall be applied for a period of 10 seconds +5/-0 seconds allowing the measurements to be taken. 8.�6.�.1 Samples. Each sample to be tested shall be as specified in 4.�.5 4.�.9. A.4.6.1 ISO/IEC Guide �7 is a component of accreditation of certification organizations specified in 4.1.5 and 4.�.� of this standard. Those paragraphs contain mandatory reference to ISO/IEC 65 in which ISO/IEC Guide �7 is referenced.Substantiation: Editorial corrections.Committee Meeting Action: Accept

____________________________________________________________1981-� Log #7 FAE-RPE Final Action: Accept in Principle(Entire Document)____________________________________________________________Submitter: Glenn Ericksen, Arlington Heights Fire DepartmentComment on Proposal No: 1981-1Recommendation: There is no need to make SCBA cylinders interchangeable between various manufacturers of SCBA equipment. Do not create an unnecessary level of expense and effort to fix a problem that does not exist.Substantiation: In over �0 years in the fire service I have never run into a situation where it was necessary to mix SCBA cylinders on an emergency scene. As all cylinders have a common filling thread, and SCBA cylinders are refilled on the scene rather than exchanged between units, there is no need to make them interchangeable between manufacturers. It would be better to focus on the different types of fire hose coupling threads which IS creating difficulty in the field.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-� Log #9 FAE-RPE Final Action: Reject(Entire Document)____________________________________________________________Submitter: John Jackson, Westchester County Department of Emergency ServicesComment on Proposal No: 1981-4Recommendation: Delete : Do market analysis to determine cylinder most widely used by the agencies.Substantiation: Replacement of cylinders currently in service. Do market analysis of cylinders used by fire service. Determine cylinders thread most widely used and make adapters available for the remainder. Until all cylinder can be replaced thru attrition.Committee Meeting Action: RejectCommittee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-4 Log #1� FAE-RPE Final Action: Accept(Entire Document)____________________________________________________________Submitter: Stephen S. Solomon, Tamwork Fire DepartmentComment on Proposal No: 1981-�Recommendation: Delete requirement for SCBA cylinder interoperability.Substantiation: Currently our (the fire service’s) cascade systems can refill any brand and most can fill at multiple pressures. There is no problem, so why create one by making everyone airpacks obsolete. I am looking to purchase airpacks and cannot until this is resolved.Committee Meeting Action: Accept

____________________________________________________________1981-5 Log #14 FAE-RPE Final Action: Hold(Entire Document)____________________________________________________________Submitter: David Covington, San Antonio Fire DepartmentComment on Proposal No: 1981-�Recommendation: It is my understanding that the committee is working on cylinder interoperability compatibility. Although this may be a good idea, I caution the committee to consider it very carefully in light of recent events in San Antonio. We recently experienced a number of o-ring failures where the SCBA valve screws in to the cylinder. After sending units to NIOSH and Southwest Research Institute (a respected research lab in San Antonio), we have found that the type of fitting that we now use in our SCBA cylinders is antiquated and based on a 1965 CGA standard.Substantiation: The engineers at SWRI have concluded that the design is flawed and this would explain our o-ring failures. Our informal poll of departments confirmed that virtually all SCBA manufacturers have o-ring issues. The CGA spec does not include an o-ring but allows it when hand tightening. We have more information if you wish to see it, but the real issue is that it would be wrong to build an interoperability based on a defective design that has plagued the fire service for many years. The

1981-7

Report on Comments F2006 — Copyright, NFPA NFPA 1981correct method would be to consult the dive people who have ditched the design and work out a new fitting that works for firefighters.Committee Meeting Action: HoldCommittee Statement: The Comment has proposed complex or significant changes that would cause the Committee to restudy the related issues to be sure that all effected text is reasonably and responsibly investigated and addressed. These can not be accommodated within the compressed time frame the Committee has to process the comments for the ROC.

____________________________________________________________1981-6 Log #�5 FAE-RPE Final Action: Accept in Principle(Entire Document)____________________________________________________________Submitter: C Jorgensen, Fire Apparatus Magazine, LLCComment on Proposal No: 1981-�Recommendation: 1. Delete all sections regarding cylinder interoperability. �. Delete all references to CBRN certification for volunteer fire departments or any department covering communities of less than 40,000 population by most recent U. S. Census.Substantiation: Firefighter-to-Chief Officer �5 years; fire magazine editor 10 years. 1. Adoption would place undue financial burden on fire departments. �. Adoption would force incompatibility of SCBA within departments for many years. �. CBRN decision should be left to local jurisdictions in rural communities served by volunteer fire departments as no such need has been identified by fire service itself. 4. Fire Service members and chief officers say cylinder interoperability provides no benefits as air supply not a problem.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-7 Log #�4 FAE-RPE Final Action: Reject(Entire Document)____________________________________________________________Submitter: Joe McLaughlin, Cottontown FDComment on Proposal No: 1981-�Recommendation: In favor of all cylinders being interchangeable. Listen to the fire fighters not the manufacturers.Substantiation: None given.Committee Meeting Action: RejectCommittee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-8 Log #85 FAE-RPE Final Action: Accept in Principle(Entire Document)____________________________________________________________Submitter: James H. Young, Bethel Fire Dept.Comment on Proposal No: 1981-�Recommendation: Making all bottles for SCBA use the same to fit all makes of SCBA units bottle policy.Substantiation: We do not feel that there is any problem with the current policy regarding SCBA bottles, we have had no problems and feel this is not a good idea.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-9 Log #87 FAE-RPE Final Action: Reject(Entire Document)____________________________________________________________Submitter: Alexander Rodriguez, Mansfield Public SafetyComment on Proposal No: 1981-�Recommendation: Mansfield Public Safety supports the proposed requirements. This is essentially the same as when fire hose threads were standardized.Substantiation: If there are no set standards for interchangeability of air bottles, some SCBA manufacturers will continue to make proprietary air bottles.Committee Meeting Action: RejectCommittee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-10 Log #88 FAE-RPE Final Action: Hold(Entire Document)____________________________________________________________Submitter: I. David Daniels, International Association of Fire ChiefsComment on Proposal No: 1981-�Recommendation: The Safety, Health and Survival section of the IAFC is in favor of changes to SCBAs that provide for interoperability. To this

end, we believe that the most effective approach would be to require the retroactive installation of a standardized RIC/RIT connection, in addition to requiring that all new assemblies be provided with the connection. We agree that work needs to be done on cylinder standardization, but do not feel it reasonable to expect that this would occur in a reasonable period of time, given the technical financial and legislative changes that will be necessary to accomplish this.Substantiation: The problem with cylinder standardization in the standard is the reality that many agencies will not be able to comply with the requirement in the short term principally for financial reasons. Fire Departments continue to struggle with shrinking budgets; therefore, it does not seem like a good idea to create a requirement that few will strive to achieve due to perceptions barriers, when the same objective can be achieved by alternative means. Further, a requirement in the standard for standardization of cylinders may create a greater safety hazard in its place if organizations elect to ignore it.Committee Meeting Action: HoldCommittee Statement: The Comment has proposed complex or significant changes that would cause the Committee to restudy the related issues to be sure that all effected text is reasonably and responsibly investigated and addressed. These can not be accommodated within the compressed time frame the Committee has to process the comments for the ROC.

____________________________________________________________1981-11 Log #90 FAE-RPE Final Action: Accept in Principle(Entire Document)____________________________________________________________Submitter: Michael Leestma, Bowling Green Fire DivisionComment on Proposal No: 1981-�Recommendation: The Technical Committee (TC) on Respiratory Protection Equipment would like the emergency services community to take special note of the proposed changes to the proposed �007 edition of NFPA 1981 that would allow interchangeability of SCBA breathing air cylinders and valve assemblies between various manufacturers’ SCBA.Substantiation: By forcing all emergency services to have interchangeable SCBA bottles you would be causing many agencies to not be able to afford this high cost of upgrades. Our department has just purchased new SCBA’s and this would render all of our new units unusable unless we somehow retrofit them. These SCBAs are NIOSH approved only as designed. A retrofit would void the approval. The new RIC UAC fitting on all new SCBA’s allows for rapid filling. This should allow plenty of time for change out of empty bottles.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-1� Log #9� FAE-RPE Final Action: Accept in Principle(Entire Document)____________________________________________________________Submitter: Hank Clemmensen, Palatine Rural Fire Protection DistrictComment on Proposal No: 1981-�Recommendation: Remove all references to Interchangeability of SCBA breathing air cylinders and valve assemblies between various manufacturer’s of SCBA. The Illinois Fire Chiefs Association Board does not support the proposed revision to NFPA 1981 requiring interoperability of SCBA cylinders.Substantiation: The Illinois Fire Chiefs Association Board does not support the proposed revision to NFPA 1981 requiring interoperability of SCBA cylinders. The costs for interoperability appear to be substantial and would be solely funded by local governments. Currently there are a number of important issues that remain unanswered. We do not believe it is justifiable to burden municipalities or fire protection districts with a requirement that will involve substantial financial costs without demonstrable increases to firefighter safety. The competition between manufacturers has resulted in vast improvements to SCBA’s used by firefighters. This proposal would freeze the current cylinder size, pressures and valve configurations, thus restricting new technology. We believe this move has the potential to suppress further innovation and most likely will do nothing to enhance firefighter safety.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-1� Log #94 FAE-RPE Final Action: Accept in Principle(Entire Document)____________________________________________________________Submitter: Thomas A. Stalnaker, Goshen Fire CompanyComment on Proposal No: 1981-�Recommendation: Remove the requirement for cylinder interchangeability.Substantiation: A) The proposed change is not driven by a need in the fire service, which generally feels that the need does not exist. Instead

1981-8

Report on Comments F2006 — Copyright, NFPA NFPA 1981it was originally driven by a request from the Department of Homeland Security, which has since backed away from this request. It is not in the best interest of the Fire Service, and thus the public we serve. B) The requirement would create the opposite from the intended effect for 15 to �0 years as departments gradually change over to the new equipment. Few departments can afford to change all their SCBA units at the same time, and this would prevent interoperability between new units and many existing units. This will effect everyday operations, while not solving the interdepartmental interoperability problem, if it in fact exists. By the time the change over is complete, the prescribed design will certainly be obsolete necessitating starting the process all over again. Who of us would consider using air cylinders designed �0 years ago (steel ��00 psi cylinders)? C) If this change were to be enacted, manufacturers will stop producing replacement cylinders for existing SCBA, forcing departments to replace SCBA units when the cylinders need to be replaced, further exacerbating the problems of incompatible mixtures of SCBA units. If smaller departments can not afford to replace them, they will have to use cylinders beyond their allowed life, or do without SCBA. Neither situation improves safety for firefighters or the public. D) Forcing a specific design on SCBA manufacturers will prevent innovations and improvements that in the long term improve safety for firefighters. E) Interchangeability of SCBA cylinders is not a problem in the fire service. Even in mass incidents and terrorist attacks. The commanders at both the World Trade Center and Pentagon on 9/11/01 have stated that they did not have any problems with SCBA cylinders. The Chief of New Orleans Fire Department has said the same thing about the Katrina operations in �005. F) The cost for replacing all the SCBA units in service would run into many millions of dollars. This expense could only be paid by superseding other requirements that every fire department has. Without this wholesale replacement, the apparent aim of this proposal would not be realized.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-14 Log #98 FAE-RPE Final Action: Accept in Principle(Entire Document)____________________________________________________________Submitter: Donald M. Donaldson, Greater Sudbury Fire ServicesComment on Proposal No: 1981-1Recommendation: Insert: All cylinders to be left as is.Substantiation: Very concerned about cylinder inter-operability and impact on our organization. No need for this in the world we operate in up in Northern Ontario and this will cost money which is better spent elsewhere these standards are for all and not just law enforcement based groups.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-15 Log #99 FAE-RPE Final Action: Accept in Principle(Entire Document)____________________________________________________________Submitter: J.W. Douglas, Town of Fort Erie Fire DepartmentComment on Proposal No: 1981-�Recommendation: Revision to NFPA 1981 Standard in �00� included significant changes to SCBA including the provision of RIC connections to facilitate air transfer between users or spare cylinders, as well as Heads Up Display (HUD). These new features added substantial cost to each new SCBA being purchased as well as the need for batteries to operate the electronics in the SCBA. The changes from the �00� edition are still having significant impact across the Province of Ontario. Many departments have begun changing SCBA to meet the �00� standard and have a mix of SCBA. If the proposed �007 standard were adopted some fire departments may end up with three or more styles of SCBA. This presents major challenges for training and safety of firefighters who may have to use any of these styles. The introduction of new SCBA that have cylinders that are not interchangeable with the current inventory creates problems to ensure provision of adequate number of cylinders to supply both current and new style SCBA and therefore is counterproductive to the stated purpose of improving fire ground interoperability. It also appears that the cylinders will only be cross-applicable within any given pressure band - 4500 psi cylinders can still only be used in 4500 psi packs. Given the equipment differences that exist in both automatic and mutual aid situations between departments, SCBA equipment pressure differences will negate any interoperability benefit. Given that this upgrade or retrofit would require changes to both the SCBA and the Cylinder, this is not even as simple as the requirements to upgrade current SCBA to add RIC/UAC and HUD. The costs of this upgrade would be extreme.

An additional concern is the possibility of poor quality breathing air being provided and interchanged. Breathing air quality problems were identified in Ontario in recent years and there is still concern that some departments are operating air compressors that do not provide compressed breathing air that meets the CSA Z97.4 Standard. Interchange of cylinders before assurance that the air meets the required standards could result in SCBA that is contaminated and presents a danger to firefighters. It is the opinion of the OAFC that what is required is a period of stability within this standard so that departments can both logistically and financially manage the retrofit process to the �00� edition. While there is technically no mandate to retrofit existing equipment, a number of progressive departments, diligently strive to maintain equipment so that it is consistent with the newest trends in efficiency, operation and certainly health and safety. Introducing yet another major functional revision to SCBA will simply be financially prohibitive.Substantiation: Financial hardships to progressive department trying to maintain currency of standards.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-16 Log #111 FAE-RPE Final Action: Accept(Entire Document)____________________________________________________________Submitter: Beverly Gulledge, Scott Health & SafetyComment on Proposal No: 1981-�Recommendation: Requesting interchangeability requirements be deleted as follows: ● 5.1.1 and an interchangeable breathing air cylinder product label. ● 5.1.1.2 Delete entire clause. ● 5.1.7 through 5.1.7.2 Delete all clauses. ● 5.2.4 Delete entire clause. ● 6.1.4 and an interchangeable SCBA cylinder and valve assembly ● 6.5 through 6.5.4 Delete all clauses. (Move 6.5.5 to Section 6.1) ● Figure 6.5.1 Delete entire figure. ● 7.16 through 7.16.3 Delete all clauses. ● 8.23 through 8.23.6 Delete all clauses. ● 8.24 through 8.24.7 Delete all clauses. ● Table 24.4.2 Delete table. ● 8.25 through 8.25.6 Delete all clauses.Substantiation: Problem: Cylinder interchangeability as required in the NFPA 1981 ROP would render SCBA within the same (small or large) emergency services department non compatible. ● Substantiation: The confusion this situation presents would be present each day and at each response. Imagine trying to maintain a supply of two styles of cylinders for use with two styles of SCBA (interchangeable and non interchangeable) at each response site. Problem: Interchangeability of SCBA cylinders is perceived by several Federal agencies (Federal Emergency Management Agency, Interagency Board, etc.) as being the necessary to provide sufficient breathing air for large number of emergency worker using SCBA. ● Substantiation: The ability to fill SCBA cylinders at: (1) the response site, (�) the staging areas, (�) the maintenance shops using compressor and/or cascade systems render interchangeability of SCBA cylinders obsolete. ● Substantiation: FDNY has documented that the interchangeability of SCBA cylinders was never a factor during the attacks, rescue, and recovery operations at the World Trade Center. ● Substantiation: Fairfax County Fire and Rescue reports that interoperability of SCBA cylinder did not affect the ability of the fire service to perform during the multi-jurisdictional response to the fire and collapse at the Pentagon. ● Substantiation: New Orleans Fire Department reports that during Hurricane Katrina’s aftermath the fire companies did not run short of breathing air for any reason. ● Reason: Richard S. Tobin’s (Deputy Chief, FDNY) Nov. 14, 2005 letter to the Fire Service User Community of Self-Contained Breathing Apparatus. ● Reason: Fire Apparatus and Emergency Equipment Magazine’s NFPA Seeks Comments on SCBA Interchange Proposal” by C. Peter Jorgensen. Note: Supporting material is available for review at NFPA Headquarters.Committee Meeting Action: Accept

____________________________________________________________1981-17 Log #19� FAE-RPE Final Action: Accept in Principle(Entire Document)____________________________________________________________Submitter: Dusty Stevens, Byers Volunteer Fire DepartmentComment on Proposal No: 1981-1Recommendation: Please delete interchangeability requirement for SCBA bottles.Substantiation: Our department sees no need for this requirement, not have we ever read or heard of this being an issue with any agency in the fire service.

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Report on Comments F2006 — Copyright, NFPA NFPA 1981 It will be an unfair burden on the agencies that will have to comply as well as the taxpayers that will ultimately have to pay the bill. Let us use our resources to solve legitimate problems. If it ain’t broke, don’t fix it.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-18 Log #194 FAE-RPE Final Action: Accept in Principle(Entire Document)____________________________________________________________Submitter: Niles Weborg, Ephraim Fire DepartmentComment on Proposal No: 1981-�Recommendation: First, let me state that our department is vehemently opposed to the proposed standard for the SCBA bottle compatibility, and wish the interchangeability requirements be deleted.Substantiation: Along with our neighboring community fire departments we have standardized our air packs and bottles across all jurisdictions. We all use common bottles, manufacturers and pressures. A phasing in of bottles over time will create compatibility issues we currently don’t have. Over time this issue may resolve itself as bottles are removed from service and replaced. However, I know of departments in my areas that continue to buy new air packs with aluminum bottles so they do not face the mandatory replacement issues. These departments may never see the new bottles. While all agree cost should never be a primary concern when discussing safety. This may place an unfair tax burden on our community residents, our cost for replacement would be approximately $1,600 per bottle with a supply of thirty bottles for our department our cost would be as much as $48,000. This cost will be financially beyond ours and I am sure many of our neighbors reach. Many of us have only recently been able to move to NFPA compliant air packs through the Fire Act grant programs, we could only hope that if the revised standards are passed, future federal grants will be available to assist small departments such as our. I agree that interoperability is a major issue facing the fire service today; I feel strongly that there are many other issues that should be addressed that are far more urgent and significant than the air bottle issue. If I had funding available, I would much prefer to be able to address simple day to day compatibility issues like radio compatibility, universal training abilities and levels, hose connection issues, and hydrant fittings as these issues that not only face us in a major crisis but also on a day to day basis.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-19 Log #195 FAE-RPE Final Action: Accept in Principle in Part(Entire Document)____________________________________________________________Submitter: Steven Edwards, Fire Chiefs Association of Massachussetts, Inc.Comment on Proposal No: 1981-�Recommendation: Be advised that the association overwhelmingly opposes the proposed changes to NFPA 1981.Substantiation: The feeling is that over the past few years, millions of dollars of grant money has been spent on upgrading the SCBA capabilities of hundreds of fire departments. These upgrades include, but are not limited to, newer models with upgraded features, increases in air volume/pressure ratings, new purchases or upgrading of mobile fill stations, and new purchases or upgrading of station cascade systems. The chiefs all stated that they have worked with their neighboring communities in the past and have developed procedures to provide adaptors in the event that various types or manufacturers units need to be filled during mutual aid emergencies. Not one chief stated that their department had ever had a problem filling bottles while at the scene of mutual aid calls. The majority of chiefs are seriously concerned with the financial implications that this change may cause. Most departments try to follow the very professional NFPA guidelines, but this particular proposal may cause severe budgetary problems. In a time where layoffs and station closures are taking place in order to function within budgetary restraints, there is no need to propose a regulatory change that has such far reaching implications.We are all struggling with “national” and “federal” proposals on NIMS, national mutual aid systems, and interoperability, to name a few, and without federal funding there is no way that this requirement will be embraced by the Massachusetts fire service.Committee Meeting Action: Accept in Principle in Part 1. Accept in Principle the deletion of the requirements for cylinder interchangeability. �. Reject other changes to the document.Committee Statement: 1. See Committee Comment 1981-76 (Log #CC1). �. The committee has added other changes to this edition to enhance the safety of the users.

____________________________________________________________1981-�0 Log #�07 FAE-RPE Final Action: Reject(Entire Document)____________________________________________________________Submitter: Ross Babcock, Stone Mills Township Fire DepartmentComment on Proposal No: 1981-�Recommendation: Please note concern reference new changes. H&S is a concern for this new change.Substantiation: We are a small volunteer department with 4 stations, 100 firefighters and 18 apparatus. We have 48 SCBAs which are identical and in good working order, but are on the older side of things. As a health safety issue a few years back we standardized in 1998 so that all stations were the same for training/reserve etc. How can 1/you justify changing old packs when we are under tight budget restraints? 48 packs $�000 plus all bottles require upgrades as well 48 × 600 = $58,000. 48 pack = $144,000 + 08 bottles = $58,000 Grand total =$�0�,800.00.Committee Meeting Action: RejectCommittee Statement: The edition of NFPA 1981 hat this edition will replace is the �00� edition, not 1998 edition. However, see Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-�1 Log #�19 FAE-RPE Final Action: Accept(Entire Document)____________________________________________________________Submitter: Ron King, Town of Sherman Volunteer Fire DepartmentComment on Proposal No: 1981-�Recommendation: It has come to our attention, that the NFPA Technical Committee is currently considering requiring all self-contained breathing apparatus (SCBA) to be interchangeable in all respects. this would include connections, carrying devices and standardized bottles. As a small rural fire department in Northern Wisconsin we would like to express our opposition to this proposal.Substantiation: The costs alone to do this throughout the nation would make for a tremendous burden not only on small fire departments, such as ours, but on all fire departments. We realize that this is an outgrowth of work FEMA has done since 9-11 and has come under the umbrella of the new buzzword “interoperability”. but, for what purpose? Small fire departments such as ours often have to share resources on the fire ground and we have had no difficulty with adequate air supply for our firefighters. Already, we have common connections on all SCBA for refilling bottles. No matter what manufacturer, the connections are the same. This is really all the interoperability that is needed. Never has it been the case that we need to interchange bottles between one firefighting unit and another. Each department brings to the fire scene its own brand of bottle plus at least one extra for each one that is in use. That is more than adequate for even very complex multi-incident situations. The only really necessary interoperability factor is already in place and that is a universal refilling valves to refill from a portable cascade system. The important thing is to have continuous air supply and this we do have currently. We can push this “interoperability” too far. We need to weight the cost versus the benefits. In the case of SCBA the costs would run into many billions of collars and the benefits would be minuscule to nonexistent. For the next 10 to 1� years there would still be incompatibility due to the time necessary to changeover from the old SCBA to the new SCBA. Beyond that we would now have a system in place that past experience would indicate is not superior to the present system. Finally, standardization of all SCBA systems may actually hurt firefighters in the long run. Currently, there is incentive for different branches to update, change, and innovate in order to try to entice fire departments to bury their brand. If all is standardized, there is little to choose from one brand to another, as well as little incentive for the various companies to try to improve and make theirs better than the competition. Consequently, innovations will be lacking and in the long run the firefighter on the line will suffer the consequences.We believe there are much more important places where fire departments and national resources should be spending their money. Consequently, we urge you to rethink this and not include universal SCBA as part of your final document.Committee Meeting Action: AcceptCommittee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-�� Log #��0 FAE-RPE Final Action: Accept in Principle(Entire Document)____________________________________________________________Submitter: Ken Eden, Niagara on the LakeComment on Proposal No: 1981-�Recommendation: Our objections to interoperability of SCGA bottles are as follows: 1. In over �5 years of fire service in three provinces and five departments, the problem of lack of interoperability of air bottles has never been a concern because the issue never came up. �. Should this change be adopted it would essentially eliminate the possibility of being able to phase in a replacement program for SCBA as

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Report on Comments F2006 — Copyright, NFPA NFPA 1981a department would not be able to interchange bottles within their own system until all units had been replaced. �. It would probably take �0-�5 years for all current SCBA to be replaced so why bother to implement a program with a �5 year pay back? It is not cost effective. 4. There are already problems with noncompatibility between high and low pressure sets and the proposed change would not resolve this issue. 5. The suggested cost of new SCBA that meets the proposed standard are simply too high for perceived benefits that, we feel, are negligible and would do little to improve firefighter safety. 6. We do not see how this will be a significant improvement to firefighter safety or operational efficiency.Substantiation: We are constantly trying to protect tax payer’s dollars and strive to provide the most cost effective fire service possible, always doing a cost benefit analysis on projects and equipment that we propose for funding. We do not compromise firefighter safety but are willing to forgo unnecessary features on equipment that do not positively affect its use, longevity or safety. We simply do not feel that interoperability of air bottles is something that is necessary. Firefighter safety is something that cannot be compromised but can, we think be better addressed in this case through more or improved training and operational procedures than by being forced to purchase SCBA has interoperable bottles. We strongly support ongoing product improvements and firefighter safety but are far from convinced that the proposed changes to NFPA 1981, �00� are necessary and are, at best, marginal improvements to existing SCBA.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-�� Log #��4 FAE-RPE Final Action: Accept in Principle(Entire Document)____________________________________________________________Submitter: Eric Kramer, Third District Volunteer Fire DepartmentComment on Proposal No: 1981-�Recommendation: Interchangeability requirements to be deleted from proposed NFPA 1981.Substantiation: The proposed requirements would not offer any significant increase in firefighter safety. In my opinion, it could ultimately decrease firefighter safety by allowing a firefighter endless quick reentry beyond the standard one or two spare bottles. At least now, a firefighter is limited by the time it takes to refill a bottle or change complete packs beyond the spare bottle. I operated in Jefferson Parish, Louisiana before, during and after Hurricane Katrina and observed no problems between agencies on the multiple incidents we encountered. This seems to be a needless and costly change. Planning and communication are much more vital and efficient areas of focus.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-�4 Log #�4� FAE-RPE Final Action: Reject(Entire Document)____________________________________________________________Submitter: Gordon Jopling, Township of Smith Ennismore & LakefieldComment on Proposal No: 1981-�Recommendation: None given.Substantiation: Cylinder Interchangeability - explain the logistics in changing pre �007 and new cylinders - SCBA non changeability associates costs to comply. Purchase either CBRN or non CBRN - not all departments have this need. Use of common sense from Technical Committee. Huge investment for all North America.Committee Meeting Action: RejectCommittee Statement: No recommendation was made by the submitter; however the submitter should see Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-�5 Log #�4� FAE-RPE Final Action: Reject(Entire Document)____________________________________________________________Submitter: William Brandes, Creve Coeur Fire Protection DistrictComment on Proposal No: 1981-�Recommendation: None given.Substantiation: Oppose NFPA 1981 in its entirety, with the exception of a standardized RIT connection.Committee Meeting Action: RejectCommittee Statement: The submitter made no recommendation. The submitter should see Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-�6 Log #�45 FAE-RPE Final Action: Hold(Entire Document)____________________________________________________________Submitter: Roger Donnellan, Waynesville, NCComment on Proposal No: 1981-�Recommendation: Every new SCBA purchased has a RIT fitting at the cylinder valve. This RIT fitting is universal on all new SCBA no matter the manufacturer. The new NFPA update on SCBA proposed enhanced communications and CBRN, both of these proposed upgrades are long overdue. You should also include a self rescue on SCBA’s harness, when all other avenues are closed. I suggest removal of all �,�00 psi and �,000 psi SCBA’s cylinders and upgrade to 4,500 psi 1,�00, 1800 and �400 liters. All cylinder valve outlets should be on the same side.Substantiation: I disagree that there will be no more innovations on SCBA’s.Committee Meeting Action: HoldCommittee Statement: The Comment has proposed complex or significant changes that would cause the Committee to restudy the related issues to be sure that all effected text is reasonably and responsibly investigated and addressed. These can not be accommodated within the compressed time frame the Committee has to process the comments for the ROC.

____________________________________________________________1981-�7 Log #�46 FAE-RPE Final Action: Reject(Entire Document)____________________________________________________________Submitter: J. Glenn Gagel, Louisville Fire DepartmentComment on Proposal No: 1981-�Recommendation: None given.Substantiation: Due to 1050 ��16 PSI and 50 4500 PSI Scott-Pak cylinders, this proposed standard could cause serious financial problem. The LFD through grants and capitals has purchased �00 new carbon cylinders for the pak-50’s. The surrounding county departments have MSA, Drager, ISI and Survive-Air paks. Cylinder interchangeability in no way had or will effect LFD or the county departments’ ability to handle situation that both of us respond to.Committee Meeting Action: RejectCommittee Statement: The submitter did not provide any recommendation for the committee to consider. The submitter should see Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-�8 Log #�47 FAE-RPE Final Action: Reject(Entire Document)____________________________________________________________Submitter: J. Glenn Gagel, Louisville Fire DepartmentComment on Proposal No: 198�-�Recommendation: None given.Substantiation: The LFD and the county departments has ample supply of spare cylinders and mobile supply cylinder refill equipment to maintain safe and reliable supply. Due to a NFPA standard air valve thread, all departments use through NOISH and DOT standards this type of valve.Committee Meeting Action: RejectCommittee Statement: The submitter did not provide any recommendation for the committee to consider. The submitter should see Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-�9 Log #�� FAE-RPE Final Action: Accept in Principle(Entire Document)____________________________________________________________Submitter: Technical Correlating Committee on Fire and Emergency Services Protective Clothing and EquipmentComment on Proposal No: 1981-�Recommendation: TCC NOTE 1: The TCC directs the TC to review requirements to determine if sufficient direction is provided for SCBA that could be supplied with multiple breathing air cylinders. Where such a design is used, the TC should require that only a single cylinder valve can be used rather than separate cylinder valves for each cylinder used.

TCC NOTE 2: The TCC directs the TC to review 6.1.5 and 6.5.5 and confirm that the requirements for the pressure gauge are best handled as a design requirement, evaluated by the certification organization, rather than by a referenced test method that could be subjective and not conducive to repeatable and accurate test results.

TCC NOTE 3: The TCC directs the TC to consider using the same mannequin protective cover as specified in NFPA 198� ROP as the protective cover for the test mannequin in NFPA 1981. The requirements from NFPA 198� for the mannequin protective cover follow:

8.X.X.X Both the calibration mannequin specified in 8.1�.4.1 and the heat and flame test mannequin specified in 8.1�.4.� shall have protective coverings.

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Report on Comments F2006 — Copyright, NFPA NFPA 19818.X.X.X.1 The protective coverings shall be a weld blanket made of

fireproof silica cloth of a minimum weight of 18 oz/sq yard. 8.X.X.X.2 The protective coverings shall be designed and constructed

to provide coverage over the surface of the mannequins.8.X.X.X.3 Where additional insulation is needed to protect the

mannequin electronics, an additional thermal liner underlayer shall be permitted.

8.X.X.X The complete protective covering shall be discarded and shall not be used where the damage to any portion indicates the covering can no longer provide thermal protection for the test mannequin.Substantiation: TCC Substantiation 1: The TCC is concerned that where SCBA are designed to use multiple breathing air cylinders with multiple cylinder valves rather than a single valve controlling the breathing air supply from all cylinders, the likely chance that the SCBA users can become confused with which valves are open/closed can result in injury or death of that user. A recent experience with such configurations has caused the death of a fire fighter and such designs incorporating multiple cylinders with multiple cylinder valves need to be avoided.TCC Substantiation 2: The TCC is seeking continuity test methods and a proposed test for reading the gauge would be a loose method that does not provide for accurate repeatability. The TCC feels this is more appropriate handled as a design requirement.TCC Substantiation 3: The TCC is seeking consistency in testing requirements. This same test is also in NFPA 198� ROP (this cycle) and is specifying a different mannequin protective cover, revised since the previous edition of NFPA 198�, than NFPA 1981. Both documents should specify the same protective cover.Committee Meeting Action: Accept in Principle 1. Accept in Principle. See Committee Comment 1981-76 (Log #CC1). �. Accept in Principle. See committee action on Comment 1981-9� (Log #7�). �. Accept in Principle. See committee action on Comment 1981-�10 (Log #184).Committee Statement: The committee addressed all three of the TCC’s concerns.

____________________________________________________________1981-�0 Log #�8 FAE-RPE Final Action: Accept(Entire Document)____________________________________________________________Submitter: Greg Wyant, Noblesville Fire DepartmentComment on Proposal No: 1981-�Recommendation: The Noblesville Fire Department does not support the proposed revision to NFPA 1981 (�007) that requires interoperability of SCBA cylinders. The NFD recommendation is to abandon the current proposal.Substantiation: There is no tangible benefit to the Noblesville Fire Department or the other departments in this county. The cost of such an endeavor would be overwhelming to the point that it would divert funds from firefighter safety. This diversion would place those funds into a program with conspicuously less benefit to the majority. Mandatory interoperability would force the SCBA/Cylinder manufacturers to focus so much effort, in the form of research and development, on interoperability conformity that they would be forced to neglect other more important research and development issues. Interoperability of SCBA/Cylinders is not listed on this departments risk management plan as an identified area of concern.Committee Meeting Action: AcceptCommittee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-�1 Log #�1 FAE-RPE Final Action: Hold(Entire Document)____________________________________________________________Submitter: Tom May, Rochester, NYComment on Proposal No: 1981-�Recommendation: I would like to comment on the SCBA Standard 1981. The heads up display is a good idea to remind wearers of their air supply, but I have found problems. In very dark conditions the bright lights opposes one’s night vision. While searching for both life and fire I find the heads up display very distracting, and I feel more blind than usual. My suggestion is to try using all red lights to allow better night vision, or just one red light that comes on at 1/� the bottles capacity.Substantiation: The current heads up display could cause as many problems as it solves. I can imagine that some one could miss the signs of rollover, or miss finding a fire when the glow of a fire is not seen due to that blinding green light in one’s face. I have heard the same comments from other firefighters, but no one seems to know how to make changes. I assume this is a start. I have also heard that NFPA codes are mainly developed by industry and those who do not use the firefighting equipment. I hope that the firefighters who use the equipment are listened to.Committee Meeting Action: Hold

Committee Statement: The Comment has proposed complex or significant changes that would cause the Committee to restudy the related issues to be sure that all effected text is reasonably and responsibly investigated and addressed. These can not be accommodated within the compressed time frame the Committee has to process the comments for the ROC.

____________________________________________________________1981-�� Log #�� FAE-RPE Final Action: Accept in Principle in Part(Entire Document)____________________________________________________________Submitter: Brett Merritt, Rockwall Fire DepartmentComment on Proposal No: 1981-�Recommendation: I would recommend that no change be made to the current NFPA 1981. The change to total interoperability as proposed would be disastrous to small departments such as ours. As with all other departments this would be too costly for us to undertake all at one time and would create difficulties for us when purchasing new equipment. Even as a small department we strive to be compliant with NFPA, but with a change such as this, it would make it almost impossible to remain compliant. Substantiation: If the committee follows through with the proposals, they must make sure the funds are available to all departments, large and small to be able to make the necessary upgrades to be compliant with the new rules. If now funds are going to be made available, then no changes should be made. Committee Meeting Action: Accept in Principle in Part 1. Reject that no changes be made to the current NFPA 1981. �. Accept in Principle the issues regarding interchangeability of SCBA cylinders.Committee Statement: 1. The committee has made other changes to NFPA 1981 that enhance user safety. �. See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-�� Log #5 FAE-RPE Final Action: Hold(Entire Document)____________________________________________________________Submitter: Tom Kissner, Smithsburg, MDComment on Proposal No: 1981-1Recommendation: Instead of changing the cylinders, why don’t you just change the bracket that holds the cylinder? Make all of the manufactures can to a ratchet type assembly. Have NIOSH and OSHA lift there cylinder requirement by the same manufacture to gain there certification for use.Substantiation: Agree, but with changes.Committee Meeting Action: HoldCommittee Statement: The Comment has proposed complex or significant changes that would cause the Committee to restudy the related issues to be sure that all effected text is reasonably and responsibly investigated and addressed. These can not be accommodated within the compressed time frame the Committee has to process the comments for the ROC.

____________________________________________________________1981-�4 Log #75 FAE-RPE Final Action: Accept(Entire Document)____________________________________________________________TCC Action: The Technical Correlating Committee ACCEPTS Item #2 of this comment. The TCC carefully reviewed the issues regarding the CBRN requirements being deleted from the proposed 2008 edition of NFPA 1981, including those expressed in the negative ballots on this issue, and the verbal positions heard from TC and TCC members. In accordance with the Regulations Governing Committee Projects (RGCPs), the TCC is taking the action it deems necessary in accordance with its authority as defined in 3.4.2, and in 4.4.7.1: “…The TCC shall be permitted to choose between alternatives presented by the TCs or develop text, as it deems necessary, to achieve correlation, consistence, and the correction of errors and omissions...” The TCC was concerned that some TC members expressed the opinion that while they did see a need for CBRN SCBA in their organization, they didn’t believe that it was necessary throughout the country and that individual departments should make their own determination, and another opinion was that it would be wrong to make other departments pay so much more for their SCBA when they don’t foresee a need for them. There is no way that anyone can predict where a future CBRN event will occur in this country. The terrorist threat is a reality not only in larger metropolitan areas but also in smaller communities and rural areas where terrorists would seek to severely affect the economy or bring it to a halt. While we can and should prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. In the Committee process, all members come to the table with a bias and represent their sponsoring organization’s

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Report on Comments F2006 — Copyright, NFPA NFPA 1981feelings, but the safety, well being, and protection of the emergency responders must be the goal and local issues should take a secondary position to the improvement of safety for the emergency responders performing in the hazardous environments. In regards to cost, some TC members argued the point that municipalities should have a choice in what SCBA they purchase. In opposition to this stance, one TC member (King) stated, “There is no way that anyone can predict where a future CBRN event will occur in this country. While we can (and should) prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. It is interesting to note that a couple of the first responders who voted against having mandatory CBRN compliant SCBA in this standard acknowledge that their own department insists on CBRN compliant SCBA when purchasing new equipment.” Another TC member (Rossos) stated, “I disagree with the committee’s action regarding CBRN; therefore I must vote in the negative. I believe it is our purpose and responsibility as members of the Committee to strive to design SCBA standards and codes where the end user has the highest level of protection possible. I realize as an end user, that we need to strike a balance between best protection and secondary effects such as comfort, size, weight, etc. and in some regards even economics. We were given no evidence of any of the above compromises to mandating CBRN on all SCBAs. The only thing that we know for sure is that the end user would have a higher level of protection with CBRN as opposed to without. Very few end users have a choice in this matter. Most choices are made by purchasing agents or administrators who often base their decisions on the minimum legal standard available for the lowest price. I believe our first and most important responsibility on this committee is to those who wear SCBA, not to who buys SCBA. Regretfully, when there was no cost involved or reduction in protection, we voted to give the choice to the buyer and not the user.” This was based on the fact that all SCBA manufacturers present at the TC ROC meeting stated that the increased cost of CBRN protection for SCBA was negligible (under $100) or none. Also, TC Chairman Reed responded, “The argument during ROC was that many parts of the country may not have a need for CBRN protection. Unfortunately, in the post 9/11 world, I think this is being unrealistic. While major metropolitan areas may be more likely targets of a terrorist event, we have already seen that the terrorists themselves may reside in small communities while they await their opportunity to strike. They may have the chemical, biological, or nuclear material in their possession, making the possibility of exposure greater for even small, rural areas. But terrorist attacks aside, CBRN-certified SCBA offers greater protection for the fire fighter for a very minimal cost. If this protection is not required by the standard, many jurisdictions will not specify this for their fire fighters.” To the issue about CBRN compliant SCBA are uncomfortable to wear, this appears to be limited to one or two manufacturers’ chosen materials and the reality appears to be that first responders using CBRN SCBA are not reporting any significant difference relating to the comfort of the equipment and other manufacturers report no complaints from organizations who have purchased and use CBRN SCBA. And to the issue of CBRN compliant SCBA will not be as durable, there appears to be no reason to believe that CBRN compliant SCBA are any less durable than the non-CBRN compliant products on the market today and NIOSH has not received any complaints or identified any durability problems of CBRN SCBA over “regular” SCBA. To the issue of correlation and consistence, the TCC notes that other standards do require CBRN SCBA including NFPA 1500, Standard on Fire Department Occupational Safety and Health Program, 7.11.1.1 of the 2007 edition; 42 CFR 84, Respiratory Protective Devices, and the Statement of Standard for NIOSH CBRN SCBA Testing; and Section 5(A)(1) of the Occupational Safety and Health Act. The TCC believes that lack of correlation with these standards and regulations causes a strong potential decrease of safety for emergency responders due to purchasers believing that as NFPA 1981 is silent on CBRN requirements they do not to have that protection. The TCC further notes that the Department of Homeland Security (DHS) has formally adopted the NIOSH Statement of Standard for NIOSH CBRN SCBA Testing as one of the standards for first responder PPE. Only SCBA that have been approved by NIOSH as CBRN SCBA, which also requires certification to NFPA 1981, can be listed in the Authorized Equipment List (AEL), established by the DHS Office of Grants and Training as the list of recommended equipment for emergency responders. Purchase of SCBA with federal monies through several of the government grant programs requires that SCBA have CBRN approvals from NIOSH. In addition, the InterAgency Board for Equipment Standardization and Interoperability (the IAB) has established CBRN SCBA as the only qualified SCBA in its Standardized Equipment List (SEL). This SEL further provides detailed recommendations for first responder PPE.

While NFPA 1500 provides requirements for fire departments, it does not provide requirements for non-fire based emergency responders. NFPA 1981, Standard for Open-Circuit Self-Contained Breathing Apparatus for Emergency Services, does provide SCBA requirements for any emergency services organization that needs protection from IDLH atmospheres. IDLH protection can only be provided by SCBA. The shortsightedness of the TC in removing the CBRN requirement leaves law enforcement responders, emergency medical responders, non-fire based hazardous materials response teams, and the skilled trades emergency responders without CBRN respiratory protection. CBRN protection offers verification of enhanced protection for emergency responders which is not otherwise available. Without CBRN protection evaluation, no SCBA components are tested for permeation, penetration, corrosion resistance, or other detrimental effects from exposure to hazardous chemical warfare atmospheres. NIOSH benchmark testing of non-CBRN hardened NIOSH certified SCBA against CBRN agents demonstrated that CWA agents could cause catastrophic failures within minutes of exposure. A comment by a TC member (Birch) stated, “…it is proper at this point in time to not require CBRN is because although NIOSH and other agencies make/made a good point of testing SCBAs against the list of chemical agents, there are missing tests. There are no tests to show that SCBAs as manufactured now, when altered to meet CBRN requirements, are still resistant to the ‘normal’ atmospheres and chemical agents in which they are currently used.” NIOSH (Boord) countered with, “The selection of the test challenge agents for CBRN protection was based on a comprehensive review of available technical data and consultations with other government agencies (e.g., DOD, DOJ, DOE, etc.). Various chemical data lists were analyzed, including lists from the EPA, ATSDR, NFPA 1994, U.S. Army Center for Health Promotion and Preventative Medicine (USACHPPM) Technical Guide 244, and classified sources. This review established a total of 151 toxic industrial chemicals and chemical warfare agents (TIC-CWA) as potential candidates for challenge agents. The candidate agents were evaluated for permeation (molecularly diffusing through material) and penetration (seeping through interfacing components) characteristics as part of a review of their physical properties.” “This evaluation concluded that Sarin (GB) and Sulfur Mustard (HD) could be selected as the two representative agents for the penetration/permeation test for the complete listing of 151 CWA and TICs due to their physical properties and molecular structure.” “NIOSH is unaware of any data that indicates the CBRN respirators provide less protection against TICs than their industrial counterparts. The evaluation for CBRN protection provides verification and assurance that the component and material combinations in the approved SCBA configurations provide high resistance to permeation and penetration of hazardous atmospheres of toxic industrial chemicals and materials into the breathing air. This is of importance to all responders subject to extreme exposures to any hazardous industrial chemicals and materials.” The TCC, acting in accordance with 3.4.3(g) of the RGCPs, “Determining whether or not the TC has given due consideration to all evidence presented to it in connection with the preparation of its Report including all comments relating to negative votes” does not believe the TC gave full and appropriate review and due consideration to all the issues and, therefore has taken these actions. In addition to the action taken on 1981-59, the following comments will be affected by this change and, therefore, the following changes must be made to these comments 1981-34 In action #2, change action from “Reject” to “Accept” 1981-50 Change action from “Accept in Principle” to “Reject” 1981-51 Change action from “Accept in Principle” to “Reject” 1981-52 Change action from “Accept in Principle” to “Reject” 1981-53 Change action from “Accept in Principle” to “Reject” 1981-54 Change action from “Accept in Principle” to “Reject” 1981-55 Change action from “Accept in Principle” to “Reject” 1981-56 Change action from “Reject” to “Accept” 1981-57 Change action from “Accept in Principle” to “Reject” 1981-58 Change action from “Accept in Principle” to “Reject” 1981-84 Change action from “Accept in Principle” to “Reject” 1981-85 Change action from “Accept in Principle” to “Reject” 1981-86 Change action from “Accept in Principle” to “Reject” 1981-87 Change action from “Accept in Principle” to “Reject”Comment 1981-59 (Log #162).Submitter: Scott Sutter, North Lake Tahoe FireComment on Proposal No: 1981-�Recommendation: 1. We support interoperability of cylinders - Please do it! �. CBRN approval - yes but crucial to streamline NIOSH/NFPA/CBRN certification process for manufacturers. �. Communication requirement to 15 feet - good change but not if when electronics fail, communications are worse than before. This is the case with our current equipment, one battery.

1981-1�

Report on Comments F2006 — Copyright, NFPA NFPA 1981Substantiation: In voice amplifier fails (often), then fire fighter is totally inaudible because speech diaphragm was replaced by a microphone. An engineering issue but good goal for standards.Committee Meeting Action: Accept in Principle in Part 1. Reject. �. Reject. �. Accept in Principle. See Committee Comment 1981-8� (Log #CC�) and 1981-176 (Log #CC�).Committee Statement: 1. See Committee Comment 1981-76 (Log #CC1). �. See committee action on Comment 1981-181 (Log #16�). �. See Committee Comment 1981-8� (Log #CC�) and 1981-176 (Log #CC�).

____________________________________________________________1981-�5 Log #76 FAE-RPE Final Action: Accept in Principle(Entire Document)____________________________________________________________Submitter: D Carruthers, Clearview Fire DepartmentComment on Proposal No: 1981-�Recommendation: NFPA 1981-�00� included significant changes which are creating logistical and financial burdens on all municipalities, especially smaller, volunteer departments.Substantiation: With over 100 cylinders in use at this time, the replacement with interchangeable cylinders would take a period of at least 5 more years, during which time we would be risking using the wrong cylinder with the correct SCBA.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-�6 Log #�18 FAE-RPE Final Action: Accept(1.1.1)____________________________________________________________Submitter: Les Boord, NIOSHComment on Proposal No: 1981-�Recommendation: Revise bullet 1.1.1 This standard shall specify the minimum requirements for the design, performance, testing and certification of compressed breathing air open-circuit self-contained breathing apparatus (SCBA) and compressed breathing air combination open-circuit self-contained breathing apparatus and supplied air respirators (SCBA/SAR) for emergency services personnel.Substantiation: Modify text in bullet 1.1.1.Committee Meeting Action: AcceptCommittee Statement: The action on this comment modifies the text accepted in Comment 1981-�7 (Log #1�5).

____________________________________________________________1981-�7 Log #1�5 FAE-RPE Final Action: Accept(1.1.1, 1.1.2, 1.3.2, 4.1.10, and 4.2.8)____________________________________________________________Submitter: Stephen R. Sanders, Safety Equipment Institute (SEI)Comment on Proposal No: 1981-�Recommendation: Revise text to read:

1.1.1 This standard shall specify the minimum requirements for the design, performance, testing, and certification of new open-circuit self-contained breathing apparatus (SCBA) and combination open-circuit self-contained breathing apparatus and supplied air respirators (SCBA/SAR), and for the replacement parts, components, and accessories for these respirators.

1.1.2 This standard shall also specify the minimum requirements for the design, performance, testing, and certification of replacement parts, components, and add-on accessories for SCBA and combination SCBA/SARs certified as compliant to specific earlier editions of this standard.

1.3.2 This standard shall apply to the design, manufacturing, and certification of new open-circuit SCBA and combination SCBA/SARs, and shall apply to replacement parts, components, and add-on accessories for such respirators certified as compliant to specific earlier editions of this standard.

4.1.10 The certification organization shall not issue any new certifications for any SCBA to the �00� edition of this standard on or after the NFPA effective dated for the �007 edition which is XX February �007.

4.2.8 The certification organization and the manufacturer shall evaluate any changes affecting the form, fit, or function of compliant product to determine its continued certification to this �007 edition of NFPA 1981.

4.2.8.1 The certification organization and the manufacturer shall evaluate replacement parts, components, and add-on accessories to determine any changes affecting the form, fit, or function for SCBA certified to the 1997 edition or the �00� edition of NFPA 1981 to permit revisions to the original certification.

4.2.8.2 Replacement parts, components, and add-on accessories for SCBAs certified to the 1997 edition or the �00� edition of NFPA 1981 shall be approved by NIOSH in accordance with 4� CFR 84.

Substantiation: Following a discussion held during the TC’s Jacksonville, FL meeting, the need for having a mechanism which allows certification organization(s) the ability to verify changes/revisions/additions to SCBA certified to previous editions of NFPA 1981 was identified. The revisions/additions in this comment serve to allow certification organization(s) to verify changes made by SCBA manufacturers to SCBA certified to previous editions (1997 edition and �00� edition) of NFPA 1981.Committee Meeting Action: Accept

____________________________________________________________1981-�8 Log #58 FAE-RPE Final Action: Accept(1.1.7)____________________________________________________________Submitter: Karen Lehtonen, Lion ApparelComment on Proposal No: 1981-�Recommendation: Revise text to read: This standard shall not be construed as addressing all of the safety concerns associated with the use of compliant protective ensembles or elements SCBA. It shall be the responsibility of the persons and organizations that use compliant protective ensembles or elements SCBA to establish safety and health practices and determine the applicability of regulatory limitations prior to use.Substantiation: Editorial revisions to reflect product covered by this standard.Committee Meeting Action: Accept

____________________________________________________________1981-�9 Log #117 FAE-RPE Final Action: Accept(1.1.7 and 1.1.8)____________________________________________________________Submitter: Stephen R. Sanders, Safety Equipment Institute (SEI)Comment on Proposal No: 1981-�Recommendation: Revise text to read: 1.1.7 This standard shall not be construed as addressing all of the safety concerns associated with the use of compliant protective ensemble or elements SCBA. It shall be the responsibility of the persons and organizations that use compliant protective ensembles or elements SCBA to establish safety and health practices and determine the applicability of regulatory limitations prior to use. 1.1.8 This standard shall not be construed as addressing all of the safety concerns, if any, associated with the use of this standard by testing facilities. It shall be the responsibility of the persons and organizations that use this standard to conduct testing of protective ensembles or elements SCBA to establish safety and health practices and determine the applicability of regulatory limitations prior to using this standard for any designing, manufacturing and testing.Substantiation: Reference(s) to “protective ensembles or elements” is incorrect for this standard.Committee Meeting Action: Accept

____________________________________________________________1981-40 Log #59 FAE-RPE Final Action: Accept(1.3.2)____________________________________________________________Submitter: Karen Lehtonen, Lion ApparelComment on Proposal No: 1981-�Recommendation: Revise text to read: This standard shall apply to the design, manufacturing, and certification of new open-circuit SCBA and combination SCBA/SAR’s.Substantiation: Add SCBA/SAR’s to this paragraph for consistency with 1.�.1.Committee Meeting Action: Accept

____________________________________________________________1981-41 Log #60 FAE-RPE Final Action: Accept(Chapter 2)____________________________________________________________Submitter: Karen Lehtonen, Lion ApparelComment on Proposal No: 1981-�Recommendation: Update the following standards editions and titles in Chapter �: �.� NFPA Publications. NFPA 1500, Standard on Fire Department Occupational Safety and Health Program, �00� �007 edition. NFPA 1971, Standard on Protective Ensemble for Structural Fire Fighting and Proximity Fire Fighting, �000 �007 edition. �.�.1 AATCC Publications. AATCC 1�5, Dimensional Changes in Automatic of Fabrics After Home Laundering of Woven and Knit Fabrics, 1995 �004. �.�.� ANSI Publications. ANSI/UL 91�, Standard for Intrinsically Safe Apparatus and Associated Apparatus for Use in Class I, II, and III, Division 1 Hazardous Locations, Sixth Edition, 1997 �00�.

1981-14

Report on Comments F2006 — Copyright, NFPA NFPA 1981 �.�.� ASTM Publications. ASTM B 117, Standard Test Method for Salt Spray (Fog) Testing, 1985 �00�. ASTM D 100�, Standard Test Method for Haze and Luminous Transmittance of Transparent Plastics, 1988 �000. �.�.5 ISO Publications. ISO 6�, General Requirements for Bodies Operating Assessment and Certification/Registration of Quality Systems, 1996. ISO/IEC 170�5, General Requirements for the Competence of Testing and Calibration Laboratories, 1999 �005. ISO/IEC 17011, Conformity Assessment – General Requirements for Accreditation Bodies Accrediting Conformity Assessment Bodies, �004.Substantiation: Several standards have more recent revisions and title changes. Also there are additional standard that should be included on this list.Committee Meeting Action: AcceptCommittee Statement: See also committee action on Comment 1981-4� (Log #118).

____________________________________________________________1981-4� Log #118 FAE-RPE Final Action: Accept(2.3.1, 2.3.2, 2.3.3, and 2.3.5)____________________________________________________________Submitter: Stephen R. Sanders, Safety Equipment Institute (SEI)Comment on Proposal No: 1981-�Recommendation: Revise text to read: 2.3.1 AATCC Publication. American Association of Textile Chemists and Colorists, P.O. Box 1��15, Research Triangle Park, NC �7709. AATCC 1�5, Dimensional Changes in Automatic Home Laundering of Woven and Knit Fabrics, 1995 �001. 2.3.2 ANSI Publications. American National Standards Institute, 11 West 4�nd Street, 1�th floor, New York, NY 100�6. ANSI/UL 91�, Standard for Intrinsically Safe Apparatus and Associated Apparatus for Use in Class I, II and III, Division I Hazardous Locations, 1997 �00�. 2.3.3 ASTM Publications. American Society for Testing and Materials, 100 Barr Harbor Drive, West Conshohocken, PA 194�8-�959. ASTM B 117, Standard Test Method for Salt Spray (Fog) Testing, 1985 �00�. ASTM D100�, Standard Test Method for Haze and Luminous Transmittance of Transparent Plastics, 1988 �000. 2.3.5 ISO Publications. International Organization for Standardization, 1, rue de Varembe, Case postale 56, CH-1�11 Geneve �0, Switzerland. ISO/IEC Guide �7, Guidelines for corrective action to be taken by a certification body in the event of misuse of its mark of conformity, 198�. ISO/IEC 170�5, General requirements for the competence of testing and calibration laboratories, 1999 �005. ISO/IEC 17011, Conformity Assessment – General Requirements for Accreditation Bodies Accrediting Conformity Assessment Bodies, �004.Substantiation: Reference(s) have been updated accordingly.Committee Meeting Action: AcceptCommittee Statement: Some of these duplicate reference in Comment 1981-41 (Log #60).

____________________________________________________________1981-4� Log #40 FAE-RPE Final Action: Accept in Principle(2.3.5)____________________________________________________________Submitter: Robert Sell, Draeger Safety, Inc.Comment on Proposal No: 1981-�Recommendation: Add the following text: ISO/IEC 17011, General requirements for accreditation bodies accrediting conformity assessment bodies, �005.Substantiation: This document is referenced in 4.�.� and including the reference in the appropriate section would remain consistent with document format.Committee Meeting Action: Accept in Principle See committee action on Comment 1981-41 (Log #60).Committee Statement: See committee action on Comment 1981-41 (Log #60).

____________________________________________________________1981-44 Log #119 FAE-RPE Final Action: Accept in Principle(Chapter 3 General Definitions)____________________________________________________________Submitter: Stephen R. Sanders, Safety Equipment Institute (SEI)Comment on Proposal No: 1981-�Recommendation: Revise the following definitions to read:

3.3.1 Accessory. An item, or items, that are could be attached to the a certified product, that but are not necessary for the certified product to meet the requirements of the standard.

3.3.10 Closed-Circuit SCBA. A recirculation-type re-circulation-type SCBA in which the exhaled gas is rebreathed re-breathed by the wearer after the carbon dioxide has been removed from the exhalation gas and the oxygen content within the system has been restored from sources

such as compressed breathing air, chemical oxygen, and liquid oxygen, or compressed gaseous oxygen.

3.3.11* Combination SCBA/SAR. An atmosphere-supplying respirator that supplies a respirable atmosphere to the user from a combination of two breathing air sources that are both are independent of the ambient environment. and consists of (1) a compliant open-circuit SCBA having a minimum rated service time of �0 minutes and (�) having a connection for the attachment of an air line that would provide a continuous supply of breathing air independent of the SCBA breathing air supply. (See also 3.3.2 the definitions for: Atmosphere-Supplying Respirator 3.3.41, Self-Contained Breathing Apparatus and 3.3.44, Supplied Air Respirator.)

A.3.3.11 Combination SCBA/SAR. Combination SCBA/SAR consist of (1) an SCBA certified as compliant with NFPA 1981, Standard on Open-Circuit Self-Contained Breathing Apparatus, and having a minimum rated service life of �0 minutes, and (�) having a connection for the attachment of an air line that provides a continuous supply of breathing air that is independent of the SCBA breathing air supply. This The definition does not include SARs that are used in conjunction with an escape self-contained breathing apparatus (ESCBA) where the ESCBA provides less than a minimum rated service time life of �0 minutes. For the purpose of this standard, combination SCBA/SARs are encompassed by the terms “self-contained breathing apparatus” and “SCBA”.

3.3.13 Component. Any material, part, or subassembly providing the required protection that is used in the construction of the SCBA of the compliant product.

3.3.14* Compressed Breathing Air. Oxygen or a respirable gas mixture stored in a compressed state and supplied to the user in gaseous form. A respirable gas mixture derived from either normal atmospheric air or from manufactured synthetic air, stored in a compressed state in storage cylinders and respirator breathing air cylinders, and supplied to the user in gaseous form.

3.3.18 End-of-Service Time Indicator (EOSTI). A warning device on an SCBA that warns the user that the end of the service time breathing air supply of the SCBA is approaching.

3.3.21 Follow-up Program. The sampling, inspections, tests, or other measures conducted by the certification organization on a periodic basis to determine the continued compliance of labeled and listed products that are being produced by the manufacturer to the requirements of this standard.

3.3.22 Gas. An aeriform fluid that is Matter in a gaseous state at standard temperature and pressure.

3.3.24 Heads Up Display (HUD). Visual display of information and system condition status visible to the SCBA wearer.

3.3.29 Negative Pressure SCBA. An SCBA in which the pressure inside the facepiece, in relation to the pressure surrounding the outside of the facepiece, is negative less than the pressure surrounding the outside of the facepiece during any part of the inhalation or exhalation cycle when tested by NIOSH in accordance with 4� CFR 84, Subpart H.

3.3.30* NIOSH Certified. Tested and certified by the National Institute for Occupational Safety and Health (NIOSH) of the U.S. Department of Health and Human Services in accordance with the requirements of Title 4�, Code of Federal Regulations, Part 84, Subpart H (4� CFR 84). (See also 3.3.7, Certification/Certified.)

3.3.31 Open-Circuit SCBA. An SCBA in which exhalation is vented to the atmosphere and not rebreathed. There are two types of open-circuit SCBA: negative pressure or demand type, and positive pressure or pressure demand type.

3.3.33 Positive Pressure SCBA. An SCBA in which the pressure inside the facepiece, in relation to the pressure surrounding the outside of the facepiece, is positive greater than or equal to the pressure surrounding the outside of the facepiece during both inhalation and exhalation when tested by NIOSH in accordance with 4� CFR 84, Subpart H.

3.3.35* Product Label. A label or marking affixed to the SCBA by the manufacturer containing general information, care, maintenance, or similar data. (See also 3.3.2, Labeled.) A marking provided by the manufacturer for each compliant product containing compliant statements, certification statements, manufacturer and model information, or similar data. The product label is not the certification organization’s label, symbol, or identifying mark; however, the certification organization’s label, symbol, or identifying mark is attached to or part of the product label.

3.3.37 Rated Service Time. The period of time, stated on the SCBA’s NIOSH certification label, that the SCBA supplied air to the breathing machine when tested when tested by NIOSH in accordance with 4� CFR 84, Subpart H.

3.3.38 RIC. An Abbreviation for rapid intervention crew/company “Rapid Intervention Crew/Company”.

3.3.40 SCBA. An abbreviation for self-contained breathing apparatus. For the purposes of this standard, where this abbreviation is used without any qualifier, it indicates only open-circuit self-contained breathing apparatus and combination SCBA/SARs. (See 3.3.11, Combination SCBA/SAR, and 3.3.41, also the definition for Self-Contained Breathing Apparatus.)

3.3.42* Self-Contained Breathing Apparatus (SCBA). An atmosphere-supplying respirator that supplies a respirable air atmosphere to the user from a breathing air source that is independent of the ambient environment and designed to be carried by the user. For the purposes of

1981-15

Report on Comments F2006 — Copyright, NFPA NFPA 1981this standard, where this term is used without any qualifier, it indicates only open-circuit self-contained breathing apparatus or combination SCBA/SARs. For the purposes of this standard, combination SCBA/SARs are encompassed by the terms self-contained breathing apparatus or SCBA. (See also 3.3.2, Atmosphere-Supplying Respirator; 3.3.11, Combination SCBA/SAR; and 3.3.44, Supplied Air Respirator.)

A.3.3.42 Self-Contained Breathing Apparatus (SCBA). For the purposes of this standard, where the term is used without any qualifier, it indicates only open-circuit self-contained breathing apparatus or combination SCBA/SARs. For the purposes of this standard, combination SCBA/SAR are encompassed by the terms self-contained breathing apparatus or SCBA. See also the definitions for: Atmosphere-Supplying Respirator, Combination SCBA/SAR, and Supplied Air Respirator.)

3.3.43 Service Life. The period for which a certified compliant product is may be useful before retirement.

3.3.45* Supplied Air Respirator. An atmosphere-supplying respirator for which the source of breathing air is not designed to be carried by the user. Also known as an “airline respirator”. See also the definitions for: Atmosphere-Supplying Respirator, Combination SCBA/SAR, and Self-Contained Breathing Apparatus.

A.3.3.45 Supplied Air Respirator. For the purposes of this standard, combination SCBA/SAR are encompassed by the terms “self-contained breathing apparatus” and “SCBA”.

3.3.46 UAC. An Abbreviation for universal air connection “Universal Air Connection”. Also known as: RIC/UAC. Substantiation: The definitions for all of the terms noted in this comment have been revised to agree with the Project’s definitions for these terms.Committee Meeting Action: Accept in Principle See committee action on Comment 1981-45 (Log #�48).Committee Statement: See committee action on Comment 1981-45 (Log #�48).

____________________________________________________________1981-45 Log #�48 FAE-RPE Final Action: Accept(Chapter 3 General Definitions)____________________________________________________________Submitter: Eric J. Beck, Mine Safety Appliances Co.Comment on Proposal No: 1981-�Recommendation: �.� General Definitions. Replace the existing Section �.�, General Definitions, with the following: �.� General Definitions. �.�.1 Accessory. An item, or items, that could be attached to a certified product, but are not necessary for the certified product to meet the requirements of the standard. �.�.� Atmosphere-Supplying Respirator. A respirator that supplies the respirator user with breathing air from a source independent of the ambient atmosphere and includes self-contained breathing apparatus (SCBA) and supplied air respirators (SAR). (See also �.�.11, Combination SCBA/SAR, �.�.41, Self-Contained Breathing Apparatus, and �.�.44, Supplied Air Respirator.) �.�.� Basic Plane. Deleted (Note to eliminate this definition and move it to Dh 6 or Ch 8.) �.�.4 Breathing Air. See �.�.14, Compressed Breathing Air. �.�.5 Breathing Air Cylinder. The pressure vessel or vessels that are an integral part of the SCBA and that contain the breathing gas supply; can be configured as a single cylinder or other pressure vessel, or as multiple cylinders or pressure vessels. �.�.6 Breathing Air/Gas Container. See �.�.5, Breathing Air Cylinder. �.�.7 Certification/Certified. A system whereby a certification organization determines that a manufacturer has demonstrated the ability to produce a product that complies with the requirements of this standard, authorizes the manufacturer to use a label on listed products that comply with the requirements of this standard, and establishes a follow-up program conducted by the certification organization as a check on the methods the manufacturer uses to determine continued compliance of labeled and listed products with the requirements of this standard. (See also �.�.�9, NIOSH Certified.) �.�.8 Certification Organization. An independent third-party organization that determines product compliance with the requirements of this standard with a labeling/listing/ follow-up program. �.�.9 Char. The formation of a brittle residue when material is exposed to thermal energy. �.�.10 Closed-Circuit SCBA. A recirculation-type SCBA in which the exhaled gas is rebreathed by the wearer after the carbon dioxide has been removed from the exhalation gas and the oxygen content within the system has been restored from sources such as compressed breathing air, chemical oxygen, liquid oxygen, or compressed gaseous oxygen. �.�.11* Combination SCBA/SAR. An atmosphere-supplying respirator that supplies a respirable atmosphere to the user from a combination of two breathing air sources that are both independent of the ambient environment. See also the definitions for: Atmosphere-Supplying Respirator, Self-Contained Breathing Apparatus, and the Supplied Air Respirator.

Annex: Combination SCBA/SAR consist of (1) an SCBA certified as compliant with NFPA 1981, Standard on Open-Circuit Self-Contained Breathing Apparatus, and having a minimum rated service life of �0 minutes; and (�) having a connection for the attachment of an air line that provides a continuous supply of breathing air that is independent of the SCBA breathing air supply. The definition does not include SAR that are used in conjunction with escape self-contained breathing apparatus (ESCBA) where ESCBA provide less than a minimum rated service life of �0 minutes. For the purpose of this standard, combination SCBA/SAR are encompassed by the terms “self-contained breathing apparatus” and “SCBA”. �.�.1� Compliance/Compliant. Meeting or exceeding all applicable requirements of this standard. �.�.1� Component. Any material, part, or subassembly used in the construction of the compliant product. Annex: Components include items required for the design and construction of the product and are evaluated and tested as a part of the whole product. �.�.14* Compressed Breathing Air. A respirable gas mixture derived from either normal atmospheric air or from manufactured synthetic air, stored in a compressed state in storage cylinders and respirator breathing air cylinders, and supplied to the user in a gaseous form. See also definition of: Synthetic Breathing Air. �.�.15 Cylinder. See �.�5, Breathing Air Cylinder. �.�.16 Demand SCBA. See �.�.�8, Negative Pressure SCBA. �.�.17 Drip. To run or fall in drops or blobs. �.�.18 End-of-Service-Time Indicator (EOSTI). A warning device on an SCBA that warns the user that the end of the breathing air supply is approaching. �.�.19 Fabric Component. Any single or combination of natural or synthetic material(s) that are pliable and that are made by weaving, felting, forming, or knitting. �.�.�0 Facepiece. The component of an SCBA that covers the wearer’s nose, mouth, and eyes. �.�.�1 Follow-up Program. The sampling, inspections, tests, or other measures conducted by the certification organization on a periodic basis to determine the continued compliance of labeled and listed products that are being produced by the manufacturer to the requirements of this standard. �.�.�� Gas. Matter in a gaseous state at standard temperature and pressure. �.�.�� Haze. Light that is scattered as a result of passing through a transparent object. �.�.�4 Heads Up Display (HUD). Visual display of information and system condition status visible to the wearer. �.�.�5 Identical SCBA. SCBA that are produced to the same engineering and manufacturing specifications. �.�.�6 Manufacturer. The entity that directs and controls any of the following: compliant product design, compliant product manufacturing, or compliant product quality assurance; or the entity that assumes the liability for the compliant product or provides the warranty for the compliant product. �.�.�7 Melt. A response to heat by a material resulting in evidence of flowing or dripping. �.�.�8 Mid-Sagittal Plane. The plane, perpendicular to the basic and coronal planes, that bisects the head symmetrically. �.�.�9 Negative Pressure SCBA. An SCBA in which the pressure inside the facepiece, in relation to the pressure surrounding the outside of the facepiece, is negative during any part of the inhalation or exhalation cycle when tested by NIOSH in accordance with 4� CFR 84. �.�.�0* NIOSH Certified. Tested and certified by the National Institute for Occupational Safety and Health (NIOSH) of the U.S. Department of Health and Human Services in accordance with the requirements of Title 4�, Code of Federal Regulations, Part 84, Subpart H (4� CFR). �.�.�1 Open-Circuit SCBA. An SCBA in which exhalation is vented to the atmosphere and not rebreathed. �.�.�� Pink Noise. Noise that contains constant energy per octave band. �.�.�� Positive Pressure SCBA. An SCBA in which the pressure inside the facepiece, in relation to the pressure surrounding the outside of the facepiece, is positive during both inhalation and exhalation when tested by NIOSH in accordance with 4� CFR 84, Subpart H. �.�.�4 Pressure Demand SCBA. See �.�.��, Positive Pressure SCBA. �.�.�5* Product Label. A marking provided by the manufacturer for each compliant product containing compliant statements, certification statements, manufacturer and model information, or similar data. The product label is not the certification organization’s label, symbol, or identifying mark; however, the certification organization’s label, symbol, or identifying mark is attached to or part of the product label. �.�.�6 Rapid Intervention Crew/Company Universal Air Connection System (RIC UAC). A system that allows emergency replenishment of breathing air to the SCBA of disabled or entrapped fire or emergency services personnel. �.�.�7 Rated Service Time. The period of time stated on the SCBA’s NIOSH certification label that the SCBA supplied air to the breathing machine when tested to 4� CFR 84, Subpart H.

1981-16

Report on Comments F2006 — Copyright, NFPA NFPA 1981 �.�.�8 RIC. Abbreviation for the term “Rapid Intervention Crew/Company”. �.�.�9 SAR. An abbreviation for supplied air respirator. (See �.�.44, Supplied Air Respirator.) �.�.40 SCBA. An abbreviation for Self-Contained Breathing Apparatus. (See also the definition for Self-Contained Breathing Apparatus.) �.�.41 SCBA/SAR. An abbreviation for combination open-circuit SCBA and supplied air respirator. (See �.�.11, Combination SCBA/SAR, �.�.41, Self-Contained Breathing Apparatus, and �.�.44, Supplied Air Respirator.) �.�.4� Self-Contained Breathing Apparatus (SCBA). An atmosphere-supplying respirator that supplies a respirable air atmosphere to the user from a breathing air source that is independent of the ambient environment and designed to be carried by the user. Annex: For the purposes of this standard, where the term is used without a qualifier, it indicates only open-circuit self-contained breathing apparatus or combination SCBA/SARs. For the purposes of this self-contained breathing apparatus or SCBA. See also the definitions for: Atmosphere-Supplying Respirator, Combination SCBA/SAR, and Supplied Air Respirator. �.�.4� Service Life. The period for which compliant product may be useful before retirement. �.�.44 Service Time. See �.�.�6, Rated Service Time. �.�.45 Supplied Air Respirator. An atmosphere-supplying respirator for which the source of breathing air is not designed to be carried by the user. Also known as an “airline respirator.” See also the definitions for: Atmosphere-Supplying Respirator, Combination SCBA/SAR, and Self-Contained Breathing Apparatus. Annex: For the purposes of this standard, combination SCBA/SAR are encompassed by the terms “self-contained breathing apparatus” and “SCBA”. Add Synthetic Breathing Air. �.�.46 UAC. Abbreviation for the term “Universal Air Connection”. Also known as: RIC/UAC. �.�.47 Universal Air Connection (UAC). The male fitting, affixed to the SCBA, and the female fitting, affixed to the filling hose, to provide emergency replenishment of breathing air to an SCBA breathing air cylinder. Also known as Rapid Intervention Crew/Company Universal Air Connection.Substantiation: The above Section �.� has been revised to be consistent with the latest NFPA Glossary of Terms and TCC project definitions.Committee Meeting Action: AcceptCommittee Statement: Some cross reference numbers corrected by committee action on Comment 1981-1 (Log #69).

____________________________________________________________1981-46 Log #�09 FAE-RPE Final Action: Reject(3.3.5 Breathing Air Cylinder)____________________________________________________________Submitter: Les Boord, NIOSHComment on Proposal No: 1981-�Recommendation: Revise bullet �.�.5: “The pressure vessel or vessels that are an integral part of the SCBA and that contain the breathing gas supply can be configured as a single cylinder or other pressure vessel or as multiple cylinders or pressure vessels at a rated service pressure of ��16 psi �000 psi or 4500 psi.”Substantiation: Revise bullet.Committee Meeting Action: RejectCommittee Statement: Multiple cylinders could be used for the SCBA air supply.

____________________________________________________________1981-47 Log #�17 FAE-RPE Final Action: Accept(3.3.14 Compressed Breathing Air)____________________________________________________________Submitter: Les Boord, NIOSHComment on Proposal No: 1981-�Recommendation: Delete text from bullet �.�.14 Oxygen or.”Substantiation: Deletion of text.Committee Meeting Action: Accept

____________________________________________________________1981-48 Log #�11 FAE-RPE Final Action: Accept(3.3.44 Service Time and 3.3.36 Rated Service Time)____________________________________________________________Submitter: Les Boord, NIOSHComment on Proposal No: 1981-�Recommendation: Bullet �.�.44 Service Time. See �.�.�6, Rated Service Time.Substantiation: Incorrect bullet reference.Committee Meeting Action: Accept

____________________________________________________________1981-49 Log #11� FAE-RPE Final Action: Reject(4.1.2)____________________________________________________________Submitter: Beverly Gulledge, Scott Health & SafetyComment on Proposal No: 1981-�Recommendation: Requesting interchangeability requirements be deleted as follows: ● 5.1.1 and an interchangeable breathing air cylinder product label. ● 5.1.1.2 Delete entire clause. ● 5.1.7 through 5.1.7.2 Delete all clauses. ● 5.2.4 Delete entire clause. ● 6.1.4 and an interchangeable SCBA cylinder and valve assembly. ● 6.5 through 6.5.5 Delete all clauses. ● Figure 6.5.1 Delete entire figure. ● 7.16 through 7.16.3 Delete all clauses. ● 8.23 through 8.23.6 Delete all clauses. ● 8.24 through 8.24.7 Delete all clauses. ● Table 24.4.2 Delete table. ● 8.25 through 8.25.6 Delete all clauses.Substantiation: Problem: Cylinder interchangeability as required in the NFPA 1981 ROP would render the NIOSH approval void; therefore the NFPA 1981 certification would also be rendered void. ● Substantiation: Cylinder interchangeability presents a conflict, as NIOSH only issues approvals to the manufacturer of complete respirators for the complete respirator. By definition, cylinder interchangeability allows the use a cylinder not supplied by the complete SCBA manufacturer. ● Reason: NFPA 1981:2007 edition, F2006ROP Draft clause 4.1.2 states, “Prior to certification of SCBA to the requirements of this standard, SCBA shall be NIOSH certified.” ● Reason: 42 CFR Part 84 Section 84.30(a) states, “The Institute shall issue certificates of approval pursuant to the provisions of this subpart only for individual, completely assembled respirators which have been examined, inspected, and tested, and which meet the minimum requirements set forth in subparts H through L of this part, as applicable.” ● Reason: 42 CFR Part 84 Section 84.30(b) states “The Institute will not issue certificates of approval for any respirator component or for any respirator subassembly.” ● Reason: The NIOSH Application Procedures for the Certification of Respirators section B.1.1 states, “Only the manufacturer of the product may apply for approval... A manufacturer is defined as the individual or organization that controls and is responsible for the production of the complete and final product in the form as offered to the user...” Problem: Cylinder interchangeability as required in NFPA 1981 ROP would deny the SCBA manufacturer the control and responsibility for the production of the complete and final product in the form as offered to the user. ● Substantiation: SCBA cylinders produced by an individual or organization other than the manufacturer of the complete SCBA as approved by NIOSH would not be responsible for insuring the quality and performance of the complete SCBA as offered to the user are equal to those originally evaluated and approved by NIOSH. ● Reason: 42 CFR Part 84 Section 84.30(a) states, “The Institute shall issue certificates of approval pursuant to the provisions of this subpart only for individual, completely assembled respirators which have been examined, inspected, and tested, and which meet the minimum requirements set forth in subparts H through L of this part, as applicable.” ● Reason: The NIOSH Application Procedures for the Certification of Respirators section B.1.1 states, “Only the manufacture of the product may apply for approval... A manufacturer is defined as the individual or organization that controls and is responsible for the production of the complete and final product in the form as offered to the user...” Problem: Conflict in the approval and certification requirements presented by 4� CFR Part 84, NFPA 1981 F�006ROP, the NIOSH Standard Application Procedure, and the SEI Open-Circuit SCBA Program Manual. ● Substantiation: NFPA 1981 F2006ROP, current 42 CFR Part 84, current NIOSH Standard Application Procedure, nor the Safety Equipment Institute (SEI) current Open-Circuit SCBA Program Manual reflects NIOSH, NFPA and SEI representatives agreement, during NFPA Technical Committee meetings, to work together to solve the conflict in the approval and certification process presented by 4� CFR Part 84, NFPA 1981 F�006 ROP, the NIOSH Standard Application Procedure, and the SEI Open-Circuit SCBA Program Manual. ● Substantiation: No statement, comment, clarification, or revision of any published document pertaining to the approval and certification requirements of NFPA SCBA manufacturers to obtain NFPA 1981 certification have been published.Committee Meeting Action: RejectCommittee Statement: The proposed cylinder interchangeability requirements would not have voided NIOSH certification. However, see the committee action on Comment 1981-16 (Log #111).

1981-17

Report on Comments F2006 — Copyright, NFPA NFPA 1981____________________________________________________________1981-50 Log #�6 FAE-RPE Final Action: Reject(4.1.3)____________________________________________________________TCC Action: The Technical Correlating Committee REJECTS this comment. The TCC carefully reviewed the issues regarding the CBRN requirements being deleted from the proposed 2008 edition of NFPA 1981, including those expressed in the negative ballots on this issue, and the verbal positions heard from TC and TCC members. In accordance with the Regulations Governing Committee Projects (RGCPs), the TCC is taking the action it deems necessary in accordance with its authority as defined in 3.4.2, and in 4.4.7.1: “…The TCC shall be permitted to choose between alternatives presented by the TCs or develop text, as it deems necessary, to achieve correlation, consistence, and the correction of errors and omissions...” The TCC was concerned that some TC members expressed the opinion that while they did see a need for CBRN SCBA in their organization, they didn’t believe that it was necessary throughout the country and that individual departments should make their own determination, and another opinion was that it would be wrong to make other departments pay so much more for their SCBA when they don’t foresee a need for them. There is no way that anyone can predict where a future CBRN event will occur in this country. The terrorist threat is a reality not only in larger metropolitan areas but also in smaller communities and rural areas where terrorists would seek to severely affect the economy or bring it to a halt. While we can and should prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. In the Committee process, all members come to the table with a bias and represent their sponsoring organization’s feelings, but the safety, well being, and protection of the emergency responders must be the goal and local issues should take a secondary position to the improvement of safety for the emergency responders performing in the hazardous environments. In regards to cost, some TC members argued the point that municipalities should have a choice in what SCBA they purchase. In opposition to this stance, one TC member (King) stated, “There is no way that anyone can predict where a future CBRN event will occur in this country. While we can (and should) prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. It is interesting to note that a couple of the first responders who voted against having mandatory CBRN compliant SCBA in this standard acknowledge that their own department insists on CBRN compliant SCBA when purchasing new equipment.” Another TC member (Rossos) stated, “I disagree with the committee’s action regarding CBRN; therefore I must vote in the negative. I believe it is our purpose and responsibility as members of the Committee to strive to design SCBA standards and codes where the end user has the highest level of protection possible. I realize as an end user, that we need to strike a balance between best protection and secondary effects such as comfort, size, weight, etc. and in some regards even economics. We were given no evidence of any of the above compromises to mandating CBRN on all SCBAs. The only thing that we know for sure is that the end user would have a higher level of protection with CBRN as opposed to without. Very few end users have a choice in this matter. Most choices are made by purchasing agents or administrators who often base their decisions on the minimum legal standard available for the lowest price. I believe our first and most important responsibility on this committee is to those who wear SCBA, not to who buys SCBA. Regretfully, when there was no cost involved or reduction in protection, we voted to give the choice to the buyer and not the user.” This was based on the fact that all SCBA manufacturers present at the TC ROC meeting stated that the increased cost of CBRN protection for SCBA was negligible (under $100) or none. Also, TC Chairman Reed responded, “The argument during ROC was that many parts of the country may not have a need for CBRN protection. Unfortunately, in the post 9/11 world, I think this is being unrealistic. While major metropolitan areas may be more likely targets of a terrorist event, we have already seen that the terrorists themselves may reside in small communities while they await their opportunity to strike. They may have the chemical, biological, or nuclear material in their possession, making the possibility of exposure greater for even small, rural areas. But terrorist attacks aside, CBRN-certified SCBA offers greater protection for the fire fighter for a very minimal cost. If this protection is not required by the standard, many jurisdictions will not specify this for their fire fighters.” To the issue about CBRN compliant SCBA are uncomfortable to wear, this appears to be limited to one or two manufacturers’ chosen materials and the reality appears to be that first responders using

CBRN SCBA are not reporting any significant difference relating to the comfort of the equipment and other manufacturers report no complaints from organizations who have purchased and use CBRN SCBA. And to the issue of CBRN compliant SCBA will not be as durable, there appears to be no reason to believe that CBRN compliant SCBA are any less durable than the non-CBRN compliant products on the market today and NIOSH has not received any complaints or identified any durability problems of CBRN SCBA over “regular” SCBA. To the issue of correlation and consistence, the TCC notes that other standards do require CBRN SCBA including NFPA 1500, Standard on Fire Department Occupational Safety and Health Program, 7.11.1.1 of the 2007 edition; 42 CFR 84, Respiratory Protective Devices, and the Statement of Standard for NIOSH CBRN SCBA Testing; and Section 5(A)(1) of the Occupational Safety and Health Act. The TCC believes that lack of correlation with these standards and regulations causes a strong potential decrease of safety for emergency responders due to purchasers believing that as NFPA 1981 is silent on CBRN requirements they do not to have that protection. The TCC further notes that the Department of Homeland Security (DHS) has formally adopted the NIOSH Statement of Standard for NIOSH CBRN SCBA Testing as one of the standards for first responder PPE. Only SCBA that have been approved by NIOSH as CBRN SCBA, which also requires certification to NFPA 1981, can be listed in the Authorized Equipment List (AEL), established by the DHS Office of Grants and Training as the list of recommended equipment for emergency responders. Purchase of SCBA with federal monies through several of the government grant programs requires that SCBA have CBRN approvals from NIOSH. In addition, the InterAgency Board for Equipment Standardization and Interoperability (the IAB) has established CBRN SCBA as the only qualified SCBA in its Standardized Equipment List (SEL). This SEL further provides detailed recommendations for first responder PPE. While NFPA 1500 provides requirements for fire departments, it does not provide requirements for non-fire based emergency responders. NFPA 1981, Standard for Open-Circuit Self-Contained Breathing Apparatus for Emergency Services, does provide SCBA requirements for any emergency services organization that needs protection from IDLH atmospheres. IDLH protection can only be provided by SCBA. The shortsightedness of the TC in removing the CBRN requirement leaves law enforcement responders, emergency medical responders, non-fire based hazardous materials response teams, and the skilled trades emergency responders without CBRN respiratory protection. CBRN protection offers verification of enhanced protection for emergency responders which is not otherwise available. Without CBRN protection evaluation, no SCBA components are tested for permeation, penetration, corrosion resistance, or other detrimental effects from exposure to hazardous chemical warfare atmospheres. NIOSH benchmark testing of non-CBRN hardened NIOSH certified SCBA against CBRN agents demonstrated that CWA agents could cause catastrophic failures within minutes of exposure. A comment by a TC member (Birch) stated, “…it is proper at this point in time to not require CBRN is because although NIOSH and other agencies make/made a good point of testing SCBAs against the list of chemical agents, there are missing tests. There are no tests to show that SCBAs as manufactured now, when altered to meet CBRN requirements, are still resistant to the ‘normal’ atmospheres and chemical agents in which they are currently used.” NIOSH (Boord) countered with, “The selection of the test challenge agents for CBRN protection was based on a comprehensive review of available technical data and consultations with other government agencies (e.g., DOD, DOJ, DOE, etc.). Various chemical data lists were analyzed, including lists from the EPA, ATSDR, NFPA 1994, U.S. Army Center for Health Promotion and Preventative Medicine (USACHPPM) Technical Guide 244, and classified sources. This review established a total of 151 toxic industrial chemicals and chemical warfare agents (TIC-CWA) as potential candidates for challenge agents. The candidate agents were evaluated for permeation (molecularly diffusing through material) and penetration (seeping through interfacing components) characteristics as part of a review of their physical properties.” “This evaluation concluded that Sarin (GB) and Sulfur Mustard (HD) could be selected as the two representative agents for the penetration/permeation test for the complete listing of 151 CWA and TICs due to their physical properties and molecular structure.” “NIOSH is unaware of any data that indicates the CBRN respirators provide less protection against TICs than their industrial counterparts. The evaluation for CBRN protection provides verification and assurance that the component and material combinations in the approved SCBA configurations provide high resistance to permeation and penetration of hazardous atmospheres of toxic industrial chemicals and materials into the breathing air. This is of importance to all responders subject to extreme exposures to any hazardous industrial chemicals and materials.”

1981-18

Report on Comments F2006 — Copyright, NFPA NFPA 1981 The TCC, acting in accordance with 3.4.3(g) of the RGCPs, “Determining whether or not the TC has given due consideration to all evidence presented to it in connection with the preparation of its Report including all comments relating to negative votes” does not believe the TC gave full and appropriate review and due consideration to all the issues and, therefore has taken these actions. In addition to the action taken on 1981-59, the following comments will be affected by this change and, therefore, the following changes must be made to these comments 1981-34 In action #2, change action from “Reject” to “Accept” 1981-50 Change action from “Accept in Principle” to “Reject” 1981-51 Change action from “Accept in Principle” to “Reject” 1981-52 Change action from “Accept in Principle” to “Reject” 1981-53 Change action from “Accept in Principle” to “Reject” 1981-54 Change action from “Accept in Principle” to “Reject” 1981-55 Change action from “Accept in Principle” to “Reject” 1981-56 Change action from “Reject” to “Accept” 1981-57 Change action from “Accept in Principle” to “Reject” 1981-58 Change action from “Accept in Principle” to “Reject” 1981-84 Change action from “Accept in Principle” to “Reject” 1981-85 Change action from “Accept in Principle” to “Reject” 1981-86 Change action from “Accept in Principle” to “Reject” 1981-87 Change action from “Accept in Principle” to “Reject”Submitter: Denis Pilon, Weyburn Fire DepartmentComment on Proposal No: 1981-�Recommendation: Delete entire paragraph.Substantiation: Many rural areas have an extremely low risk of a CBRN attack. This section will add a significant cost to new SCBA purchases without adding a measurable level of safety in these smaller centers. In addition, many larger centers may require a CBRN capability within their HazMat response teams but not necessarily for every SCBA in the department. We believe that the decision as to whether or not CBRN SCBA is required within a jurisdiction and the level at which the department should be outfitted with CBRN SCBA is best left with the AHJ based on a community risk analysis, level of service provided and ability to pay for the additional level of protection.Committee Meeting Action: Accept in Principle See committee action on Comment 1981-59 (Log #16�).Committee Statement: While the committee does not agree with the submitters substantiation, the CBRN requirement is being deleted by the committee action on Comment 1981-59 (Log #16�).

____________________________________________________________1981-51 Log #�8 FAE-RPE Final Action: Reject(4.1.3)____________________________________________________________TCC Action: The Technical Correlating Committee REJECTS this comment. The TCC carefully reviewed the issues regarding the CBRN requirements being deleted from the proposed 2008 edition of NFPA 1981, including those expressed in the negative ballots on this issue, and the verbal positions heard from TC and TCC members. In accordance with the Regulations Governing Committee Projects (RGCPs), the TCC is taking the action it deems necessary in accordance with its authority as defined in 3.4.2, and in 4.4.7.1: “…The TCC shall be permitted to choose between alternatives presented by the TCs or develop text, as it deems necessary, to achieve correlation, consistence, and the correction of errors and omissions...” The TCC was concerned that some TC members expressed the opinion that while they did see a need for CBRN SCBA in their organization, they didn’t believe that it was necessary throughout the country and that individual departments should make their own determination, and another opinion was that it would be wrong to make other departments pay so much more for their SCBA when they don’t foresee a need for them. There is no way that anyone can predict where a future CBRN event will occur in this country. The terrorist threat is a reality not only in larger metropolitan areas but also in smaller communities and rural areas where terrorists would seek to severely affect the economy or bring it to a halt. While we can and should prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. In the Committee process, all members come to the table with a bias and represent their sponsoring organization’s feelings, but the safety, well being, and protection of the emergency responders must be the goal and local issues should take a secondary position to the improvement of safety for the emergency responders performing in the hazardous environments. In regards to cost, some TC members argued the point that municipalities should have a choice in what SCBA they purchase. In opposition to this stance, one TC member (King) stated, “There is no way that anyone can predict where a future CBRN event will occur in this country. While we can (and should) prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first

responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. It is interesting to note that a couple of the first responders who voted against having mandatory CBRN compliant SCBA in this standard acknowledge that their own department insists on CBRN compliant SCBA when purchasing new equipment.” Another TC member (Rossos) stated, “I disagree with the committee’s action regarding CBRN; therefore I must vote in the negative. I believe it is our purpose and responsibility as members of the Committee to strive to design SCBA standards and codes where the end user has the highest level of protection possible. I realize as an end user, that we need to strike a balance between best protection and secondary effects such as comfort, size, weight, etc. and in some regards even economics. We were given no evidence of any of the above compromises to mandating CBRN on all SCBAs. The only thing that we know for sure is that the end user would have a higher level of protection with CBRN as opposed to without. Very few end users have a choice in this matter. Most choices are made by purchasing agents or administrators who often base their decisions on the minimum legal standard available for the lowest price. I believe our first and most important responsibility on this committee is to those who wear SCBA, not to who buys SCBA. Regretfully, when there was no cost involved or reduction in protection, we voted to give the choice to the buyer and not the user.” This was based on the fact that all SCBA manufacturers present at the TC ROC meeting stated that the increased cost of CBRN protection for SCBA was negligible (under $100) or none. Also, TC Chairman Reed responded, “The argument during ROC was that many parts of the country may not have a need for CBRN protection. Unfortunately, in the post 9/11 world, I think this is being unrealistic. While major metropolitan areas may be more likely targets of a terrorist event, we have already seen that the terrorists themselves may reside in small communities while they await their opportunity to strike. They may have the chemical, biological, or nuclear material in their possession, making the possibility of exposure greater for even small, rural areas. But terrorist attacks aside, CBRN-certified SCBA offers greater protection for the fire fighter for a very minimal cost. If this protection is not required by the standard, many jurisdictions will not specify this for their fire fighters.” To the issue about CBRN compliant SCBA are uncomfortable to wear, this appears to be limited to one or two manufacturers’ chosen materials and the reality appears to be that first responders using CBRN SCBA are not reporting any significant difference relating to the comfort of the equipment and other manufacturers report no complaints from organizations who have purchased and use CBRN SCBA. And to the issue of CBRN compliant SCBA will not be as durable, there appears to be no reason to believe that CBRN compliant SCBA are any less durable than the non-CBRN compliant products on the market today and NIOSH has not received any complaints or identified any durability problems of CBRN SCBA over “regular” SCBA. To the issue of correlation and consistence, the TCC notes that other standards do require CBRN SCBA including NFPA 1500, Standard on Fire Department Occupational Safety and Health Program, 7.11.1.1 of the 2007 edition; 42 CFR 84, Respiratory Protective Devices, and the Statement of Standard for NIOSH CBRN SCBA Testing; and Section 5(A)(1) of the Occupational Safety and Health Act. The TCC believes that lack of correlation with these standards and regulations causes a strong potential decrease of safety for emergency responders due to purchasers believing that as NFPA 1981 is silent on CBRN requirements they do not to have that protection. The TCC further notes that the Department of Homeland Security (DHS) has formally adopted the NIOSH Statement of Standard for NIOSH CBRN SCBA Testing as one of the standards for first responder PPE. Only SCBA that have been approved by NIOSH as CBRN SCBA, which also requires certification to NFPA 1981, can be listed in the Authorized Equipment List (AEL), established by the DHS Office of Grants and Training as the list of recommended equipment for emergency responders. Purchase of SCBA with federal monies through several of the government grant programs requires that SCBA have CBRN approvals from NIOSH. In addition, the InterAgency Board for Equipment Standardization and Interoperability (the IAB) has established CBRN SCBA as the only qualified SCBA in its Standardized Equipment List (SEL). This SEL further provides detailed recommendations for first responder PPE. While NFPA 1500 provides requirements for fire departments, it does not provide requirements for non-fire based emergency responders. NFPA 1981, Standard for Open-Circuit Self-Contained Breathing Apparatus for Emergency Services, does provide SCBA requirements for any emergency services organization that needs protection from IDLH atmospheres. IDLH protection can only be provided by SCBA. The shortsightedness of the TC in removing the CBRN requirement leaves law enforcement responders, emergency medical responders, non-fire based hazardous materials response teams, and the skilled trades emergency responders without CBRN respiratory protection.

1981-19

Report on Comments F2006 — Copyright, NFPA NFPA 1981 CBRN protection offers verification of enhanced protection for emergency responders which is not otherwise available. Without CBRN protection evaluation, no SCBA components are tested for permeation, penetration, corrosion resistance, or other detrimental effects from exposure to hazardous chemical warfare atmospheres. NIOSH benchmark testing of non-CBRN hardened NIOSH certified SCBA against CBRN agents demonstrated that CWA agents could cause catastrophic failures within minutes of exposure. A comment by a TC member (Birch) stated, “…it is proper at this point in time to not require CBRN is because although NIOSH and other agencies make/made a good point of testing SCBAs against the list of chemical agents, there are missing tests. There are no tests to show that SCBAs as manufactured now, when altered to meet CBRN requirements, are still resistant to the ‘normal’ atmospheres and chemical agents in which they are currently used.” NIOSH (Boord) countered with, “The selection of the test challenge agents for CBRN protection was based on a comprehensive review of available technical data and consultations with other government agencies (e.g., DOD, DOJ, DOE, etc.). Various chemical data lists were analyzed, including lists from the EPA, ATSDR, NFPA 1994, U.S. Army Center for Health Promotion and Preventative Medicine (USACHPPM) Technical Guide 244, and classified sources. This review established a total of 151 toxic industrial chemicals and chemical warfare agents (TIC-CWA) as potential candidates for challenge agents. The candidate agents were evaluated for permeation (molecularly diffusing through material) and penetration (seeping through interfacing components) characteristics as part of a review of their physical properties.” “This evaluation concluded that Sarin (GB) and Sulfur Mustard (HD) could be selected as the two representative agents for the penetration/permeation test for the complete listing of 151 CWA and TICs due to their physical properties and molecular structure.” “NIOSH is unaware of any data that indicates the CBRN respirators provide less protection against TICs than their industrial counterparts. The evaluation for CBRN protection provides verification and assurance that the component and material combinations in the approved SCBA configurations provide high resistance to permeation and penetration of hazardous atmospheres of toxic industrial chemicals and materials into the breathing air. This is of importance to all responders subject to extreme exposures to any hazardous industrial chemicals and materials.” The TCC, acting in accordance with 3.4.3(g) of the RGCPs, “Determining whether or not the TC has given due consideration to all evidence presented to it in connection with the preparation of its Report including all comments relating to negative votes” does not believe the TC gave full and appropriate review and due consideration to all the issues and, therefore has taken these actions. In addition to the action taken on 1981-59, the following comments will be affected by this change and, therefore, the following changes must be made to these comments 1981-34 In action #2, change action from “Reject” to “Accept” 1981-50 Change action from “Accept in Principle” to “Reject” 1981-51 Change action from “Accept in Principle” to “Reject” 1981-52 Change action from “Accept in Principle” to “Reject” 1981-53 Change action from “Accept in Principle” to “Reject” 1981-54 Change action from “Accept in Principle” to “Reject” 1981-55 Change action from “Accept in Principle” to “Reject” 1981-56 Change action from “Reject” to “Accept” 1981-57 Change action from “Accept in Principle” to “Reject” 1981-58 Change action from “Accept in Principle” to “Reject” 1981-84 Change action from “Accept in Principle” to “Reject” 1981-85 Change action from “Accept in Principle” to “Reject” 1981-86 Change action from “Accept in Principle” to “Reject” 1981-87 Change action from “Accept in Principle” to “Reject”Submitter: Robert Sell, Draeger Safety, Inc.Comment on Proposal No: 1981-�Recommendation: Delete entire section: SCBA that are certified as compliant with NFPA 1981 shall also be certified by NIOSH as a CBRN SCBA.Substantiation: 1. The NFPA 1500 Technical Committee has already made this a requirement (Section 7.11.1.1) in their document for the next revision. �. CBRN certifications would increase the lead time for NFPA 1981 certifications and would require a longer implementation date for NFPA 1981. �. From discussions with many volunteer fire departments. CBRN certification is something that they feel is not needed for their operations.Committee Meeting Action: Accept in Principle See committee action on Comment 1981-59 (Log #16�).Committee Statement: While the committee does not agree with the submitters substantiation, the CBRN requirement is being deleted by the committee action on Comment 1981-59 (Log #16�).

____________________________________________________________1981-5� Log #56 FAE-RPE Final Action: Reject(4.1.3)____________________________________________________________TCC Action: The Technical Correlating Committee REJECTS this comment. The TCC carefully reviewed the issues regarding the CBRN requirements being deleted from the proposed 2008 edition of NFPA 1981, including those expressed in the negative ballots on this issue, and the verbal positions heard from TC and TCC members. In accordance with the Regulations Governing Committee Projects (RGCPs), the TCC is taking the action it deems necessary in accordance with its authority as defined in 3.4.2, and in 4.4.7.1: “…The TCC shall be permitted to choose between alternatives presented by the TCs or develop text, as it deems necessary, to achieve correlation, consistence, and the correction of errors and omissions...” The TCC was concerned that some TC members expressed the opinion that while they did see a need for CBRN SCBA in their organization, they didn’t believe that it was necessary throughout the country and that individual departments should make their own determination, and another opinion was that it would be wrong to make other departments pay so much more for their SCBA when they don’t foresee a need for them. There is no way that anyone can predict where a future CBRN event will occur in this country. The terrorist threat is a reality not only in larger metropolitan areas but also in smaller communities and rural areas where terrorists would seek to severely affect the economy or bring it to a halt. While we can and should prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. In the Committee process, all members come to the table with a bias and represent their sponsoring organization’s feelings, but the safety, well being, and protection of the emergency responders must be the goal and local issues should take a secondary position to the improvement of safety for the emergency responders performing in the hazardous environments. In regards to cost, some TC members argued the point that municipalities should have a choice in what SCBA they purchase. In opposition to this stance, one TC member (King) stated, “There is no way that anyone can predict where a future CBRN event will occur in this country. While we can (and should) prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. It is interesting to note that a couple of the first responders who voted against having mandatory CBRN compliant SCBA in this standard acknowledge that their own department insists on CBRN compliant SCBA when purchasing new equipment.” Another TC member (Rossos) stated, “I disagree with the committee’s action regarding CBRN; therefore I must vote in the negative. I believe it is our purpose and responsibility as members of the Committee to strive to design SCBA standards and codes where the end user has the highest level of protection possible. I realize as an end user, that we need to strike a balance between best protection and secondary effects such as comfort, size, weight, etc. and in some regards even economics. We were given no evidence of any of the above compromises to mandating CBRN on all SCBAs. The only thing that we know for sure is that the end user would have a higher level of protection with CBRN as opposed to without. Very few end users have a choice in this matter. Most choices are made by purchasing agents or administrators who often base their decisions on the minimum legal standard available for the lowest price. I believe our first and most important responsibility on this committee is to those who wear SCBA, not to who buys SCBA. Regretfully, when there was no cost involved or reduction in protection, we voted to give the choice to the buyer and not the user.” This was based on the fact that all SCBA manufacturers present at the TC ROC meeting stated that the increased cost of CBRN protection for SCBA was negligible (under $100) or none. Also, TC Chairman Reed responded, “The argument during ROC was that many parts of the country may not have a need for CBRN protection. Unfortunately, in the post 9/11 world, I think this is being unrealistic. While major metropolitan areas may be more likely targets of a terrorist event, we have already seen that the terrorists themselves may reside in small communities while they await their opportunity to strike. They may have the chemical, biological, or nuclear material in their possession, making the possibility of exposure greater for even small, rural areas. But terrorist attacks aside, CBRN-certified SCBA offers greater protection for the fire fighter for a very minimal cost. If this protection is not required by the standard, many jurisdictions will not specify this for their fire fighters.” To the issue about CBRN compliant SCBA are uncomfortable to wear, this appears to be limited to one or two manufacturers’ chosen materials and the reality appears to be that first responders using

1981-�0

Report on Comments F2006 — Copyright, NFPA NFPA 1981CBRN SCBA are not reporting any significant difference relating to the comfort of the equipment and other manufacturers report no complaints from organizations who have purchased and use CBRN SCBA. And to the issue of CBRN compliant SCBA will not be as durable, there appears to be no reason to believe that CBRN compliant SCBA are any less durable than the non-CBRN compliant products on the market today and NIOSH has not received any complaints or identified any durability problems of CBRN SCBA over “regular” SCBA. To the issue of correlation and consistence, the TCC notes that other standards do require CBRN SCBA including NFPA 1500, Standard on Fire Department Occupational Safety and Health Program, 7.11.1.1 of the 2007 edition; 42 CFR 84, Respiratory Protective Devices, and the Statement of Standard for NIOSH CBRN SCBA Testing; and Section 5(A)(1) of the Occupational Safety and Health Act. The TCC believes that lack of correlation with these standards and regulations causes a strong potential decrease of safety for emergency responders due to purchasers believing that as NFPA 1981 is silent on CBRN requirements they do not to have that protection. The TCC further notes that the Department of Homeland Security (DHS) has formally adopted the NIOSH Statement of Standard for NIOSH CBRN SCBA Testing as one of the standards for first responder PPE. Only SCBA that have been approved by NIOSH as CBRN SCBA, which also requires certification to NFPA 1981, can be listed in the Authorized Equipment List (AEL), established by the DHS Office of Grants and Training as the list of recommended equipment for emergency responders. Purchase of SCBA with federal monies through several of the government grant programs requires that SCBA have CBRN approvals from NIOSH. In addition, the InterAgency Board for Equipment Standardization and Interoperability (the IAB) has established CBRN SCBA as the only qualified SCBA in its Standardized Equipment List (SEL). This SEL further provides detailed recommendations for first responder PPE. While NFPA 1500 provides requirements for fire departments, it does not provide requirements for non-fire based emergency responders. NFPA 1981, Standard for Open-Circuit Self-Contained Breathing Apparatus for Emergency Services, does provide SCBA requirements for any emergency services organization that needs protection from IDLH atmospheres. IDLH protection can only be provided by SCBA. The shortsightedness of the TC in removing the CBRN requirement leaves law enforcement responders, emergency medical responders, non-fire based hazardous materials response teams, and the skilled trades emergency responders without CBRN respiratory protection. CBRN protection offers verification of enhanced protection for emergency responders which is not otherwise available. Without CBRN protection evaluation, no SCBA components are tested for permeation, penetration, corrosion resistance, or other detrimental effects from exposure to hazardous chemical warfare atmospheres. NIOSH benchmark testing of non-CBRN hardened NIOSH certified SCBA against CBRN agents demonstrated that CWA agents could cause catastrophic failures within minutes of exposure. A comment by a TC member (Birch) stated, “…it is proper at this point in time to not require CBRN is because although NIOSH and other agencies make/made a good point of testing SCBAs against the list of chemical agents, there are missing tests. There are no tests to show that SCBAs as manufactured now, when altered to meet CBRN requirements, are still resistant to the ‘normal’ atmospheres and chemical agents in which they are currently used.” NIOSH (Boord) countered with, “The selection of the test challenge agents for CBRN protection was based on a comprehensive review of available technical data and consultations with other government agencies (e.g., DOD, DOJ, DOE, etc.). Various chemical data lists were analyzed, including lists from the EPA, ATSDR, NFPA 1994, U.S. Army Center for Health Promotion and Preventative Medicine (USACHPPM) Technical Guide 244, and classified sources. This review established a total of 151 toxic industrial chemicals and chemical warfare agents (TIC-CWA) as potential candidates for challenge agents. The candidate agents were evaluated for permeation (molecularly diffusing through material) and penetration (seeping through interfacing components) characteristics as part of a review of their physical properties.” “This evaluation concluded that Sarin (GB) and Sulfur Mustard (HD) could be selected as the two representative agents for the penetration/permeation test for the complete listing of 151 CWA and TICs due to their physical properties and molecular structure.” “NIOSH is unaware of any data that indicates the CBRN respirators provide less protection against TICs than their industrial counterparts. The evaluation for CBRN protection provides verification and assurance that the component and material combinations in the approved SCBA configurations provide high resistance to permeation and penetration of hazardous atmospheres of toxic industrial chemicals and materials into the breathing air. This is of importance to all responders subject to extreme exposures to any hazardous industrial chemicals and materials.”

The TCC, acting in accordance with 3.4.3(g) of the RGCPs, “Determining whether or not the TC has given due consideration to all evidence presented to it in connection with the preparation of its Report including all comments relating to negative votes” does not believe the TC gave full and appropriate review and due consideration to all the issues and, therefore has taken these actions. In addition to the action taken on 1981-59, the following comments will be affected by this change and, therefore, the following changes must be made to these comments 1981-34 In action #2, change action from “Reject” to “Accept” 1981-50 Change action from “Accept in Principle” to “Reject” 1981-51 Change action from “Accept in Principle” to “Reject” 1981-52 Change action from “Accept in Principle” to “Reject” 1981-53 Change action from “Accept in Principle” to “Reject” 1981-54 Change action from “Accept in Principle” to “Reject” 1981-55 Change action from “Accept in Principle” to “Reject” 1981-56 Change action from “Reject” to “Accept” 1981-57 Change action from “Accept in Principle” to “Reject” 1981-58 Change action from “Accept in Principle” to “Reject” 1981-84 Change action from “Accept in Principle” to “Reject” 1981-85 Change action from “Accept in Principle” to “Reject” 1981-86 Change action from “Accept in Principle” to “Reject” 1981-87 Change action from “Accept in Principle” to “Reject”Submitter: David T. Bernzweig, Columbus, OHComment on Proposal No: 1981-�Recommendation: Delete paragraph: SCBA that are certified as compliant with NFPA 1981 shall also be certified by NIOSH as a CBRN SCBA.Substantiation: The requirement to require the adoption of only CBRN certified SCBA is not substantiated by any universal fire service need or desire. The decision to adopt a CBRN certified SCBA is a decision best determined by the local authority.Committee Meeting Action: Accept in Principle See committee action on Comment 1981-59 (Log #16�).Committee Statement: See committee action on Comment 1981-59 (Log #16�).

____________________________________________________________1981-5� Log #8� FAE-RPE Final Action: Reject(4.1.3)____________________________________________________________TCC Action: The Technical Correlating Committee REJECTS this comment. The TCC carefully reviewed the issues regarding the CBRN requirements being deleted from the proposed 2008 edition of NFPA 1981, including those expressed in the negative ballots on this issue, and the verbal positions heard from TC and TCC members. In accordance with the Regulations Governing Committee Projects (RGCPs), the TCC is taking the action it deems necessary in accordance with its authority as defined in 3.4.2, and in 4.4.7.1: “…The TCC shall be permitted to choose between alternatives presented by the TCs or develop text, as it deems necessary, to achieve correlation, consistence, and the correction of errors and omissions...” The TCC was concerned that some TC members expressed the opinion that while they did see a need for CBRN SCBA in their organization, they didn’t believe that it was necessary throughout the country and that individual departments should make their own determination, and another opinion was that it would be wrong to make other departments pay so much more for their SCBA when they don’t foresee a need for them. There is no way that anyone can predict where a future CBRN event will occur in this country. The terrorist threat is a reality not only in larger metropolitan areas but also in smaller communities and rural areas where terrorists would seek to severely affect the economy or bring it to a halt. While we can and should prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. In the Committee process, all members come to the table with a bias and represent their sponsoring organization’s feelings, but the safety, well being, and protection of the emergency responders must be the goal and local issues should take a secondary position to the improvement of safety for the emergency responders performing in the hazardous environments. In regards to cost, some TC members argued the point that municipalities should have a choice in what SCBA they purchase. In opposition to this stance, one TC member (King) stated, “There is no way that anyone can predict where a future CBRN event will occur in this country. While we can (and should) prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. It is interesting to note that a couple of the first responders who voted against having mandatory CBRN compliant SCBA in this standard acknowledge that their own department insists on CBRN compliant SCBA when purchasing new equipment.”

1981-�1

Report on Comments F2006 — Copyright, NFPA NFPA 1981 Another TC member (Rossos) stated, “I disagree with the committee’s action regarding CBRN; therefore I must vote in the negative. I believe it is our purpose and responsibility as members of the Committee to strive to design SCBA standards and codes where the end user has the highest level of protection possible. I realize as an end user, that we need to strike a balance between best protection and secondary effects such as comfort, size, weight, etc. and in some regards even economics. We were given no evidence of any of the above compromises to mandating CBRN on all SCBAs. The only thing that we know for sure is that the end user would have a higher level of protection with CBRN as opposed to without. Very few end users have a choice in this matter. Most choices are made by purchasing agents or administrators who often base their decisions on the minimum legal standard available for the lowest price. I believe our first and most important responsibility on this committee is to those who wear SCBA, not to who buys SCBA. Regretfully, when there was no cost involved or reduction in protection, we voted to give the choice to the buyer and not the user.” This was based on the fact that all SCBA manufacturers present at the TC ROC meeting stated that the increased cost of CBRN protection for SCBA was negligible (under $100) or none. Also, TC Chairman Reed responded, “The argument during ROC was that many parts of the country may not have a need for CBRN protection. Unfortunately, in the post 9/11 world, I think this is being unrealistic. While major metropolitan areas may be more likely targets of a terrorist event, we have already seen that the terrorists themselves may reside in small communities while they await their opportunity to strike. They may have the chemical, biological, or nuclear material in their possession, making the possibility of exposure greater for even small, rural areas. But terrorist attacks aside, CBRN-certified SCBA offers greater protection for the fire fighter for a very minimal cost. If this protection is not required by the standard, many jurisdictions will not specify this for their fire fighters.” To the issue about CBRN compliant SCBA are uncomfortable to wear, this appears to be limited to one or two manufacturers’ chosen materials and the reality appears to be that first responders using CBRN SCBA are not reporting any significant difference relating to the comfort of the equipment and other manufacturers report no complaints from organizations who have purchased and use CBRN SCBA. And to the issue of CBRN compliant SCBA will not be as durable, there appears to be no reason to believe that CBRN compliant SCBA are any less durable than the non-CBRN compliant products on the market today and NIOSH has not received any complaints or identified any durability problems of CBRN SCBA over “regular” SCBA. To the issue of correlation and consistence, the TCC notes that other standards do require CBRN SCBA including NFPA 1500, Standard on Fire Department Occupational Safety and Health Program, 7.11.1.1 of the 2007 edition; 42 CFR 84, Respiratory Protective Devices, and the Statement of Standard for NIOSH CBRN SCBA Testing; and Section 5(A)(1) of the Occupational Safety and Health Act. The TCC believes that lack of correlation with these standards and regulations causes a strong potential decrease of safety for emergency responders due to purchasers believing that as NFPA 1981 is silent on CBRN requirements they do not to have that protection. The TCC further notes that the Department of Homeland Security (DHS) has formally adopted the NIOSH Statement of Standard for NIOSH CBRN SCBA Testing as one of the standards for first responder PPE. Only SCBA that have been approved by NIOSH as CBRN SCBA, which also requires certification to NFPA 1981, can be listed in the Authorized Equipment List (AEL), established by the DHS Office of Grants and Training as the list of recommended equipment for emergency responders. Purchase of SCBA with federal monies through several of the government grant programs requires that SCBA have CBRN approvals from NIOSH. In addition, the InterAgency Board for Equipment Standardization and Interoperability (the IAB) has established CBRN SCBA as the only qualified SCBA in its Standardized Equipment List (SEL). This SEL further provides detailed recommendations for first responder PPE. While NFPA 1500 provides requirements for fire departments, it does not provide requirements for non-fire based emergency responders. NFPA 1981, Standard for Open-Circuit Self-Contained Breathing Apparatus for Emergency Services, does provide SCBA requirements for any emergency services organization that needs protection from IDLH atmospheres. IDLH protection can only be provided by SCBA. The shortsightedness of the TC in removing the CBRN requirement leaves law enforcement responders, emergency medical responders, non-fire based hazardous materials response teams, and the skilled trades emergency responders without CBRN respiratory protection. CBRN protection offers verification of enhanced protection for emergency responders which is not otherwise available. Without CBRN protection evaluation, no SCBA components are tested for permeation, penetration, corrosion resistance, or other detrimental effects from exposure to hazardous chemical warfare atmospheres.

NIOSH benchmark testing of non-CBRN hardened NIOSH certified SCBA against CBRN agents demonstrated that CWA agents could cause catastrophic failures within minutes of exposure. A comment by a TC member (Birch) stated, “…it is proper at this point in time to not require CBRN is because although NIOSH and other agencies make/made a good point of testing SCBAs against the list of chemical agents, there are missing tests. There are no tests to show that SCBAs as manufactured now, when altered to meet CBRN requirements, are still resistant to the ‘normal’ atmospheres and chemical agents in which they are currently used.” NIOSH (Boord) countered with, “The selection of the test challenge agents for CBRN protection was based on a comprehensive review of available technical data and consultations with other government agencies (e.g., DOD, DOJ, DOE, etc.). Various chemical data lists were analyzed, including lists from the EPA, ATSDR, NFPA 1994, U.S. Army Center for Health Promotion and Preventative Medicine (USACHPPM) Technical Guide 244, and classified sources. This review established a total of 151 toxic industrial chemicals and chemical warfare agents (TIC-CWA) as potential candidates for challenge agents. The candidate agents were evaluated for permeation (molecularly diffusing through material) and penetration (seeping through interfacing components) characteristics as part of a review of their physical properties.” “This evaluation concluded that Sarin (GB) and Sulfur Mustard (HD) could be selected as the two representative agents for the penetration/permeation test for the complete listing of 151 CWA and TICs due to their physical properties and molecular structure.” “NIOSH is unaware of any data that indicates the CBRN respirators provide less protection against TICs than their industrial counterparts. The evaluation for CBRN protection provides verification and assurance that the component and material combinations in the approved SCBA configurations provide high resistance to permeation and penetration of hazardous atmospheres of toxic industrial chemicals and materials into the breathing air. This is of importance to all responders subject to extreme exposures to any hazardous industrial chemicals and materials.” The TCC, acting in accordance with 3.4.3(g) of the RGCPs, “Determining whether or not the TC has given due consideration to all evidence presented to it in connection with the preparation of its Report including all comments relating to negative votes” does not believe the TC gave full and appropriate review and due consideration to all the issues and, therefore has taken these actions. In addition to the action taken on 1981-59, the following comments will be affected by this change and, therefore, the following changes must be made to these comments 1981-34 In action #2, change action from “Reject” to “Accept” 1981-50 Change action from “Accept in Principle” to “Reject” 1981-51 Change action from “Accept in Principle” to “Reject” 1981-52 Change action from “Accept in Principle” to “Reject” 1981-53 Change action from “Accept in Principle” to “Reject” 1981-54 Change action from “Accept in Principle” to “Reject” 1981-55 Change action from “Accept in Principle” to “Reject” 1981-56 Change action from “Reject” to “Accept” 1981-57 Change action from “Accept in Principle” to “Reject” 1981-58 Change action from “Accept in Principle” to “Reject” 1981-84 Change action from “Accept in Principle” to “Reject” 1981-85 Change action from “Accept in Principle” to “Reject” 1981-86 Change action from “Accept in Principle” to “Reject” 1981-87 Change action from “Accept in Principle” to “Reject”Submitter: Lori Rammel, City of Trotwood Fire & RescueComment on Proposal No: 1981-�Recommendation: Delete the following paragraph: SCBA that are certified as compliant with NFPA 1981 shall also be certified by NIOSH as a CBRN SCBA.Substantiation: The requirement to require the adoption of only CBRN certified SCBA is not substantiated by any universal fire service need or desire. The decision to adopt a CBRN certified SCBA is a decision best determined by the local authority.Committee Meeting Action: Accept in Principle See committee action on Comment 1981-59 (Log #16�).Committee Statement: See committee action on Comment 1981-59 (Log #16�).

____________________________________________________________1981-54 Log #84 FAE-RPE Final Action: Reject(4.1.3)____________________________________________________________TCC Action: The Technical Correlating Committee REJECTS this comment. The TCC carefully reviewed the issues regarding the CBRN requirements being deleted from the proposed 2008 edition of NFPA 1981, including those expressed in the negative ballots on this issue, and the verbal positions heard from TC and TCC members. In accordance with the Regulations Governing Committee Projects (RGCPs), the TCC is taking the action it deems necessary in accordance with its authority as defined in 3.4.2, and in 4.4.7.1: “…The TCC shall be permitted to choose between alternatives presented by the TCs or develop text, as it deems necessary, to achieve correlation, consistence, and the correction of errors and omissions...”

1981-��

Report on Comments F2006 — Copyright, NFPA NFPA 1981 The TCC was concerned that some TC members expressed the opinion that while they did see a need for CBRN SCBA in their organization, they didn’t believe that it was necessary throughout the country and that individual departments should make their own determination, and another opinion was that it would be wrong to make other departments pay so much more for their SCBA when they don’t foresee a need for them. There is no way that anyone can predict where a future CBRN event will occur in this country. The terrorist threat is a reality not only in larger metropolitan areas but also in smaller communities and rural areas where terrorists would seek to severely affect the economy or bring it to a halt. While we can and should prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. In the Committee process, all members come to the table with a bias and represent their sponsoring organization’s feelings, but the safety, well being, and protection of the emergency responders must be the goal and local issues should take a secondary position to the improvement of safety for the emergency responders performing in the hazardous environments. In regards to cost, some TC members argued the point that municipalities should have a choice in what SCBA they purchase. In opposition to this stance, one TC member (King) stated, “There is no way that anyone can predict where a future CBRN event will occur in this country. While we can (and should) prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. It is interesting to note that a couple of the first responders who voted against having mandatory CBRN compliant SCBA in this standard acknowledge that their own department insists on CBRN compliant SCBA when purchasing new equipment.” Another TC member (Rossos) stated, “I disagree with the committee’s action regarding CBRN; therefore I must vote in the negative. I believe it is our purpose and responsibility as members of the Committee to strive to design SCBA standards and codes where the end user has the highest level of protection possible. I realize as an end user, that we need to strike a balance between best protection and secondary effects such as comfort, size, weight, etc. and in some regards even economics. We were given no evidence of any of the above compromises to mandating CBRN on all SCBAs. The only thing that we know for sure is that the end user would have a higher level of protection with CBRN as opposed to without. Very few end users have a choice in this matter. Most choices are made by purchasing agents or administrators who often base their decisions on the minimum legal standard available for the lowest price. I believe our first and most important responsibility on this committee is to those who wear SCBA, not to who buys SCBA. Regretfully, when there was no cost involved or reduction in protection, we voted to give the choice to the buyer and not the user.” This was based on the fact that all SCBA manufacturers present at the TC ROC meeting stated that the increased cost of CBRN protection for SCBA was negligible (under $100) or none. Also, TC Chairman Reed responded, “The argument during ROC was that many parts of the country may not have a need for CBRN protection. Unfortunately, in the post 9/11 world, I think this is being unrealistic. While major metropolitan areas may be more likely targets of a terrorist event, we have already seen that the terrorists themselves may reside in small communities while they await their opportunity to strike. They may have the chemical, biological, or nuclear material in their possession, making the possibility of exposure greater for even small, rural areas. But terrorist attacks aside, CBRN-certified SCBA offers greater protection for the fire fighter for a very minimal cost. If this protection is not required by the standard, many jurisdictions will not specify this for their fire fighters.” To the issue about CBRN compliant SCBA are uncomfortable to wear, this appears to be limited to one or two manufacturers’ chosen materials and the reality appears to be that first responders using CBRN SCBA are not reporting any significant difference relating to the comfort of the equipment and other manufacturers report no complaints from organizations who have purchased and use CBRN SCBA. And to the issue of CBRN compliant SCBA will not be as durable, there appears to be no reason to believe that CBRN compliant SCBA are any less durable than the non-CBRN compliant products on the market today and NIOSH has not received any complaints or identified any durability problems of CBRN SCBA over “regular” SCBA. To the issue of correlation and consistence, the TCC notes that other standards do require CBRN SCBA including NFPA 1500, Standard on Fire Department Occupational Safety and Health Program, 7.11.1.1 of the 2007 edition; 42 CFR 84, Respiratory Protective Devices, and the Statement of Standard for NIOSH CBRN SCBA Testing; and Section 5(A)(1) of the Occupational Safety and Health Act. The TCC

believes that lack of correlation with these standards and regulations causes a strong potential decrease of safety for emergency responders due to purchasers believing that as NFPA 1981 is silent on CBRN requirements they do not to have that protection. The TCC further notes that the Department of Homeland Security (DHS) has formally adopted the NIOSH Statement of Standard for NIOSH CBRN SCBA Testing as one of the standards for first responder PPE. Only SCBA that have been approved by NIOSH as CBRN SCBA, which also requires certification to NFPA 1981, can be listed in the Authorized Equipment List (AEL), established by the DHS Office of Grants and Training as the list of recommended equipment for emergency responders. Purchase of SCBA with federal monies through several of the government grant programs requires that SCBA have CBRN approvals from NIOSH. In addition, the InterAgency Board for Equipment Standardization and Interoperability (the IAB) has established CBRN SCBA as the only qualified SCBA in its Standardized Equipment List (SEL). This SEL further provides detailed recommendations for first responder PPE. While NFPA 1500 provides requirements for fire departments, it does not provide requirements for non-fire based emergency responders. NFPA 1981, Standard for Open-Circuit Self-Contained Breathing Apparatus for Emergency Services, does provide SCBA requirements for any emergency services organization that needs protection from IDLH atmospheres. IDLH protection can only be provided by SCBA. The shortsightedness of the TC in removing the CBRN requirement leaves law enforcement responders, emergency medical responders, non-fire based hazardous materials response teams, and the skilled trades emergency responders without CBRN respiratory protection. CBRN protection offers verification of enhanced protection for emergency responders which is not otherwise available. Without CBRN protection evaluation, no SCBA components are tested for permeation, penetration, corrosion resistance, or other detrimental effects from exposure to hazardous chemical warfare atmospheres. NIOSH benchmark testing of non-CBRN hardened NIOSH certified SCBA against CBRN agents demonstrated that CWA agents could cause catastrophic failures within minutes of exposure. A comment by a TC member (Birch) stated, “…it is proper at this point in time to not require CBRN is because although NIOSH and other agencies make/made a good point of testing SCBAs against the list of chemical agents, there are missing tests. There are no tests to show that SCBAs as manufactured now, when altered to meet CBRN requirements, are still resistant to the ‘normal’ atmospheres and chemical agents in which they are currently used.” NIOSH (Boord) countered with, “The selection of the test challenge agents for CBRN protection was based on a comprehensive review of available technical data and consultations with other government agencies (e.g., DOD, DOJ, DOE, etc.). Various chemical data lists were analyzed, including lists from the EPA, ATSDR, NFPA 1994, U.S. Army Center for Health Promotion and Preventative Medicine (USACHPPM) Technical Guide 244, and classified sources. This review established a total of 151 toxic industrial chemicals and chemical warfare agents (TIC-CWA) as potential candidates for challenge agents. The candidate agents were evaluated for permeation (molecularly diffusing through material) and penetration (seeping through interfacing components) characteristics as part of a review of their physical properties.” “This evaluation concluded that Sarin (GB) and Sulfur Mustard (HD) could be selected as the two representative agents for the penetration/permeation test for the complete listing of 151 CWA and TICs due to their physical properties and molecular structure.” “NIOSH is unaware of any data that indicates the CBRN respirators provide less protection against TICs than their industrial counterparts. The evaluation for CBRN protection provides verification and assurance that the component and material combinations in the approved SCBA configurations provide high resistance to permeation and penetration of hazardous atmospheres of toxic industrial chemicals and materials into the breathing air. This is of importance to all responders subject to extreme exposures to any hazardous industrial chemicals and materials.” The TCC, acting in accordance with 3.4.3(g) of the RGCPs, “Determining whether or not the TC has given due consideration to all evidence presented to it in connection with the preparation of its Report including all comments relating to negative votes” does not believe the TC gave full and appropriate review and due consideration to all the issues and, therefore has taken these actions. In addition to the action taken on 1981-59, the following comments will be affected by this change and, therefore, the following changes must be made to these comments 1981-34 In action #2, change action from “Reject” to “Accept” 1981-50 Change action from “Accept in Principle” to “Reject” 1981-51 Change action from “Accept in Principle” to “Reject” 1981-52 Change action from “Accept in Principle” to “Reject” 1981-53 Change action from “Accept in Principle” to “Reject” 1981-54 Change action from “Accept in Principle” to “Reject” 1981-55 Change action from “Accept in Principle” to “Reject”

1981-��

Report on Comments F2006 — Copyright, NFPA NFPA 1981 1981-56 Change action from “Reject” to “Accept” 1981-57 Change action from “Accept in Principle” to “Reject” 1981-58 Change action from “Accept in Principle” to “Reject” 1981-84 Change action from “Accept in Principle” to “Reject” 1981-85 Change action from “Accept in Principle” to “Reject” 1981-86 Change action from “Accept in Principle” to “Reject” 1981-87 Change action from “Accept in Principle” to “Reject”Submitter: Lawrence Petrick, Ohio Association of Professional FirefightersComment on Proposal No: 1981-�Recommendation: Delete the following paragraph: SCBA that are certified as compliant with NFPA 1981 shall also be certified by NIOSH as a SBRN SCBA.Substantiation: The SCBA was designed for actual everyday fire service needs, firefighting. Changing it to meet the challenge of a rarely occurring event is not proper risk assessment of the fire service. It is a disservice. This requirement is not substantiated by any universal fire service need or desire. The decision to adopt a CBRN SCBA is that of the local authority.Committee Meeting Action: Accept in Principle See committee action on Comment 1981-59 (Log #16�).Committee Statement: While the committee does not agree with the submitters substantiation, the CBRN requirement is being deleted by the committee action on Comment 1981-59 (Log #16�).

____________________________________________________________1981-55 Log #114 FAE-RPE Final Action: Reject(4.1.3)____________________________________________________________TCC Action: The Technical Correlating Committee REJECTS this comment. The TCC carefully reviewed the issues regarding the CBRN requirements being deleted from the proposed 2008 edition of NFPA 1981, including those expressed in the negative ballots on this issue, and the verbal positions heard from TC and TCC members. In accordance with the Regulations Governing Committee Projects (RGCPs), the TCC is taking the action it deems necessary in accordance with its authority as defined in 3.4.2, and in 4.4.7.1: “…The TCC shall be permitted to choose between alternatives presented by the TCs or develop text, as it deems necessary, to achieve correlation, consistence, and the correction of errors and omissions...” The TCC was concerned that some TC members expressed the opinion that while they did see a need for CBRN SCBA in their organization, they didn’t believe that it was necessary throughout the country and that individual departments should make their own determination, and another opinion was that it would be wrong to make other departments pay so much more for their SCBA when they don’t foresee a need for them. There is no way that anyone can predict where a future CBRN event will occur in this country. The terrorist threat is a reality not only in larger metropolitan areas but also in smaller communities and rural areas where terrorists would seek to severely affect the economy or bring it to a halt. While we can and should prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. In the Committee process, all members come to the table with a bias and represent their sponsoring organization’s feelings, but the safety, well being, and protection of the emergency responders must be the goal and local issues should take a secondary position to the improvement of safety for the emergency responders performing in the hazardous environments. In regards to cost, some TC members argued the point that municipalities should have a choice in what SCBA they purchase. In opposition to this stance, one TC member (King) stated, “There is no way that anyone can predict where a future CBRN event will occur in this country. While we can (and should) prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. It is interesting to note that a couple of the first responders who voted against having mandatory CBRN compliant SCBA in this standard acknowledge that their own department insists on CBRN compliant SCBA when purchasing new equipment.” Another TC member (Rossos) stated, “I disagree with the committee’s action regarding CBRN; therefore I must vote in the negative. I believe it is our purpose and responsibility as members of the Committee to strive to design SCBA standards and codes where the end user has the highest level of protection possible. I realize as an end user, that we need to strike a balance between best protection and secondary effects such as comfort, size, weight, etc. and in some regards even economics. We were given no evidence of any of the above compromises to mandating CBRN on all SCBAs. The only thing that we know for sure is that the end user would have a higher level of protection with CBRN as opposed to without. Very few end users have a choice in this matter. Most choices are made by purchasing agents

or administrators who often base their decisions on the minimum legal standard available for the lowest price. I believe our first and most important responsibility on this committee is to those who wear SCBA, not to who buys SCBA. Regretfully, when there was no cost involved or reduction in protection, we voted to give the choice to the buyer and not the user.” This was based on the fact that all SCBA manufacturers present at the TC ROC meeting stated that the increased cost of CBRN protection for SCBA was negligible (under $100) or none. Also, TC Chairman Reed responded, “The argument during ROC was that many parts of the country may not have a need for CBRN protection. Unfortunately, in the post 9/11 world, I think this is being unrealistic. While major metropolitan areas may be more likely targets of a terrorist event, we have already seen that the terrorists themselves may reside in small communities while they await their opportunity to strike. They may have the chemical, biological, or nuclear material in their possession, making the possibility of exposure greater for even small, rural areas. But terrorist attacks aside, CBRN-certified SCBA offers greater protection for the fire fighter for a very minimal cost. If this protection is not required by the standard, many jurisdictions will not specify this for their fire fighters.” To the issue about CBRN compliant SCBA are uncomfortable to wear, this appears to be limited to one or two manufacturers’ chosen materials and the reality appears to be that first responders using CBRN SCBA are not reporting any significant difference relating to the comfort of the equipment and other manufacturers report no complaints from organizations who have purchased and use CBRN SCBA. And to the issue of CBRN compliant SCBA will not be as durable, there appears to be no reason to believe that CBRN compliant SCBA are any less durable than the non-CBRN compliant products on the market today and NIOSH has not received any complaints or identified any durability problems of CBRN SCBA over “regular” SCBA. To the issue of correlation and consistence, the TCC notes that other standards do require CBRN SCBA including NFPA 1500, Standard on Fire Department Occupational Safety and Health Program, 7.11.1.1 of the 2007 edition; 42 CFR 84, Respiratory Protective Devices, and the Statement of Standard for NIOSH CBRN SCBA Testing; and Section 5(A)(1) of the Occupational Safety and Health Act. The TCC believes that lack of correlation with these standards and regulations causes a strong potential decrease of safety for emergency responders due to purchasers believing that as NFPA 1981 is silent on CBRN requirements they do not to have that protection. The TCC further notes that the Department of Homeland Security (DHS) has formally adopted the NIOSH Statement of Standard for NIOSH CBRN SCBA Testing as one of the standards for first responder PPE. Only SCBA that have been approved by NIOSH as CBRN SCBA, which also requires certification to NFPA 1981, can be listed in the Authorized Equipment List (AEL), established by the DHS Office of Grants and Training as the list of recommended equipment for emergency responders. Purchase of SCBA with federal monies through several of the government grant programs requires that SCBA have CBRN approvals from NIOSH. In addition, the InterAgency Board for Equipment Standardization and Interoperability (the IAB) has established CBRN SCBA as the only qualified SCBA in its Standardized Equipment List (SEL). This SEL further provides detailed recommendations for first responder PPE. While NFPA 1500 provides requirements for fire departments, it does not provide requirements for non-fire based emergency responders. NFPA 1981, Standard for Open-Circuit Self-Contained Breathing Apparatus for Emergency Services, does provide SCBA requirements for any emergency services organization that needs protection from IDLH atmospheres. IDLH protection can only be provided by SCBA. The shortsightedness of the TC in removing the CBRN requirement leaves law enforcement responders, emergency medical responders, non-fire based hazardous materials response teams, and the skilled trades emergency responders without CBRN respiratory protection. CBRN protection offers verification of enhanced protection for emergency responders which is not otherwise available. Without CBRN protection evaluation, no SCBA components are tested for permeation, penetration, corrosion resistance, or other detrimental effects from exposure to hazardous chemical warfare atmospheres. NIOSH benchmark testing of non-CBRN hardened NIOSH certified SCBA against CBRN agents demonstrated that CWA agents could cause catastrophic failures within minutes of exposure. A comment by a TC member (Birch) stated, “…it is proper at this point in time to not require CBRN is because although NIOSH and other agencies make/made a good point of testing SCBAs against the list of chemical agents, there are missing tests. There are no tests to show that SCBAs as manufactured now, when altered to meet CBRN requirements, are still resistant to the ‘normal’ atmospheres and chemical agents in which they are currently used.” NIOSH (Boord) countered with, “The selection of the test challenge agents for CBRN protection was based on a comprehensive review of available technical

1981-�4

Report on Comments F2006 — Copyright, NFPA NFPA 1981data and consultations with other government agencies (e.g., DOD, DOJ, DOE, etc.). Various chemical data lists were analyzed, including lists from the EPA, ATSDR, NFPA 1994, U.S. Army Center for Health Promotion and Preventative Medicine (USACHPPM) Technical Guide 244, and classified sources. This review established a total of 151 toxic industrial chemicals and chemical warfare agents (TIC-CWA) as potential candidates for challenge agents. The candidate agents were evaluated for permeation (molecularly diffusing through material) and penetration (seeping through interfacing components) characteristics as part of a review of their physical properties.” “This evaluation concluded that Sarin (GB) and Sulfur Mustard (HD) could be selected as the two representative agents for the penetration/permeation test for the complete listing of 151 CWA and TICs due to their physical properties and molecular structure.” “NIOSH is unaware of any data that indicates the CBRN respirators provide less protection against TICs than their industrial counterparts. The evaluation for CBRN protection provides verification and assurance that the component and material combinations in the approved SCBA configurations provide high resistance to permeation and penetration of hazardous atmospheres of toxic industrial chemicals and materials into the breathing air. This is of importance to all responders subject to extreme exposures to any hazardous industrial chemicals and materials.” The TCC, acting in accordance with 3.4.3(g) of the RGCPs, “Determining whether or not the TC has given due consideration to all evidence presented to it in connection with the preparation of its Report including all comments relating to negative votes” does not believe the TC gave full and appropriate review and due consideration to all the issues and, therefore has taken these actions. In addition to the action taken on 1981-59, the following comments will be affected by this change and, therefore, the following changes must be made to these comments 1981-34 In action #2, change action from “Reject” to “Accept” 1981-50 Change action from “Accept in Principle” to “Reject” 1981-51 Change action from “Accept in Principle” to “Reject” 1981-52 Change action from “Accept in Principle” to “Reject” 1981-53 Change action from “Accept in Principle” to “Reject” 1981-54 Change action from “Accept in Principle” to “Reject” 1981-55 Change action from “Accept in Principle” to “Reject” 1981-56 Change action from “Reject” to “Accept” 1981-57 Change action from “Accept in Principle” to “Reject” 1981-58 Change action from “Accept in Principle” to “Reject” 1981-84 Change action from “Accept in Principle” to “Reject” 1981-85 Change action from “Accept in Principle” to “Reject” 1981-86 Change action from “Accept in Principle” to “Reject” 1981-87 Change action from “Accept in Principle” to “Reject”Submitter: Beverly Gulledge, Scott Health & SafetyComment on Proposal No: 1981-�Recommendation: Requesting interchangeability requirements be deleted as follows: ● 4.1.3 Delete entire clause.Substantiation: Problem: Conflict in the requirement presented by NFPA 1981:�007 edition, F�006ROP and NIOSH requirements for approval of CBRN SCBA. Each organization requires the approval/certification of the other organization. ● Substantiation: NFPA 1981 F2006ROP, 42 CFR Part 84, NIOSH Standard Application Procedure, �8 December �001 Letter to All Respirator Manufacturers from NIOSH, nor the Safety Equipment Institute’s (SEI) Open-Circuit SCBA Program Manual reflects the NIOSH, NFPA and SEI representatives agreement, during NFPA Technical Committee meetings, to work together to solve the conflict in the approval and certification requirements presented by NFPA 1981 F�006ROP and the �8 December �001 Letter to All Respirator Manufacturers from NIOSH. ● Substantiation: No statement, comment, clarification, or revision of any published document pertaining to the approval and certification processes required of the NFPA SCBA manufacturers to obtain NFPA 1981 certification, or the NIOSH CBRN approval has been published. ● Reason: NFPA 1981:2007 edition, F2006 ROP clause 4.1.3 states, “SCBA that are certified as compliant with NFPA 1981 shall also be certified by NIOSH as a CBRN SCBA.” ● Reason: 28 December 2001 Letter to All Respirator Manufacturers from NIOSH states in the Summary of Requirement for Approval section, “�. Requirements for compliance of an SCBA to the National Fire Protection Association (NFPA) 1981. Certification by the NFPA demonstrates that the SCBA can meet the flame, heat, and other requirements for the NFPA 1981 that are important for protection against hazards that may be present for first responders to a terrorist incident.” Note: Supporting material is available for review at NFPA Headquarters.Committee Meeting Action: Accept in Principle See committee action on Comment 1981-59 (Log #16�).Committee Statement: While the committee does not agree with the submitters substantiation, the CBRN requirement is being deleted by the committee action on Comment 1981-59 (Log #16�).

____________________________________________________________1981-56 Log #1�0 FAE-RPE Final Action: Accept(4.1.3)____________________________________________________________TCC Action: The Technical Correlating Committee ACCEPTS this comment. The TCC carefully reviewed the issues regarding the CBRN requirements being deleted from the proposed 2008 edition of NFPA 1981, including those expressed in the negative ballots on this issue, and the verbal positions heard from TC and TCC members. In accordance with the Regulations Governing Committee Projects (RGCPs), the TCC is taking the action it deems necessary in accordance with its authority as defined in 3.4.2, and in 4.4.7.1: “…The TCC shall be permitted to choose between alternatives presented by the TCs or develop text, as it deems necessary, to achieve correlation, consistence, and the correction of errors and omissions...” The TCC was concerned that some TC members expressed the opinion that while they did see a need for CBRN SCBA in their organization, they didn’t believe that it was necessary throughout the country and that individual departments should make their own determination, and another opinion was that it would be wrong to make other departments pay so much more for their SCBA when they don’t foresee a need for them. There is no way that anyone can predict where a future CBRN event will occur in this country. The terrorist threat is a reality not only in larger metropolitan areas but also in smaller communities and rural areas where terrorists would seek to severely affect the economy or bring it to a halt. While we can and should prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. In the Committee process, all members come to the table with a bias and represent their sponsoring organization’s feelings, but the safety, well being, and protection of the emergency responders must be the goal and local issues should take a secondary position to the improvement of safety for the emergency responders performing in the hazardous environments. In regards to cost, some TC members argued the point that municipalities should have a choice in what SCBA they purchase. In opposition to this stance, one TC member (King) stated, “There is no way that anyone can predict where a future CBRN event will occur in this country. While we can (and should) prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. It is interesting to note that a couple of the first responders who voted against having mandatory CBRN compliant SCBA in this standard acknowledge that their own department insists on CBRN compliant SCBA when purchasing new equipment.” Another TC member (Rossos) stated, “I disagree with the committee’s action regarding CBRN; therefore I must vote in the negative. I believe it is our purpose and responsibility as members of the Committee to strive to design SCBA standards and codes where the end user has the highest level of protection possible. I realize as an end user, that we need to strike a balance between best protection and secondary effects such as comfort, size, weight, etc. and in some regards even economics. We were given no evidence of any of the above compromises to mandating CBRN on all SCBAs. The only thing that we know for sure is that the end user would have a higher level of protection with CBRN as opposed to without. Very few end users have a choice in this matter. Most choices are made by purchasing agents or administrators who often base their decisions on the minimum legal standard available for the lowest price. I believe our first and most important responsibility on this committee is to those who wear SCBA, not to who buys SCBA. Regretfully, when there was no cost involved or reduction in protection, we voted to give the choice to the buyer and not the user.” This was based on the fact that all SCBA manufacturers present at the TC ROC meeting stated that the increased cost of CBRN protection for SCBA was negligible (under $100) or none. Also, TC Chairman Reed responded, “The argument during ROC was that many parts of the country may not have a need for CBRN protection. Unfortunately, in the post 9/11 world, I think this is being unrealistic. While major metropolitan areas may be more likely targets of a terrorist event, we have already seen that the terrorists themselves may reside in small communities while they await their opportunity to strike. They may have the chemical, biological, or nuclear material in their possession, making the possibility of exposure greater for even small, rural areas. But terrorist attacks aside, CBRN-certified SCBA offers greater protection for the fire fighter for a very minimal cost. If this protection is not required by the standard, many jurisdictions will not specify this for their fire fighters.” To the issue about CBRN compliant SCBA are uncomfortable to wear, this appears to be limited to one or two manufacturers’ chosen materials and the reality appears to be that first responders using

1981-�5

Report on Comments F2006 — Copyright, NFPA NFPA 1981CBRN SCBA are not reporting any significant difference relating to the comfort of the equipment and other manufacturers report no complaints from organizations who have purchased and use CBRN SCBA. And to the issue of CBRN compliant SCBA will not be as durable, there appears to be no reason to believe that CBRN compliant SCBA are any less durable than the non-CBRN compliant products on the market today and NIOSH has not received any complaints or identified any durability problems of CBRN SCBA over “regular” SCBA. To the issue of correlation and consistence, the TCC notes that other standards do require CBRN SCBA including NFPA 1500, Standard on Fire Department Occupational Safety and Health Program, 7.11.1.1 of the 2007 edition; 42 CFR 84, Respiratory Protective Devices, and the Statement of Standard for NIOSH CBRN SCBA Testing; and Section 5(A)(1) of the Occupational Safety and Health Act. The TCC believes that lack of correlation with these standards and regulations causes a strong potential decrease of safety for emergency responders due to purchasers believing that as NFPA 1981 is silent on CBRN requirements they do not to have that protection. The TCC further notes that the Department of Homeland Security (DHS) has formally adopted the NIOSH Statement of Standard for NIOSH CBRN SCBA Testing as one of the standards for first responder PPE. Only SCBA that have been approved by NIOSH as CBRN SCBA, which also requires certification to NFPA 1981, can be listed in the Authorized Equipment List (AEL), established by the DHS Office of Grants and Training as the list of recommended equipment for emergency responders. Purchase of SCBA with federal monies through several of the government grant programs requires that SCBA have CBRN approvals from NIOSH. In addition, the InterAgency Board for Equipment Standardization and Interoperability (the IAB) has established CBRN SCBA as the only qualified SCBA in its Standardized Equipment List (SEL). This SEL further provides detailed recommendations for first responder PPE. While NFPA 1500 provides requirements for fire departments, it does not provide requirements for non-fire based emergency responders. NFPA 1981, Standard for Open-Circuit Self-Contained Breathing Apparatus for Emergency Services, does provide SCBA requirements for any emergency services organization that needs protection from IDLH atmospheres. IDLH protection can only be provided by SCBA. The shortsightedness of the TC in removing the CBRN requirement leaves law enforcement responders, emergency medical responders, non-fire based hazardous materials response teams, and the skilled trades emergency responders without CBRN respiratory protection. CBRN protection offers verification of enhanced protection for emergency responders which is not otherwise available. Without CBRN protection evaluation, no SCBA components are tested for permeation, penetration, corrosion resistance, or other detrimental effects from exposure to hazardous chemical warfare atmospheres. NIOSH benchmark testing of non-CBRN hardened NIOSH certified SCBA against CBRN agents demonstrated that CWA agents could cause catastrophic failures within minutes of exposure. A comment by a TC member (Birch) stated, “…it is proper at this point in time to not require CBRN is because although NIOSH and other agencies make/made a good point of testing SCBAs against the list of chemical agents, there are missing tests. There are no tests to show that SCBAs as manufactured now, when altered to meet CBRN requirements, are still resistant to the ‘normal’ atmospheres and chemical agents in which they are currently used.” NIOSH (Boord) countered with, “The selection of the test challenge agents for CBRN protection was based on a comprehensive review of available technical data and consultations with other government agencies (e.g., DOD, DOJ, DOE, etc.). Various chemical data lists were analyzed, including lists from the EPA, ATSDR, NFPA 1994, U.S. Army Center for Health Promotion and Preventative Medicine (USACHPPM) Technical Guide 244, and classified sources. This review established a total of 151 toxic industrial chemicals and chemical warfare agents (TIC-CWA) as potential candidates for challenge agents. The candidate agents were evaluated for permeation (molecularly diffusing through material) and penetration (seeping through interfacing components) characteristics as part of a review of their physical properties.” “This evaluation concluded that Sarin (GB) and Sulfur Mustard (HD) could be selected as the two representative agents for the penetration/permeation test for the complete listing of 151 CWA and TICs due to their physical properties and molecular structure.” “NIOSH is unaware of any data that indicates the CBRN respirators provide less protection against TICs than their industrial counterparts. The evaluation for CBRN protection provides verification and assurance that the component and material combinations in the approved SCBA configurations provide high resistance to permeation and penetration of hazardous atmospheres of toxic industrial chemicals and materials into the breathing air. This is of importance to all responders subject to extreme exposures to any hazardous industrial chemicals and materials.”

The TCC, acting in accordance with 3.4.3(g) of the RGCPs, “Determining whether or not the TC has given due consideration to all evidence presented to it in connection with the preparation of its Report including all comments relating to negative votes” does not believe the TC gave full and appropriate review and due consideration to all the issues and, therefore has taken these actions. In addition to the action taken on 1981-59, the following comments will be affected by this change and, therefore, the following changes must be made to these comments 1981-34 In action #2, change action from “Reject” to “Accept” 1981-50 Change action from “Accept in Principle” to “Reject” 1981-51 Change action from “Accept in Principle” to “Reject” 1981-52 Change action from “Accept in Principle” to “Reject” 1981-53 Change action from “Accept in Principle” to “Reject” 1981-54 Change action from “Accept in Principle” to “Reject” 1981-55 Change action from “Accept in Principle” to “Reject” 1981-56 Change action from “Reject” to “Accept” 1981-57 Change action from “Accept in Principle” to “Reject” 1981-58 Change action from “Accept in Principle” to “Reject” 1981-84 Change action from “Accept in Principle” to “Reject” 1981-85 Change action from “Accept in Principle” to “Reject” 1981-86 Change action from “Accept in Principle” to “Reject” 1981-87 Change action from “Accept in Principle” to “Reject”Submitter: Stephen R. Sanders, Safety Equipment Institute (SEI)Comment on Proposal No: 1981-�Recommendation: Revise text to read: 4.1.3 SCBA and accessories that are certified as compliant with NFPA 1981 shall also be certified by NIOSH as a CBRN SCBA. Substantiation: The term “accessories” was added to this paragraph to clarify the requirement that accessories are also included for certification by NIOSH.Committee Meeting Action: RejectCommittee Statement: See committee action on Comment 1981-59 (Log #16�).

____________________________________________________________1981-57 Log #147 FAE-RPE Final Action: Reject(4.1.3)____________________________________________________________TCC Action: The Technical Correlating Committee REJECTS this comment. The TCC carefully reviewed the issues regarding the CBRN requirements being deleted from the proposed 2008 edition of NFPA 1981, including those expressed in the negative ballots on this issue, and the verbal positions heard from TC and TCC members. In accordance with the Regulations Governing Committee Projects (RGCPs), the TCC is taking the action it deems necessary in accordance with its authority as defined in 3.4.2, and in 4.4.7.1: “…The TCC shall be permitted to choose between alternatives presented by the TCs or develop text, as it deems necessary, to achieve correlation, consistence, and the correction of errors and omissions...” The TCC was concerned that some TC members expressed the opinion that while they did see a need for CBRN SCBA in their organization, they didn’t believe that it was necessary throughout the country and that individual departments should make their own determination, and another opinion was that it would be wrong to make other departments pay so much more for their SCBA when they don’t foresee a need for them. There is no way that anyone can predict where a future CBRN event will occur in this country. The terrorist threat is a reality not only in larger metropolitan areas but also in smaller communities and rural areas where terrorists would seek to severely affect the economy or bring it to a halt. While we can and should prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. In the Committee process, all members come to the table with a bias and represent their sponsoring organization’s feelings, but the safety, well being, and protection of the emergency responders must be the goal and local issues should take a secondary position to the improvement of safety for the emergency responders performing in the hazardous environments. In regards to cost, some TC members argued the point that municipalities should have a choice in what SCBA they purchase. In opposition to this stance, one TC member (King) stated, “There is no way that anyone can predict where a future CBRN event will occur in this country. While we can (and should) prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. It is interesting to note that a couple of the first responders who voted against having mandatory CBRN compliant SCBA in this standard acknowledge that their own department insists on CBRN compliant SCBA when purchasing new equipment.”

1981-�6

Report on Comments F2006 — Copyright, NFPA NFPA 1981 Another TC member (Rossos) stated, “I disagree with the committee’s action regarding CBRN; therefore I must vote in the negative. I believe it is our purpose and responsibility as members of the Committee to strive to design SCBA standards and codes where the end user has the highest level of protection possible. I realize as an end user, that we need to strike a balance between best protection and secondary effects such as comfort, size, weight, etc. and in some regards even economics. We were given no evidence of any of the above compromises to mandating CBRN on all SCBAs. The only thing that we know for sure is that the end user would have a higher level of protection with CBRN as opposed to without. Very few end users have a choice in this matter. Most choices are made by purchasing agents or administrators who often base their decisions on the minimum legal standard available for the lowest price. I believe our first and most important responsibility on this committee is to those who wear SCBA, not to who buys SCBA. Regretfully, when there was no cost involved or reduction in protection, we voted to give the choice to the buyer and not the user.” This was based on the fact that all SCBA manufacturers present at the TC ROC meeting stated that the increased cost of CBRN protection for SCBA was negligible (under $100) or none. Also, TC Chairman Reed responded, “The argument during ROC was that many parts of the country may not have a need for CBRN protection. Unfortunately, in the post 9/11 world, I think this is being unrealistic. While major metropolitan areas may be more likely targets of a terrorist event, we have already seen that the terrorists themselves may reside in small communities while they await their opportunity to strike. They may have the chemical, biological, or nuclear material in their possession, making the possibility of exposure greater for even small, rural areas. But terrorist attacks aside, CBRN-certified SCBA offers greater protection for the fire fighter for a very minimal cost. If this protection is not required by the standard, many jurisdictions will not specify this for their fire fighters.” To the issue about CBRN compliant SCBA are uncomfortable to wear, this appears to be limited to one or two manufacturers’ chosen materials and the reality appears to be that first responders using CBRN SCBA are not reporting any significant difference relating to the comfort of the equipment and other manufacturers report no complaints from organizations who have purchased and use CBRN SCBA. And to the issue of CBRN compliant SCBA will not be as durable, there appears to be no reason to believe that CBRN compliant SCBA are any less durable than the non-CBRN compliant products on the market today and NIOSH has not received any complaints or identified any durability problems of CBRN SCBA over “regular” SCBA. To the issue of correlation and consistence, the TCC notes that other standards do require CBRN SCBA including NFPA 1500, Standard on Fire Department Occupational Safety and Health Program, 7.11.1.1 of the 2007 edition; 42 CFR 84, Respiratory Protective Devices, and the Statement of Standard for NIOSH CBRN SCBA Testing; and Section 5(A)(1) of the Occupational Safety and Health Act. The TCC believes that lack of correlation with these standards and regulations causes a strong potential decrease of safety for emergency responders due to purchasers believing that as NFPA 1981 is silent on CBRN requirements they do not to have that protection. The TCC further notes that the Department of Homeland Security (DHS) has formally adopted the NIOSH Statement of Standard for NIOSH CBRN SCBA Testing as one of the standards for first responder PPE. Only SCBA that have been approved by NIOSH as CBRN SCBA, which also requires certification to NFPA 1981, can be listed in the Authorized Equipment List (AEL), established by the DHS Office of Grants and Training as the list of recommended equipment for emergency responders. Purchase of SCBA with federal monies through several of the government grant programs requires that SCBA have CBRN approvals from NIOSH. In addition, the InterAgency Board for Equipment Standardization and Interoperability (the IAB) has established CBRN SCBA as the only qualified SCBA in its Standardized Equipment List (SEL). This SEL further provides detailed recommendations for first responder PPE. While NFPA 1500 provides requirements for fire departments, it does not provide requirements for non-fire based emergency responders. NFPA 1981, Standard for Open-Circuit Self-Contained Breathing Apparatus for Emergency Services, does provide SCBA requirements for any emergency services organization that needs protection from IDLH atmospheres. IDLH protection can only be provided by SCBA. The shortsightedness of the TC in removing the CBRN requirement leaves law enforcement responders, emergency medical responders, non-fire based hazardous materials response teams, and the skilled trades emergency responders without CBRN respiratory protection. CBRN protection offers verification of enhanced protection for emergency responders which is not otherwise available. Without CBRN protection evaluation, no SCBA components are tested for permeation, penetration, corrosion resistance, or other detrimental effects from exposure to hazardous chemical warfare atmospheres.

NIOSH benchmark testing of non-CBRN hardened NIOSH certified SCBA against CBRN agents demonstrated that CWA agents could cause catastrophic failures within minutes of exposure. A comment by a TC member (Birch) stated, “…it is proper at this point in time to not require CBRN is because although NIOSH and other agencies make/made a good point of testing SCBAs against the list of chemical agents, there are missing tests. There are no tests to show that SCBAs as manufactured now, when altered to meet CBRN requirements, are still resistant to the ‘normal’ atmospheres and chemical agents in which they are currently used.” NIOSH (Boord) countered with, “The selection of the test challenge agents for CBRN protection was based on a comprehensive review of available technical data and consultations with other government agencies (e.g., DOD, DOJ, DOE, etc.). Various chemical data lists were analyzed, including lists from the EPA, ATSDR, NFPA 1994, U.S. Army Center for Health Promotion and Preventative Medicine (USACHPPM) Technical Guide 244, and classified sources. This review established a total of 151 toxic industrial chemicals and chemical warfare agents (TIC-CWA) as potential candidates for challenge agents. The candidate agents were evaluated for permeation (molecularly diffusing through material) and penetration (seeping through interfacing components) characteristics as part of a review of their physical properties.” “This evaluation concluded that Sarin (GB) and Sulfur Mustard (HD) could be selected as the two representative agents for the penetration/permeation test for the complete listing of 151 CWA and TICs due to their physical properties and molecular structure.” “NIOSH is unaware of any data that indicates the CBRN respirators provide less protection against TICs than their industrial counterparts. The evaluation for CBRN protection provides verification and assurance that the component and material combinations in the approved SCBA configurations provide high resistance to permeation and penetration of hazardous atmospheres of toxic industrial chemicals and materials into the breathing air. This is of importance to all responders subject to extreme exposures to any hazardous industrial chemicals and materials.” The TCC, acting in accordance with 3.4.3(g) of the RGCPs, “Determining whether or not the TC has given due consideration to all evidence presented to it in connection with the preparation of its Report including all comments relating to negative votes” does not believe the TC gave full and appropriate review and due consideration to all the issues and, therefore has taken these actions. In addition to the action taken on 1981-59, the following comments will be affected by this change and, therefore, the following changes must be made to these comments 1981-34 In action #2, change action from “Reject” to “Accept” 1981-50 Change action from “Accept in Principle” to “Reject” 1981-51 Change action from “Accept in Principle” to “Reject” 1981-52 Change action from “Accept in Principle” to “Reject” 1981-53 Change action from “Accept in Principle” to “Reject” 1981-54 Change action from “Accept in Principle” to “Reject” 1981-55 Change action from “Accept in Principle” to “Reject” 1981-56 Change action from “Reject” to “Accept” 1981-57 Change action from “Accept in Principle” to “Reject” 1981-58 Change action from “Accept in Principle” to “Reject” 1981-84 Change action from “Accept in Principle” to “Reject” 1981-85 Change action from “Accept in Principle” to “Reject” 1981-86 Change action from “Accept in Principle” to “Reject” 1981-87 Change action from “Accept in Principle” to “Reject”Submitter: Steven H. Weinstein, SurvivairComment on Proposal No: 1981-�Recommendation: Delete 4.1.�.Substantiation: This requirement is unnecessary for most fire departments. The risk of a terrorist attack in a small, rural town is virtually nonexistent. Fire departments in such areas gain nothing by having CBRN-certified SCBAs, and they will lose important features such as silicone facepieces and some of the rugged plastic materials in use today. All departments now have the choice of purchasing either CBRN or non-CBRN SCBAs. Their hazard risk assessment determines what they need to purchase. The individual fire department should still have the right to make that choice when purchasing NFPA compliant SCBAs. One of the reasons that this requirement was added to the standard was to enable NIOSH to deal with cylinder interoperability certification issues through the NIOSH CBRN module. If the requirement for cylinder interoperability is deleted from the proposed NFPA 1981, �007 edition, the major impetus to have a CBRN certification requirement is eliminated.Committee Meeting Action: Accept in Principle See committee action on Comment 1981-59 (Log #16�).Committee Statement: While the committee does not agree with the submitters substantiation, the CBRN requirement is being deleted by the committee action on Comment 1981-59 (Log #16�).

1981-�7

Report on Comments F2006 — Copyright, NFPA NFPA 1981____________________________________________________________1981-58 Log #�44 FAE-RPE Final Action: Reject(4.1.3, 4.1.10.12, and 6.5.1)____________________________________________________________TCC Action: The Technical Correlating Committee REJECTS this comment. The TCC carefully reviewed the issues regarding the CBRN requirements being deleted from the proposed 2008 edition of NFPA 1981, including those expressed in the negative ballots on this issue, and the verbal positions heard from TC and TCC members. In accordance with the Regulations Governing Committee Projects (RGCPs), the TCC is taking the action it deems necessary in accordance with its authority as defined in 3.4.2, and in 4.4.7.1: “…The TCC shall be permitted to choose between alternatives presented by the TCs or develop text, as it deems necessary, to achieve correlation, consistence, and the correction of errors and omissions...” The TCC was concerned that some TC members expressed the opinion that while they did see a need for CBRN SCBA in their organization, they didn’t believe that it was necessary throughout the country and that individual departments should make their own determination, and another opinion was that it would be wrong to make other departments pay so much more for their SCBA when they don’t foresee a need for them. There is no way that anyone can predict where a future CBRN event will occur in this country. The terrorist threat is a reality not only in larger metropolitan areas but also in smaller communities and rural areas where terrorists would seek to severely affect the economy or bring it to a halt. While we can and should prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. In the Committee process, all members come to the table with a bias and represent their sponsoring organization’s feelings, but the safety, well being, and protection of the emergency responders must be the goal and local issues should take a secondary position to the improvement of safety for the emergency responders performing in the hazardous environments. In regards to cost, some TC members argued the point that municipalities should have a choice in what SCBA they purchase. In opposition to this stance, one TC member (King) stated, “There is no way that anyone can predict where a future CBRN event will occur in this country. While we can (and should) prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. It is interesting to note that a couple of the first responders who voted against having mandatory CBRN compliant SCBA in this standard acknowledge that their own department insists on CBRN compliant SCBA when purchasing new equipment.” Another TC member (Rossos) stated, “I disagree with the committee’s action regarding CBRN; therefore I must vote in the negative. I believe it is our purpose and responsibility as members of the Committee to strive to design SCBA standards and codes where the end user has the highest level of protection possible. I realize as an end user, that we need to strike a balance between best protection and secondary effects such as comfort, size, weight, etc. and in some regards even economics. We were given no evidence of any of the above compromises to mandating CBRN on all SCBAs. The only thing that we know for sure is that the end user would have a higher level of protection with CBRN as opposed to without. Very few end users have a choice in this matter. Most choices are made by purchasing agents or administrators who often base their decisions on the minimum legal standard available for the lowest price. I believe our first and most important responsibility on this committee is to those who wear SCBA, not to who buys SCBA. Regretfully, when there was no cost involved or reduction in protection, we voted to give the choice to the buyer and not the user.” This was based on the fact that all SCBA manufacturers present at the TC ROC meeting stated that the increased cost of CBRN protection for SCBA was negligible (under $100) or none. Also, TC Chairman Reed responded, “The argument during ROC was that many parts of the country may not have a need for CBRN protection. Unfortunately, in the post 9/11 world, I think this is being unrealistic. While major metropolitan areas may be more likely targets of a terrorist event, we have already seen that the terrorists themselves may reside in small communities while they await their opportunity to strike. They may have the chemical, biological, or nuclear material in their possession, making the possibility of exposure greater for even small, rural areas. But terrorist attacks aside, CBRN-certified SCBA offers greater protection for the fire fighter for a very minimal cost. If this protection is not required by the standard, many jurisdictions will not specify this for their fire fighters.” To the issue about CBRN compliant SCBA are uncomfortable to wear, this appears to be limited to one or two manufacturers’ chosen materials and the reality appears to be that first responders using

CBRN SCBA are not reporting any significant difference relating to the comfort of the equipment and other manufacturers report no complaints from organizations who have purchased and use CBRN SCBA. And to the issue of CBRN compliant SCBA will not be as durable, there appears to be no reason to believe that CBRN compliant SCBA are any less durable than the non-CBRN compliant products on the market today and NIOSH has not received any complaints or identified any durability problems of CBRN SCBA over “regular” SCBA. To the issue of correlation and consistence, the TCC notes that other standards do require CBRN SCBA including NFPA 1500, Standard on Fire Department Occupational Safety and Health Program, 7.11.1.1 of the 2007 edition; 42 CFR 84, Respiratory Protective Devices, and the Statement of Standard for NIOSH CBRN SCBA Testing; and Section 5(A)(1) of the Occupational Safety and Health Act. The TCC believes that lack of correlation with these standards and regulations causes a strong potential decrease of safety for emergency responders due to purchasers believing that as NFPA 1981 is silent on CBRN requirements they do not to have that protection. The TCC further notes that the Department of Homeland Security (DHS) has formally adopted the NIOSH Statement of Standard for NIOSH CBRN SCBA Testing as one of the standards for first responder PPE. Only SCBA that have been approved by NIOSH as CBRN SCBA, which also requires certification to NFPA 1981, can be listed in the Authorized Equipment List (AEL), established by the DHS Office of Grants and Training as the list of recommended equipment for emergency responders. Purchase of SCBA with federal monies through several of the government grant programs requires that SCBA have CBRN approvals from NIOSH. In addition, the InterAgency Board for Equipment Standardization and Interoperability (the IAB) has established CBRN SCBA as the only qualified SCBA in its Standardized Equipment List (SEL). This SEL further provides detailed recommendations for first responder PPE. While NFPA 1500 provides requirements for fire departments, it does not provide requirements for non-fire based emergency responders. NFPA 1981, Standard for Open-Circuit Self-Contained Breathing Apparatus for Emergency Services, does provide SCBA requirements for any emergency services organization that needs protection from IDLH atmospheres. IDLH protection can only be provided by SCBA. The shortsightedness of the TC in removing the CBRN requirement leaves law enforcement responders, emergency medical responders, non-fire based hazardous materials response teams, and the skilled trades emergency responders without CBRN respiratory protection. CBRN protection offers verification of enhanced protection for emergency responders which is not otherwise available. Without CBRN protection evaluation, no SCBA components are tested for permeation, penetration, corrosion resistance, or other detrimental effects from exposure to hazardous chemical warfare atmospheres. NIOSH benchmark testing of non-CBRN hardened NIOSH certified SCBA against CBRN agents demonstrated that CWA agents could cause catastrophic failures within minutes of exposure. A comment by a TC member (Birch) stated, “…it is proper at this point in time to not require CBRN is because although NIOSH and other agencies make/made a good point of testing SCBAs against the list of chemical agents, there are missing tests. There are no tests to show that SCBAs as manufactured now, when altered to meet CBRN requirements, are still resistant to the ‘normal’ atmospheres and chemical agents in which they are currently used.” NIOSH (Boord) countered with, “The selection of the test challenge agents for CBRN protection was based on a comprehensive review of available technical data and consultations with other government agencies (e.g., DOD, DOJ, DOE, etc.). Various chemical data lists were analyzed, including lists from the EPA, ATSDR, NFPA 1994, U.S. Army Center for Health Promotion and Preventative Medicine (USACHPPM) Technical Guide 244, and classified sources. This review established a total of 151 toxic industrial chemicals and chemical warfare agents (TIC-CWA) as potential candidates for challenge agents. The candidate agents were evaluated for permeation (molecularly diffusing through material) and penetration (seeping through interfacing components) characteristics as part of a review of their physical properties.” “This evaluation concluded that Sarin (GB) and Sulfur Mustard (HD) could be selected as the two representative agents for the penetration/permeation test for the complete listing of 151 CWA and TICs due to their physical properties and molecular structure.” “NIOSH is unaware of any data that indicates the CBRN respirators provide less protection against TICs than their industrial counterparts. The evaluation for CBRN protection provides verification and assurance that the component and material combinations in the approved SCBA configurations provide high resistance to permeation and penetration of hazardous atmospheres of toxic industrial chemicals and materials into the breathing air. This is of importance to all responders subject to extreme exposures to any hazardous industrial chemicals and materials.”

1981-�8

Report on Comments F2006 — Copyright, NFPA NFPA 1981 The TCC, acting in accordance with 3.4.3(g) of the RGCPs, “Determining whether or not the TC has given due consideration to all evidence presented to it in connection with the preparation of its Report including all comments relating to negative votes” does not believe the TC gave full and appropriate review and due consideration to all the issues and, therefore has taken these actions. In addition to the action taken on 1981-59, the following comments will be affected by this change and, therefore, the following changes must be made to these comments 1981-34 In action #2, change action from “Reject” to “Accept” 1981-50 Change action from “Accept in Principle” to “Reject” 1981-51 Change action from “Accept in Principle” to “Reject” 1981-52 Change action from “Accept in Principle” to “Reject” 1981-53 Change action from “Accept in Principle” to “Reject” 1981-54 Change action from “Accept in Principle” to “Reject” 1981-55 Change action from “Accept in Principle” to “Reject” 1981-56 Change action from “Reject” to “Accept” 1981-57 Change action from “Accept in Principle” to “Reject” 1981-58 Change action from “Accept in Principle” to “Reject” 1981-84 Change action from “Accept in Principle” to “Reject” 1981-85 Change action from “Accept in Principle” to “Reject” 1981-86 Change action from “Accept in Principle” to “Reject” 1981-87 Change action from “Accept in Principle” to “Reject”Submitter: Daryl Osby, Los Angeles County Fire DepartmentComment on Proposal No: 1981-�Recommendation: 1. 4.1.� SCBA that are certified as certified as compliant with NFPA 1981 shall also be certified by NIOSH as a CBRN SCBA. �. 4.1.10.1� The certification Organization is not allowed to certify a SCBA to a previous standard. i.e., (�00�) �. 6.5.1 Interchangeable Breathing Air Cylinder and Valve Assembly Design Requirements.Substantiation: 1. Note: There are many Fire Departments in rural or non strategic locations that do not need CBRN approved SCBA’s. The increased cost of purchasing to this standard will not improve or safeguard their daily operations. The CBRN requirement should be required by estimated threat level. �. Note: If the SCBA meets the previous standard, a department should be able to decide which standard meets their individual needs and budget. NFPA should be a voice to increase fire fighter safety. One step forward is better than no change due to budgetary constraints. (If a department is using �0 year old SCBA’s, the purchase of NFPA �00� compliant SCBA’s is better than no purchase because they can not afford NFPA �007 compliant SCBA’s.) �. Note: The majority of air cylinders used in the United States are presently interchangeable with the exception of Drager and Scott SCBA’s. Since this issue was initially pushed from Department of Homeland Security, which is backing off the interoperability issue, this issue should be dropped at this time. This should include all language for other components of a SCBA that references interchangeability. NFPA has made no reference to the need for this change. NFPA has not cited any statistics that indicate the present system of using a standard CGA thread pattern for low and high pressure air cylinders has not met the needs of the fire service.Committee Meeting Action: Accept in Principle in Part 1. Accept in Principle. See committee action on Comment 1981-59 (Log #16�). �. Reject. �. Accept in Principle. See Committee Comment 1981-76 (Log #CC1).Committee Statement: 1. While the committee does not agree with the submitters substantiation, the CBRN requirement is being deleted by committee action on Comment 1981-59 (Log #16�). �. The previous edition of an NFPA standard ceases to exist on the effective date of the new edition. Certification organizations will not permit continued production and certification to non existent standards. �. See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-59 Log #16� FAE-RPE Final Action: Reject(4.1.3 and 6.1.3)____________________________________________________________TCC Action: The Technical Correlating Committee REJECTS this comment. The TCC carefully reviewed the issues regarding the CBRN requirements being deleted from the proposed 2008 edition of NFPA 1981, including those expressed in the negative ballots on this issue, and the verbal positions heard from TC and TCC members. In accordance with the Regulations Governing Committee Projects (RGCPs), the TCC is taking the action it deems necessary in accordance with its authority as defined in 3.4.2, and in 4.4.7.1: “…The TCC shall be permitted to choose between alternatives presented by the TCs or develop text, as it deems necessary, to achieve correlation, consistence, and the correction of errors and omissions...” The TCC was concerned that some TC members expressed the opinion that while they did see a need for CBRN SCBA in their

organization, they didn’t believe that it was necessary throughout the country and that individual departments should make their own determination, and another opinion was that it would be wrong to make other departments pay so much more for their SCBA when they don’t foresee a need for them. There is no way that anyone can predict where a future CBRN event will occur in this country. The terrorist threat is a reality not only in larger metropolitan areas but also in smaller communities and rural areas where terrorists would seek to severely affect the economy or bring it to a halt. While we can and should prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. In the Committee process, all members come to the table with a bias and represent their sponsoring organization’s feelings, but the safety, well being, and protection of the emergency responders must be the goal and local issues should take a secondary position to the improvement of safety for the emergency responders performing in the hazardous environments. In regards to cost, some TC members argued the point that municipalities should have a choice in what SCBA they purchase. In opposition to this stance, one TC member (King) stated, “There is no way that anyone can predict where a future CBRN event will occur in this country. While we can (and should) prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. It is interesting to note that a couple of the first responders who voted against having mandatory CBRN compliant SCBA in this standard acknowledge that their own department insists on CBRN compliant SCBA when purchasing new equipment.” Another TC member (Rossos) stated, “I disagree with the committee’s action regarding CBRN; therefore I must vote in the negative. I believe it is our purpose and responsibility as members of the Committee to strive to design SCBA standards and codes where the end user has the highest level of protection possible. I realize as an end user, that we need to strike a balance between best protection and secondary effects such as comfort, size, weight, etc. and in some regards even economics. We were given no evidence of any of the above compromises to mandating CBRN on all SCBAs. The only thing that we know for sure is that the end user would have a higher level of protection with CBRN as opposed to without. Very few end users have a choice in this matter. Most choices are made by purchasing agents or administrators who often base their decisions on the minimum legal standard available for the lowest price. I believe our first and most important responsibility on this committee is to those who wear SCBA, not to who buys SCBA. Regretfully, when there was no cost involved or reduction in protection, we voted to give the choice to the buyer and not the user.” This was based on the fact that all SCBA manufacturers present at the TC ROC meeting stated that the increased cost of CBRN protection for SCBA was negligible (under $100) or none. Also, TC Chairman Reed responded, “The argument during ROC was that many parts of the country may not have a need for CBRN protection. Unfortunately, in the post 9/11 world, I think this is being unrealistic. While major metropolitan areas may be more likely targets of a terrorist event, we have already seen that the terrorists themselves may reside in small communities while they await their opportunity to strike. They may have the chemical, biological, or nuclear material in their possession, making the possibility of exposure greater for even small, rural areas. But terrorist attacks aside, CBRN-certified SCBA offers greater protection for the fire fighter for a very minimal cost. If this protection is not required by the standard, many jurisdictions will not specify this for their fire fighters.” To the issue about CBRN compliant SCBA are uncomfortable to wear, this appears to be limited to one or two manufacturers’ chosen materials and the reality appears to be that first responders using CBRN SCBA are not reporting any significant difference relating to the comfort of the equipment and other manufacturers report no complaints from organizations who have purchased and use CBRN SCBA. And to the issue of CBRN compliant SCBA will not be as durable, there appears to be no reason to believe that CBRN compliant SCBA are any less durable than the non-CBRN compliant products on the market today and NIOSH has not received any complaints or identified any durability problems of CBRN SCBA over “regular” SCBA. To the issue of correlation and consistence, the TCC notes that other standards do require CBRN SCBA including NFPA 1500, Standard on Fire Department Occupational Safety and Health Program, 7.11.1.1 of the 2007 edition; 42 CFR 84, Respiratory Protective Devices, and the Statement of Standard for NIOSH CBRN SCBA Testing; and Section 5(A)(1) of the Occupational Safety and Health Act. The TCC believes that lack of correlation with these standards and regulations causes a strong potential decrease of safety for emergency responders

1981-�9

Report on Comments F2006 — Copyright, NFPA NFPA 1981due to purchasers believing that as NFPA 1981 is silent on CBRN requirements they do not to have that protection. The TCC further notes that the Department of Homeland Security (DHS) has formally adopted the NIOSH Statement of Standard for NIOSH CBRN SCBA Testing as one of the standards for first responder PPE. Only SCBA that have been approved by NIOSH as CBRN SCBA, which also requires certification to NFPA 1981, can be listed in the Authorized Equipment List (AEL), established by the DHS Office of Grants and Training as the list of recommended equipment for emergency responders. Purchase of SCBA with federal monies through several of the government grant programs requires that SCBA have CBRN approvals from NIOSH. In addition, the InterAgency Board for Equipment Standardization and Interoperability (the IAB) has established CBRN SCBA as the only qualified SCBA in its Standardized Equipment List (SEL). This SEL further provides detailed recommendations for first responder PPE. While NFPA 1500 provides requirements for fire departments, it does not provide requirements for non-fire based emergency responders. NFPA 1981, Standard for Open-Circuit Self-Contained Breathing Apparatus for Emergency Services, does provide SCBA requirements for any emergency services organization that needs protection from IDLH atmospheres. IDLH protection can only be provided by SCBA. The shortsightedness of the TC in removing the CBRN requirement leaves law enforcement responders, emergency medical responders, non-fire based hazardous materials response teams, and the skilled trades emergency responders without CBRN respiratory protection. CBRN protection offers verification of enhanced protection for emergency responders which is not otherwise available. Without CBRN protection evaluation, no SCBA components are tested for permeation, penetration, corrosion resistance, or other detrimental effects from exposure to hazardous chemical warfare atmospheres. NIOSH benchmark testing of non-CBRN hardened NIOSH certified SCBA against CBRN agents demonstrated that CWA agents could cause catastrophic failures within minutes of exposure. A comment by a TC member (Birch) stated, “…it is proper at this point in time to not require CBRN is because although NIOSH and other agencies make/made a good point of testing SCBAs against the list of chemical agents, there are missing tests. There are no tests to show that SCBAs as manufactured now, when altered to meet CBRN requirements, are still resistant to the ‘normal’ atmospheres and chemical agents in which they are currently used.” NIOSH (Boord) countered with, “The selection of the test challenge agents for CBRN protection was based on a comprehensive review of available technical data and consultations with other government agencies (e.g., DOD, DOJ, DOE, etc.). Various chemical data lists were analyzed, including lists from the EPA, ATSDR, NFPA 1994, U.S. Army Center for Health Promotion and Preventative Medicine (USACHPPM) Technical Guide 244, and classified sources. This review established a total of 151 toxic industrial chemicals and chemical warfare agents (TIC-CWA) as potential candidates for challenge agents. The candidate agents were evaluated for permeation (molecularly diffusing through material) and penetration (seeping through interfacing components) characteristics as part of a review of their physical properties.” “This evaluation concluded that Sarin (GB) and Sulfur Mustard (HD) could be selected as the two representative agents for the penetration/permeation test for the complete listing of 151 CWA and TICs due to their physical properties and molecular structure.” “NIOSH is unaware of any data that indicates the CBRN respirators provide less protection against TICs than their industrial counterparts. The evaluation for CBRN protection provides verification and assurance that the component and material combinations in the approved SCBA configurations provide high resistance to permeation and penetration of hazardous atmospheres of toxic industrial chemicals and materials into the breathing air. This is of importance to all responders subject to extreme exposures to any hazardous industrial chemicals and materials.” The TCC, acting in accordance with 3.4.3(g) of the RGCPs, “Determining whether or not the TC has given due consideration to all evidence presented to it in connection with the preparation of its Report including all comments relating to negative votes” does not believe the TC gave full and appropriate review and due consideration to all the issues and, therefore has taken these actions. In addition to the action taken on 1981-59, the following comments will be affected by this change and, therefore, the following changes must be made to these comments 1981-34 In action #2, change action from “Reject” to “Accept” 1981-50 Change action from “Accept in Principle” to “Reject” 1981-51 Change action from “Accept in Principle” to “Reject” 1981-52 Change action from “Accept in Principle” to “Reject” 1981-53 Change action from “Accept in Principle” to “Reject” 1981-54 Change action from “Accept in Principle” to “Reject” 1981-55 Change action from “Accept in Principle” to “Reject” 1981-56 Change action from “Reject” to “Accept” 1981-57 Change action from “Accept in Principle” to “Reject”

1981-58 Change action from “Accept in Principle” to “Reject” 1981-84 Change action from “Accept in Principle” to “Reject” 1981-85 Change action from “Accept in Principle” to “Reject” 1981-86 Change action from “Accept in Principle” to “Reject” 1981-87 Change action from “Accept in Principle” to “Reject”Submitter: Bruce A. Hefner, International Safety InstrumentsComment on Proposal No: 1981-�Recommendation: Remove CBRN requirement.Substantiation: The requirement to require the adoption of only CBRN certified SCBA is not substantiated by any universal fire service needs or desire. The decision to adopt a CBRN certified SCBA is a decision best determined by the local authority.Committee Meeting Action: Accept

____________________________________________________________1981-60 Log #�1� FAE-RPE Final Action: Accept(4.1.4)____________________________________________________________Submitter: Les Boord, NIOSHComment on Proposal No: 1981-�Recommendation: The last line of bullet 4.1.4 should reference �.�.�0.Substantiation: Incorrect bullet reference.Committee Meeting Action: Accept

____________________________________________________________1981-61 Log #1�1 FAE-RPE Final Action: Accept(4.1.4, 4.1.12, 4.2.7.1, 4.2.9, 4.2.12, 4.3.5, and 4.4.2)____________________________________________________________Submitter: Stephen R. Sanders, Safety Equipment Institute (SEI)Comment on Proposal No: 1981-�Recommendation: Revise text to read:

4.1.4 All SCBA that are labeled as being compliant with this standard shall meet or exceed all applicable requirements specified in this standard and shall be certified. This certification shall be in addition to, and shall not be construed to be the same as, the NIOSH certification as specifically defined in �.�.�9 �.�.�0.

4.1.12 The certification organization shall require manufacturers to remove all certification labels and product labels indicating compliance with the �00� edition of this standard from all SCBA that are under the control of the manufacturer on 1 March �00� �1 August �007. The certification organization shall verify this action is taken.

4.2.7.1 The certification organization shall require the manufacturer to have a safety alert and product recall system specified in Section 4.8, Manufacturers’ Safety Alert and Product Recall Systems, as part of the manufacturer’s quality assurance program.

4.2.9* The certification organization shall have a follow-up inspection program of the manufacturing facilities of the compliant product, with at least two random and unannounced visits per 1�-month period to verify the product’s continued compliance.

4.2.9.2 Sample product shall be inspected and tested by the certification organization to verify the product’s continued compliance. Sample product shall be evaluated by the certification organization to verify the product’s continued compliance in order to assure the materials, components, and manufacturing quality assurance systems are consistent with the materials, components and manufacturing quality assurance that were inspected and tested by the certification organization during initial and certification and recertification.

4.2.9.3 The certification organization shall be permitted to conduct specific testing to verify the product’s continued compliance.

4.2.9.4 For products, components, and materials where prior testing, judgment, and experience of the certification organization have shown results to be in jeopardy of not complying with this standard, the certification organization shall conduct more frequent testing of sample product, components, and materials acquired in accordance with 4.�.9.1 against the applicable requirements of this standard.

4.2.12 The certification organization shall be in a position to use legal means to protect the integrity of its name and label. The name and label shall be registered and legally defended.

4.3.5 Inspection by the certification organization shall include a review of all product labels to ensure that all required label attachments, compliance statements, certification statements, and other product information are at least as specified for the protective ensemble and ensemble elements SCBA in Section 5.1, Product Label Requirements.

4.4.2 Recertification shall include inspection and evaluation to all design requirements and testing to all performance requirements as required by 4.�.9 and 4.�.�1 4.�.1� on all manufacturer models and components. Substantiation: Revisions/additions to various paragraphs in Section 4 to align Section 4 with the TCC’s boilerplate wording for Section 4.Committee Meeting Action: Accept

1981-�0

Report on Comments F2006 — Copyright, NFPA NFPA 1981____________________________________________________________1981-6� Log #�50 FAE-RPE Final Action: Accept(4.1.7)____________________________________________________________Submitter: Daniel Gohlke, W. L. Gore & AssociatesComment on Proposal No: 1981-�Recommendation: Revise text to read as follows: 4.1.7 All compliant SCBA shall be listed by the certification organization. The listing shall uniquely identify the certified product, for example, by style, model number, or part number.Substantiation: A generic listing can be misrepresented to cover products and styles of products which are not certified. The labeling requirement in 4.1.7 is redundant with 4.1.4 and 4.1.9.Committee Meeting Action: Accept

____________________________________________________________1981-6� Log #11� FAE-RPE Final Action: Reject(4.1.10, 4.1.11, and 4.1.12)____________________________________________________________Submitter: Beverly Gulledge, Scott Health & SafetyComment on Proposal No: 1981-�Recommendation: Requesting interchangeability requirements be deleted as follows: ● 5.1.1 and an interchangeable breathing air cylinder product label. ● 5.1.1.2 Delete entire clause. ● 5.1.7 through 5.1.7.2 Delete all clauses. ● 5.2.4 Delete entire clause. ● 6.1.4 and an interchangeable SCBA cylinder and valve assembly. ● 6.5 through 6.5.5 Delete all clauses. ● Figure 6.5.1 Delete entire figure. ● 7.16 through 7.16.3 Delete all clauses. ● 8.23 through 8.23.6 Delete all clauses. ● 8.24 through 8.24.7 Delete all clauses. ● Table 24.4.2 Delete table. ● 8.25 through 8.25.6 Delete all clauses.Substantiation: Problem: No avenue to backward (previous editions of NFPA 1981) convertibility of NFPA SCBA interchangeable cylinders. The confusion this situation presents could be present each day and at each response as emergency service departments maintain a supply of two styles of cylinders for use with two styles of SCBA (interchangeable and non interchangeable). One emergency service department using NFPA 1981: �00� SCBA and NFPA 1981:�007 SCBA both from the same SCBA manufacturer would not have cylinder interchangeability within their own department. ● Substantiation: SCBA certified to previous editions (1992, 1997, or �00�) of NFPA 1981 would not maintain its NFPA certification if an interchangeability cylinder (�007) was attached. ● Substantiation: Manufacturers do not have the option of requesting certification to an obsolete edition of NFPA 1981. ● Substantiation: Certification Organizations do not have the option of certifying to an obsolete edition of NFPA 1981. ● Reason: 42 CFR Part 84 Section 84.30(b) states “The Institute will not issue certificates of approval for any respirator component or for any respirator subassembly.” ● Reason: NFPA 1981 F2006 ROP 4.1.10. “The certification organization shall not certify any SCBA to the �00� edition of this standard on or after the NFPA effective date for the �007 edition which is XX February �007.” ● Reason: NFPA 1981 F2006 ROP 4.1.11. “The certification organization shall not permit any manufacturer to label any SCBA as compliant with the �00� edition of this standard on or after �1 August �007.” ● Reason: NFPA 1981 F2006 ROP 4.1.12. “The certification organization shall require manufacturers to remove all certification labels and product labels indicating compliance with the �00� edition of this standard from all SCBA that are under the control of the manufacturer on 1 March �00�. The certification organization shall verify this action is taken.”Committee Meeting Action: RejectCommittee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-64 Log #1 FAE-RPE Final Action: Reject(4.1.10.4, 4.1.11, and 4.1.12)____________________________________________________________Submitter: David Hodson, Draeger Safety UK Ltd.Comment on Proposal No: 1981-1Recommendation: For 1981 ROP �007, change dates in the following Sections: 4.1.10 to Sept �008 4.1.11 to Dec �008 4.1.1� to Dec �008Substantiation: Time Line Justification It is the goal of all SCBA manufacturers and PASS manufacturers to produce product that is compliant to the current standards but meets the needs of the end user, the Fire Service.

Product must be robust and functional at the extremes of use conditions and at the same time be user friendly. The use of new technologies and new material which improved performance and effectiveness is also a common goal for all. Design, internal test programs, long-term testing and extended-life testing takes time to complete. Field trials form an important part of a manufactures design and development programs. To ensure the functional needs and safety of the end user are not compromised Draeger requires time lines as indicated.

Time lines NFPA 1981-�007 Dates

TC acceptance of ROP September �005TCC acceptance of ROP October �005Public Comment Period for ROP December �005 to March �006TCC acceptance of ROC October �006Standards Council acceptance of NFPA 1981-�007

January �007

Publication of NFPA 1981-�007 February �007Manufacturers initial development March �006 to March �007Manufacturers final development November �006 to March �007Acceptance of applications for NFPA and CBRN approval

April �007 to July �007

Approval time for NFPA and CBRN April �007 to September �008

Issue approval for NFPA and CBRN September �008Confirm no more �00� units being labeled

December �008

Committee Meeting Action: RejectCommittee Statement: 4.1.10 The NFPA effective date for the standard is set by the Standards Council and can not be altered by the committee. 4.1.11 See committee action on Comment 1981-65 (Log #1��) and 1981-66 (Log #16�). 4.1.1� See committee action on Comment 1981-67 (Log #161).

____________________________________________________________1981-65 Log #1�� FAE-RPE Final Action: Accept(4.1.11)____________________________________________________________Submitter: Stephen R. Sanders, Safety Equipment Institute (SEI)Comment on Proposal No: 1981-�Recommendation: Revise text to read: 4.1.11 The certification organization shall not permit any manufacturer to label any SCBA as compliant with the �00� edition of this standard on or after the NFPA effective date which is XX February �007., except when replacement labels or replacement components that bear the certification organization’s label are required.Substantiation: The proposed language would allow damaged labels, or replacement SCBA parts bearing the label (i.e., backframe), to be replaced. This is important for users and authorities (such as the Texas State Fire Commission) to verify the standard to which the device was originally certified.Committee Meeting Action: Accept

____________________________________________________________1981-66 Log #16� FAE-RPE Final Action: Reject(4.1.11)____________________________________________________________Submitter: Bruce A. Hefner, International Safety InstrumentsComment on Proposal No: 1981-�Recommendation: Change �1 August �007 to �8 February �008.Substantiation: To provide adequate time line to develop and field test modifications to SCBA’s to meet �007 standard.Committee Meeting Action: RejectCommittee Statement: The NFPA effective date of the standard is set by the Standards Council and can not be altered by the committee.

____________________________________________________________1981-67 Log #161 FAE-RPE Final Action: Accept in Principle(4.1.12)____________________________________________________________Submitter: John Morris, International Safety Instruments, Inc.Comment on Proposal No: 1981-�Recommendation: Change 1 March �00� to 1 March �008.Substantiation: Correction to text, allow adequate development and field testing time for �007 standard before stopping production of �00� edition SCBA’s.

1981-�1

Report on Comments F2006 — Copyright, NFPA NFPA 1981Committee Meeting Action: Accept in Principle Change 1 March �00� to read: �1 August �007.Committee Statement: The committee corrected the date to reflect the six month grace period permitted following the NFPA effective date.

____________________________________________________________1981-68 Log #4� FAE-RPE Final Action: Accept(4.2.12)____________________________________________________________Submitter: Robert Sell, Draeger Safety, Inc.Comment on Proposal No: 1981-�Recommendation: This section is incomplete, revise to read: The certification organization shall be in a position to use legal means to protect the integrity of its name and label. The name and label shall be registered and legally defended.Substantiation: The section should read the same as what appears in NFPA 1981, �00� edition.Committee Meeting Action: AcceptCommittee Statement: See committee action on Comment 1981-61 (Log #1�1).

____________________________________________________________1981-69 Log #�1� FAE-RPE Final Action: Accept in Principle(4.2.12)____________________________________________________________Submitter: Les Boord, NIOSHComment on Proposal No: 1981-�Recommendation: The text in bullet 4.�.1� is incomplete.Substantiation: Complete text.Committee Meeting Action: Accept in Principle See committee action on Comment 1981-154 (Log #�1).Committee Statement: See committee action on Comment 1981-154 (Log #�1).

____________________________________________________________1981-70 Log #61 FAE-RPE Final Action: Accept in Principle in Part(Table 4.3.9)____________________________________________________________Submitter: Karen Lehtonen, Lion ApparelComment on Proposal No: 1981-�Recommendation: Add to Table 4.�.9 the following tests: 8.�� Interchangeable Cylinder Valve Flow Rate Test. 8.�4 Breathing Air Cylinder and Valve Assembly Retention Test. 8.�5 Cylinder Connections Accessibility Test. 8.�6 Immersion/Leakage Test.Substantiation: These tests should be included in the test series table as there is currently no mention of these tests in the inspection and testing section.Committee Meeting Action: Accept in Principle in Part 1. Reject. �. Accept. 4. Accept.Committee Statement: 1. See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-71 Log #1�� FAE-RPE Final Action: Reject(Table 4.3.9, 4.3.11, and 4.3.19)____________________________________________________________Submitter: Stephen R. Sanders, Safety Equipment Institute (SEI)Comment on Proposal No: 1981-�Recommendation: Revise text to read: Revise Table 4.�.9 Test Series, as follows: In the Category C column, insert “Breathing Air Cylinder and Valve Assembly Retention (Section 8.�4)” and then “Cylinder Connection Accessibility (Section 8.�5)” after the “Air Flow Test (Section 8.1)”. In the Category E column, delete “HUD Liquid Splash Resistance (Section 8.17).” Insert “Immersion Leakage (Section 8.�6)” after the “Wiring Connection Performance (Section 8.15)”. In the Category F column, insert “Interchangeable Cylinder Valve Assembly Flow Rate (Section 8.��)” after “Facepiece Lens Abrasion Resistance (Section 8.9)”.

4.3.11 SCBA fabric, thread, and lens and cylinder valve assembly components shall be initially tested for certification and shall meet the performance requirements of one test series of Category F, as specified in Table 4.�.9. SCBA component testing in Category F shall be conducted on test specimens as specified in each respective test method.

4.3.19 SCBA fabric, thread, and lens and cylinder valve assembly components shall be tested and shall meet the performance requirements of one test series of Category F, as specified in Table 4.�.9, every fifth year from the date of the initial certification testing specified in 4.�.11. SCBA component testing in Category F shall be conducted on test specimens as specified in each respective test method.Substantiation: Revisions to the Test Series Table to account for all of the proposed new tests added to NFPA 1981.

Please note that the existing HUD Liquid Splash Resistance Test has been deleted and replaced with the new Immersion Leakage Test, as the Immersion Leakage Test can be considered to be the worst case scenario for determining water ingress into electronic components (including HUD). The deletion of the HUD Liquid Splash Resistance Test from NFPA 1981-�007 is covered under a separate comment. Additional clarification to 4.�.11 and 4.�.19 resulting from the revision(s) to the test series table.Committee Meeting Action: RejectCommittee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-7� Log #4� FAE-RPE Final Action: Accept(4.4.2)____________________________________________________________Submitter: Robert Sell, Draeger Safety, Inc.Comment on Proposal No: 1981-�Recommendation: Revise text to read: Recertification shall include inspection and evaluation to all design requirements and testing to all performance requirements as required by 4.�.9 and 4.�.�1 4.�.8 and 4.�.1� on all manufacturer models and components.Substantiation: Incorrect references to 4.�.9 and 4.�.�1 were from NFPA 1981, �00� edition and during this revision those sections have changed to the new ones indicated.Committee Meeting Action: Accept

____________________________________________________________1981-7� Log #6� FAE-RPE Final Action: Reject(4.4.2)____________________________________________________________Submitter: Karen Lehtonen, Lion ApparelComment on Proposal No: 1981-�Recommendation: Revise text to read: Recertification shall include inspection and evaluation to all design requirements and testing to all performance requirements as required by 4.�.9 and 4.�.�1 4.�.�� on all manufacturer’s models and components.Substantiation: I do not believe the reference to 4.�.�1 is the correct reference paragraph. It is unclear if the additional reference is needed or if the change in reference to 4.�.�� is the reference of intention.Committee Meeting Action: RejectCommittee Statement: The recommended paragraph references are not correct. See committee action on Comment 1981-7� (Log #4�).

____________________________________________________________1981-74 Log #9� FAE-RPE Final Action: Accept(4.6, 4.7, and 4.8)____________________________________________________________Submitter: Ray F. Reed, Dallas Fire-RescueComment on Proposal No: 1981-�Recommendation: Revise text to read as follows: 4.6 Hazards Involving Compliant Product. 4.6.� Where a report of a hazard involved with a compliant product is received by the certification organization, the certification organization shall contact NIOSH/NPPTL and the validity of the report shall be investigated, following the procedures established by NIOSH/NPPTL. 4.6.4 Where a specific hazard is identified, the determination of the appropriate action for the certification organization and the manufacturer to undertake shall take into consideration the severity of the hazard and its consequences to the safety and health or users. 4.6.5 Where it is established that a hazard is involved with a compliant product, the certification organization in coordination with NIOSH/NPPTL shall determine the scope of the hazard including products, model numbers, serial numbers, factory production facilities, production runs and quantities involved. 4.6.6 The certification organization’s investigation shall include, but not be limited to, the extent and scope of the problem as it might apply to other compliant product or compliant product components manufactured by other manufacturers or certified by other certification organizations. 4.6.7 The certification organization in coordination with NIOSH/NPPTL shall also investigate reports of a hazard where compliant product is gaining widespread use in applications not foreseen when the standard was written, such applications in turn being ones for which the product was not certified, and no specific scope of application has been provided in the standard, and no limiting scope of application was provided by the manufacturer in written material accompanying the compliant product at the point of sale. 4.6.8 The certification organization in coordination with NIOSH/NPPTL shall require the manufacturer of the compliant product, or the manufacturer of the compliant product component if applicable, to assist the certification organization and NIOSH/NPPTL in the investigation and to conduct its own investigation as specified in Section 4.7, Manufacturers’ Investigation of Complaints and Returns. 4.6.9 Where the facts indicating a need for corrective action are conclusive and the certification organization’s appeal procedures

1981-��

Report on Comments F2006 — Copyright, NFPA NFPA 1981referenced in 4.�.11 have been followed, manufacturer has exhausted all appeal rights, the certification organization in coordination with NIOSH/NPPTL shall initiate corrective action immediately, provided there is a manufacturer to be held responsible for such action. 4.6.10 Where the facts are conclusive and corrective action is indicated, but there is no manufacturer to be held responsible, such as when the manufacturer is out of business or the manufacturer is bankrupt, the certification organization in coordination with NIOSH/NPPTL shall immediately notify relevant governmental and regulatory agencies and issue a notice to the user community about the hazard. 4.6.11 Where the facts are conclusive and corrective action is indicated, the certification organization in coordination with NIOSH/NPPTL shall take one or more of the following corrective actions: (1) Parties authorized and responsible for issuing a safety alert shall be notified when, in the opinion of the certification organization and NIOSH/NPPTL, such a safety alert is necessary to inform the users. (�) Parties authorized and responsible for issuing a product recall shall be notified when, in the opinion of the certification organization and NIOSH/NPPTL, such a recall is necessary to protect the users. (�) The mark of certification shall be removed from the product. (4) Where a hazardous condition exists and it is not practical to implement (1), (�), or (�) or the responsible parties refuse to take corrective action, the certification organization in coordination with NIOSH/NPPTL shall notify relevant governmental and regulatory agencies and issue a notice to the user community about the hazard. 4.6.1� The certification organization in coordination with NIOSH/NPPTL shall provide a report to the organization or individual identifying the reported hazardous condition and notify them of the corrective action indicated, or that no corrective action is indicated. 4.6.1� Where a change to an NFPA standard(s) is felt to be necessary, the certification organization in coordination with NIOSH/NPPTL shall also provide a copy of the report and indicated corrective actions to the NFPA, and shall also submit either a Public Proposal for a proposed change to the next revision of the applicable standard, or a proposed Temporary Interim Amendment (TIA) to the current edition of the applicable standard. 4.7 Manufacturers’ Investigation of Complaints and Returns. 4.7.� Where the manufacturer discover, during the review of specific returns or complaints, that a compliant product or compliant product component can constitute a potential safety risk to end user and is possibly subject to a safety alert or product recall, the manufacturer shall immediately contact NIOSH/NPPTL and the certification organization and provide all information about their review to assist NIOSH/NPPTL and the certification organization with their investigation. 4.8 Manufacturers’ Safety Alert and Product Recall Systems. 4.8.1 Manufacturers shall establish a written safety alert system and a written product recall system that describes the procedures to be used in the event that it decides, or is directed by the certification organization or NIOSH/NPPTL, to either issue a safety alert or to conduct a product recall. 4.8.�(�) A method of notifying all dealers, distributors, purchasers, users, and the NFPA about the safety alert or product recall that can be initiated within a one-week period following the manufacturer’s decision to issue a safety alert or to conduct a product recall, or after the manufacturer has been directed by NIOSH/NPPTL or the certification organization to issue a safety alert or conduct a product recall.Substantiation: NIOSH/NPPTL is developing procedures for investigation of reported problems with SCBA and should be added to the language currently in the document that describes the procedures that will be followed when a report of hazard is received.Committee Meeting Action: Accept

____________________________________________________________1981-75 Log #�14 FAE-RPE Final Action: Accept(4.7.3)____________________________________________________________Submitter: Les Boord, NIOSHComment on Proposal No: 1981-�Recommendation: In bullet 4.7.� “NIOSH National Personal Protection Technical Laboratory (NPPTL)” should be revised to read “NIOSH National Personal Protective Technology Laboratory (NPPTL).”Substantiation: Revised text.Committee Meeting Action: Accept

____________________________________________________________1981-76 Log #CC1 FAE-RPE Final Action: Accept(Chapter 5, 6, 7, and 8)____________________________________________________________Submitter: Technical Committee on Respiratory Protection Equipment Comment on Proposal No: 1981-1Recommendation: Revise text as follows: 5.1.1 Delete “…and an interchangeable breathing air cylinder product label.” 5.1.1.� Delete 5.1.7 Delete

5.1.7.1 Delete 5.1.7.� Delete 5.�.4 Delete 6.1.4 Delete “…and an interchangeable SCBA cylinder and valve assembly.” 6.5 Delete 6.5.1 Delete 6.5.� Delete 6.5.� Delete 6.5.4 Delete 6.5.5 Move to 6.1.1 7.16 Delete “Interchangeable” 7.16.1 Delete 7.16.� Editorial -- add “be” 7.16.� Revise text: The SCBA CGA cylinder valve handwheel connection shall be tested for attachment and detachment as specified in Section 8.�5, Cylinder Connections and Accessibility Test, and the CGA handwheel cylinder valve shall fully connect in a maximum of �0 seconds, and shall fully disconnect in a maximum of �0 seconds. 7.16.4 Revise text: “The SCBA CGA cylinder valve handwheel connection shall be tested for clearance accessibility as specified in Section 8.�5, Cylinder Connections and Accessibility Test.” and the CGA handwheel shall have a clearance between the outer diameter of the handwheel of not less than �5 mm. (1 in.) form any other surface of the SCBA. 8.�� Delete. 8.�4.�.� Revise text: “Samples shall be fitted with surrogate manufacturer’s cylinder and valve assembly.” 8.�4.�.1Delete text One SCBA specimen shall be tested with each surrogate cylinder and valve assembly as specified in 8.�4.5. (Is 8.�4.5 correct?) 8.�4.4.� Delete Table 8.�4.4.� Delete 8.�4.4.4 Change term “CGA plane” to read “valve connection plane” 8.�4.5.1 Revise text: “The specimen, fitted with the surrogate SCBA manufacturer’s cylinder and valve assembly, shall be fixed to the backplate and harness assembly in accordance with manufacturer’s instructions in the user instructions provided with the SCBA for the end user.” 8.�4.5.� Revise text: “The fully assembled SCBA shall be firmly fixed to the test bench or fixture in a manner that prevents movement of the SCBA but shall not interfere with the interoperable breathing air cylinder and valve assembly retention method.

Figure 8.24.5.4

8.�5.�.� Revise text: “Samples shall be fitted with surrogate SCBA manufacturer’s cylinder and valve assemblies.” 8.�5.�.1 Revise text: “The interoperable SCBA manufacturer’s cylinder and valve assembly shall be fixed to the backplate harness assembly following the manufacturer’s instruction provided in the User Instructions from the SCBA manufacturer.” 8.�5.4.1 Delete 8.�5.4.� Revise text: “The specimen, fitted with the surrogate SCBA manufacturer’s cylinder and valve assembly, shall be fixed to the backplate and harness assembly in accordance with the manufacturer’s instruction in the user instructions provided with the SCBA for the end user.” 8.�5.4.4 Revise text: “The test subject shall be able to fully connect the CGA handwheel cylinder and valve assembly to the SCBA in less than �0 seconds. Removal shall be accomplished within �0 seconds.”Substantiation: The Technical Committee on Respiratory Protection Equipment included requirements in the ROP that would allow the interchangeability of breathing air cylinders of the same cylinder pressure category among the various manufacturers’ SCBA, and specifically solicited input from the fire and emergency services communities on this issue. A special note was published with the ROP that described the evolution of this concept, and the advantages and disadvantages of the proposal.

1981-��

Report on Comments F2006 — Copyright, NFPA NFPA 1981 The Committee received over one hundred Public Comments related to breathing air cylinder interchangeability. In addition, NFPA received a number of letters expressing opinions from the user community on this issue. The Committee noted that the substantiation for a number of the Public Comments was based on speculation and misinformation about these issues that was spread throughout the user communities. The Committee worked closely with NIOSH/NPPTL (National Institute for Occupational Safety and Health / National Personal Protection Technology Laboratory) to ensure that cylinder interchangeability could be accomplished within the same cylinder pressure category without voiding NIOSH certification and certification to NFPA 1981. Language was also crafted to allow certified interchangeable breathing air cylinders to be also certified for use with existing SCBA, thus eliminating some of the concerns about logistics problems and incompatibility within an organization. Other Public Comments expressed valid concerns, which the Committee has enumerated below to substantiate the decision to remove cylinder interchangeability from this edition of the standard. Not a single Public Comment documented any incident where the breathing air cylinder supply was exhausted but had cylinder interchangeability been possible, operations using SCBA could have continued. Also, no Public Comment stated any incident where breathing air cylinder supply would have benefited from being able to interchange cylinders. In fact, there were comments from organizations that responded to the terrorist incidents at the New York City World Trade Center and the Pentagon on 9/11/�001, as well as to the natural disasters, Hurricanes Katrina and Rita, that struck the Gulf Coast and Texas in �005, stating that the ability to use cylinder interchangeability was never an issue. Although the Committee also received comments supporting cylinder interchangeability, the TC is unaware of any documented or anecdotal evidence of an incident that demonstrated the need for cylinder interchangeability. As pointed out in the TC Note attached to the ROP, it could be 15 years or longer before all organizations had certified interchangeable cylinders. That, coupled with the fact that SCBA are still available in three different cylinder pressure categories (��16, �000, and 4500 psi), means that true cylinder interchangeability would not be achieved even then. Some comments recommended specifying a single breathing air cylinder pressure for all SCBA, and the Committee will consider this for a future revision. Finally, other comments claimed that the proposed requirements were design restrictive and could hinder future innovation. Standards, by their very nature, are restrictive. To ensure that all cylinders will work properly with all SCBA, it is necessary to tightly specify design and functional parameters for safety and proper functioning. For all of these reasons, the Committee has deleted or revised the proposed �007 edition of the standard to remove all reference to breathing cylinder interchangeability. The TC did retain two performance requirements and the associated test methods that were originally included because of cylinder interchangeability, but that are considered important for proper functioning and enhanced safety of the SCBA in general. These are the Breathing Air Cylinder and Valve Assembly Retention and Cylinder Connections Accessibility. All references to interchangeable cylinders or use of a surrogate cylinder have been deleted from the performance requirements and associated tests. Where the Public Comments did not contain a specific recommendation for the Committee’s consideration, or were unclear in what the submitter was seeking, the Committee attempted to determine the submitter’s desire by statements made in the submitters’ substantiation. The Committee took various actions on these Public Comments depending on their perception or understanding of the submitters’ recommendation. Where the Committee understood the submitters’ recommendation but disagreed with the substantiation, other actions may have taken to express the Committee’s disagreement with the submitter’s position. Most or all of these Comments probably achieved the submitter’s actual goal, deleting requirements for cylinder interchangeability, the submitter’s objective was achieved. These actions should not be construed to mean that the Committee agrees with the submitter’s substantiation. The Technical Committee’s substantiation for deleting cylinder interchangeability is as stated in this Committee Comment. Committee Meeting Action: Accept

____________________________________________________________1981-77 Log #�06 FAE-RPE Final Action: Accept in Principle(5.1)____________________________________________________________Submitter: Salvatore Cassano, New York City Fire DepartmentComment on Proposal No: 1981-�Recommendation: Eliminate all references to the requirement for interchangeable SCBA breathing air cylinders as well as associated references and testing requirements.Substantiation: The changes recommended by this standard could decrease rather than enhance firefighter safety. The requirement for interchangeable cylinders could have a negative effect on product innovation at a cost to firefighter safety. There has not been any evidence

presented to document the need for interchangeability. Not all fire departments use the same pressure; therefore interchangeability will only be achieved via a single universal pressure. Forward/backward compatibility will not be assured lacing departments in a position of lacking compatibility among existing vendors.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-78 Log #54 FAE-RPE Final Action: Accept in Principle(5.1.1, 5.1.1.2, 5.1.7, 5.1.7.1, 6.1.4, 6.5, 7.16, and 8.23)____________________________________________________________Submitter: A. Ira Harkness, US Department of the NavyComment on Proposal No: 1981-�Recommendation: Delete SCBA Interchangeable Breathing Air Cylinder and Valve Assembly Design Requirements (Section 6.5, etc.) in its entirety. Delete references to interchangeable cylinder as necessary.Substantiation: (1) A cylinder interchangeability requirement is unnecessary, both in Navy experience and in the experience of others, as has been related to the technical committee. In perhaps the most applicable example, New York Fire Department representatives have stated that spare cylinders were never an issue on 9/11 and the attack on the World Trade Center. Providing sufficient refill capacity instead better solves the problem the cylinder interchangeability requirement is ostensibly intended to solve. (�) Cylinder interchangeability is not in fact a minimum requirement. (�) Cylinder interchangeability will create compatibility issues with existing SCBA’s for some, as well as other unintended consequences, that are not outweighed by any benefits of the requirement.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-79 Log #146 FAE-RPE Final Action: Accept in Principle(5.1.7, 6.5, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: Steven H. Weinstein, SurvivairComment on Proposal No: 1981-�Recommendation: Delete the complete sections (including all subsections).Substantiation: The inclusion of a requirement for cylinder interoperability has not been justified. There have been no documented instances of firefighter injuries or deaths due to not having such a requirement. There have not been any safety issues from lack of a cylinder interoperability requirement during large-scale responses such as the 9/11 attack or Hurricane Katrina. There would be a significant economic burden on the fire service from such a requirement, with few, if any, tangible benefits. Additionally, there would be incompatibility within a fire department between older SCBAs and newer cylinders (or with newer SCBAs and older cylinders) for a substantial period of time, which could create severe logistics problems on the fireground. Finally, a cylinder interoperability requirement could severely limit innovation in SCBA development, which could work against, rather than for, firefighter’s interests.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-80 Log #��8 FAE-RPE Final Action: Accept in Principle(5.2.4)____________________________________________________________Submitter: Salvatore Cassano, New York City Fire DepartmentComment on Proposal No: 1981-�Recommendation: Eliminate all references to the requirement for interchangeable SCBA breathing air cylinders as well as associated references and testing requirements.Substantiation: The changes recommended by this standard could decrease rather enhance firefighter safety. The requirement for interchangeable cylinders could have a negative effect on product innovation at a cost to firefighter safety. There has not been any evidence presented to document the need for interchangeability. Not all fire departments use the same pressure; therefore interchangeability will only be achieved via a single universal pressure. Forward/backward compatibility will not be assured placing departments in a position of lacking compatibility among existing vendors.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

1981-�4

Report on Comments F2006 — Copyright, NFPA NFPA 1981____________________________________________________________1981-81 Log #197 FAE-RPE Final Action: Accept(5.2.7)____________________________________________________________Submitter: Les Boord, NIOSHComment on Proposal No: 1981-�Recommendation: Revise bullet 5.�.7 by adding: (4) Emergency procedures to be followed in the event of damage malfunction or failure of the breathing apparatus.Substantiation: Modify text in bullet 5.�.7. Inclusion of this information in the user instructions will give the users needed information for training and in the event of an incident. for potential life-saving procedures to be taken in emergencies involving damage, malfunction or failure of the breathing apparatus.Committee Meeting Action: Accept

____________________________________________________________1981-8� Log #196 FAE-RPE Final Action: Accept(5.2.8(6))____________________________________________________________Submitter: Les Boord, NIOSHComment on Proposal No: 1981-�Recommendation: Revise bullet 5.�.8 by adding: (6) Complete instructions for reporting all returned equipment or complaints of damage, malfunction or failure of the breathing apparatus that may present a hazard to the user to the manufacturer, certification authority, and NIOSH NPPTL.Substantiation: Modify text in bullet 5.�.8. Inclusion of this information in the user instructions will give the users needed information for proper procedures in reporting serious damage, malfunction or failure of the breathing apparatus to the appropriate contacts for expeditious resolution.Committee Meeting Action: Accept

____________________________________________________________1981-8� Log #CC� FAE-RPE Final Action: Accept(Chapter 6, 7, and 8)____________________________________________________________Submitter: Technical Committee on Respiratory Protection Equipment Comment on Proposal No: 1981-1Recommendation: Revise text as follows:

Chapter 6 Design Requirements 6.1.9 All SCBA shall be equipped with a mechanical speaking diaphragm.

6.1.10 All SCBA shall have a voice communication system.6.1.10.1 The voice communication system shall be designed to

project sound without other persons needing a receiver to hear the voice communications.

6.1.10.2 Where the voice communication system uses electronics, the design shall incorporate an indicator that the system is “on.” This indicator shall be permitted to be positioned outside of the user’s field of vision with the SCBA facepiece properly donned.

6.10.1.3 Where the voice communications system uses electronics, the power source shall display a visual alert signal indicating low power capacity.

6.10.1.4 Where the voice communications system uses electronics, the voice communication system shall be designed to manually switch off and on without affecting the performance of the SCBA.

6.10.1.5 Where the voice communication system is automatically activated, the operation of the on/off control shall override the auto activation of the voice communication system without affecting the performance of the SCBA.

6.10.1.6 Where the voice communications system uses electronics, the voice communication system shall be permitted to be equipped with an adjustable volume (gain) control.

6.X Power Source Design Requirements6.X.1 The power source for electronics that are part of the SCBA shall

be either a single dedicated source for one device, or shall be a common power source for multiple devices.

6.X.2 Where all electronic devices that are part of the SCBA share a common power source, a single low power source visual alert signal shall be provided and shall be part of the HUD display.

6.X.3 Where multiple but not all electronic devices that are part of the SCBA share a common power source, a low power source visual alert signal shall be located on each of those electronic devices supplied by the common power source, and positioned on each of those electronic devices where it will be seen with the electronic device mounted in its permanent position on the SCBA

6.X.4 Where an electronic device uses a single, dedicated power source, the low power source visual alert signal shall be located on the electronic device and positioned where it will be seen with the electronic device mounted in its permanent position on the SCBA.

6.X.5 With the exception of HUD displays of low power source visual alert signals specified in 6.X.�, the low power source visual alert signals shall be permitted to be positioned outside of the user’s field of vision with the SCBA facepiece properly donned.

Chapter 7 Performance Requirements7.10 Speaking Diaphragm Performance Requirements7.10.1 The SCBA speaking diaphragm as identified by the SCBA

manufacturer, shall be tested for performance as specified in Section 8.10, Speaking Diaphragm Test, and shall have a value of not less than 75 percent.

7.16 Voice Communication System Performance Requirements7.16.1 The SCBA voice communication system, as identified by the

SCBA manufacturer, shall be tested for communication performance as specified in Section 8.XX, Voice Communication System Test, and shall have a value of not less than 85 percent.

7.19 Low Power Capacity7.19.1 Where power sources are used to comply with the requirements

of this standard, electronic devices shall be tested for proper functioning during low power capacity as specified in Section 8.�8, Low-Power Capacity Test, and shall continue to properly function at maximum power consumption for a minimum of � hours following the activation of the low-power source visual alert signal.

Chapter 8 Test Methods8.10 Mechanical Voice Diaphragm Test8.10.1 Application. This test method shall apply to complete SCBA. 8.10.2 Samples. Each sample to be tested shall be as specified in 4.�.9

with voice communication systems installed and in the “off” mode as per manufacturer instructions

8.10.3 Specimen Preparation. 8.10.3.1 Prior to testing, specimens shall be conditioned for a minimum

of 4 hours and tested at an ambient temperature of ��°C, ±�°C (7�°F, ±5°F), RH 50 percent, ±�5 percent.

8.10.3.2 Specimens for conditioning shall be complete SCBA. 8.10.4 Apparatus. 8.10.4.1 Testing shall be conducted in a chamber that absorbs a

minimum of 90 percent of all sound from 500 Hz to 5000 Hz. 8.10.4.2 Five listening subjects and five talkers consisting of four males

and one female shall be available for testing. The alternative of electronic recording of five talkers for testing automation and repeatability shall be permitted.

8.10.4.3 The subjects participating as listeners shall have “audiometrically normal” hearing as defined in Section 5.� of ANSI S�.�, Method for Measuring the Intelligibility of Speech over Communication Systems, in the range of 500 Hz to �000 Hz, and shall not be permitted to use any device that would enhance the listeners’ ability to hear.

8.10.4.4 Talkers and listeners shall be selected and trained according to Section 7 of ANSI S�.�, Method for Measuring the Intelligibility of Speech Over Communication Systems.

8.10.4.5 The five talkers shall not have facial hair, any unusual facial characteristics, or any other condition that could cause interference with the seal of the facepiece.

8.10.4.6 The talkers shall perform and pass a qualitative facepiece-to-face fit check per the SCBA manufacturer’s instructions.

8.10.4.7 Where the talker is qualified to wear several sizes of facepieces, then the talker shall choose the facepiece that is most comfortable.

8.10.4.8 The five talkers shall be trained in the donning and usage of the SCBA per manufacturer’s instructions.

8.10.4.9 The five talkers shall have no obvious speech defect or strong regional accent.

8.10.4.10 The distance between the talker and listener(s) shall be 1.5 m, +�05 mm/-0 mm (5 ft, +1 ft/-0 ft), and they shall be facing each other.

8.10.4.11 The test chamber shall be filled with broadband “pink” noise with a tolerance of 6 dB per octave band from 400 Hz to 4000 Hz

8.10.4.12 The forward axis of the loudspeaker shall be oriented away from the listener group.

8.10.4.13 The distance between the loudspeaker and the listeners shall be as great as possible so as to create a quasi-uniform sound field over the listening group.

8.10.4.14 More than one loudspeaker shall be permitted to be used to achieve the desired sound field.

8.10.4.15 The gain of the power amplifier used to generate the pink noise shall be adjusted to achieve an A-weighted sound level of 70 dB, ±� dB, at each listener’s head position, without listeners present.

8.10.5 Procedure. 8.10.5.1 The method for measuring word intelligibility shall be as

specified in ANSI S�.�, Method for Measuring the Intelligibility of Speech over Communication Systems, with the modified apparatus specified in 8.10.4.

8.10.5.2 The test material shall be the reading of one complete list of modified rhyme words as contained in Table � of ANSI S�.�, Method for Measuring the Intelligibility of Speech over Communication Systems.

8.10.5.2.1 The words shall be spoken singularly in the following carrier sentence: “Would you circle (list word) now?”

8.10.5.2.2 The rate shall be approximately one test word every 6 seconds.

8.10.5.2.3 The talkers shall be trained to talk at 75 dBA – 85 dBA without an SCBA facepiece, measured at the listener’s ear, placing no unusual stress on any word.

1981-�5

Report on Comments F2006 — Copyright, NFPA NFPA 19818.10.5.2.4 Training shall include the use of background noise as defined

in 8.10.4.11 through 8.10.4.15. 8.10.5.2.5 The talkers shall not vary their voice level from that used

without the facepiece after the facepiece is donned. 8.10.5.2.6 The listeners shall circle each word as they hear it. 8.10.5.3 The talkers shall conduct two tests in the chamber having an

ambient noise field as specified in 8.10.4.11 through 8.10.4.15, using a different word list for each of the following conditions:

(1) With no SCBA (�) With SCBA worn and operated per the SCBA manufacturer’s

instructions 8.10.5.4 Talkers’ speech shall be monitored during the tests to determine

if the talkers conform to the word list specified for that test. 8.10.5.5 Each listener’s response form shall be scored as to the number

of correct responses out of the 50 words recited. 8.10.5.5.1 Listeners’ scores shall be based on the words actually spoken

by the talkers. 8.10.5.5.2 Listeners’ scores shall not be reduced because of speaking

mistakes of the talkers.8.10.5.5.3 All of the listeners’ scores without the SCBA used by the

talker shall be averaged and all of the listeners’ scores with the SCBA used by the talker shall be averaged.

8.10.5.5.4 The average score of the five listeners for the talker using the SCBA shall be divided by the average score of the five listeners for the talker without using the SCBA, and the result shall be called the “score value.” This procedure shall be performed for each of the five talkers.

8.10.5.6 The average of the score values obtained in 8.10.5.5.� and 8.10.5.5.4 shall be calculated.

8.10.5.6.1 Where the average of the score values is >=80 percent, this average score value shall be used to determine pass/fail.

8.10.5.6.2 Where the average of the score values <80 percent, the sample standard deviation (s.d.) of the score values shall be calculated in the following manner:

[Existing Equation, 2002 ed. (no change)] where:x = score valuesN = sample size (5)8.10.5.6.3 Where the calculated sample standard deviation of the test

score values is >10.0, the test shall be invalidated, and the procedures of 8.10.5.� through 8.10.5.6.6 shall be repeated.

8.10.5.6.4 Where the calculated sample standard deviation of the test score values is <10.0, a test statistic, T-value, shall be calculated to determine if the average of the score values obtained is or is not equivalent to 80 percent; it shall be calculated in the following manner:

[Existing Equation, 1981, 2002 ed. (no change)] where:= average of the score values N = sample size (5) µ = 80 percent s.d. = sample standard deviation 8.10.5.6.5 For T-values =�.1�, the score value shall be considered 80

percent and shall be used to determine pass/fail. 8.10.5.6.6 For T-values >�.1�, the score value shall be as calculated in

8.10.5.6, and this calculated score value shall be used to determine pass/fail.

8.10.6 Report. The average of the score values obtained shall be calculated, recorded, and reported.

8.10.7 Interpretation. The average of the score value shall be used to determine pass/fail

8.27 Voice Communication System Test8.27.1 Application. This test method shall apply to complete SCBA. 8.27.2 Samples. Each sample to be tested shall be as specified in 4.�.9. 8.27.3 Specimen Preparation. 8.27.3.1 Prior to testing, specimens shall be conditioned for a minimum

of 4 hours and tested at an ambient temperature of ��°C, ±�°C (7�°F, ±5°F), RH 50 percent, ±�5 percent.

8.27.3.2 Specimens for conditioning shall be complete SCBA. 8.27.4 Apparatus. 8.27.4.1 Testing shall be conducted in a chamber that absorbs a

minimum of 90 percent of all sound from 500 Hz to 5000 Hz. 8.27.4.2 Five listening subjects and five talkers consisting of four males

and one female shall be available for testing. The alternative of electronic recording of five talkers for testing automation and repeatability shall be permitted.

8.27.4.3 The subjects participating as listeners shall have “audiometrically normal” hearing as defined in Section 5.� of ANSI S�.�, Method for Measuring the Intelligibility of Speech over Communication Systems, in the range of 500 Hz to �000 Hz, and shall not be permitted to use any device that would enhance the listeners’ ability to hear.

8.27.4.4 Talkers and listeners shall be selected and trained according to Section 7 of ANSI S�.�, Method for Measuring the Intelligibility of Speech Over Communication Systems.

8.27.4.5 The five talkers shall not have facial hair, any unusual facial characteristics, or any other condition that could cause interference with the seal of the facepiece.

8.27.4.6 The talkers shall perform and pass a qualitative facepiece-to-face fit check per the SCBA manufacturer’s instructions.

8.27.4.7 Where the talker is qualified to wear several sizes of facepieces, then the talker shall choose the facepiece that is most comfortable.

8.27.4.8 The five talkers shall be trained in the donning and usage of the SCBA per manufacturer’s instructions.

8.27.4.9 The five talkers shall have no obvious speech defect or strong regional accent.

8.27.4.10 The distance between the talker and listener(s) with the SCBA donned shall be � m, +�05 mm/-0 mm (10 ft, +1 ft/-0 ft), and they shall be facing each other.

8.27.4.10.1 The distance between the talker and listener(s) without the SCBA donned shall be 1.5 m, +�05 mm/-0 mm (5 ft, +1 ft/-0 ft), and they shall be facing each other.

8.27.4.11 The test chamber shall be filled with broadband “pink” noise with a tolerance of 6 dB per octave band from 400 Hz to 4000 Hz.

8.27.4.12 The forward axis of the loudspeaker shall be oriented away from the listener group.

8.27.4.13 The distance between the loudspeaker and the listeners shall be as great as possible so as to create a quasi-uniform sound field over the listening group.

8.27.4.14 More than one loudspeaker shall be permitted to be used to achieve the desired sound field.

8.27.4.15 The gain of the power amplifier used to generate the pink noise shall be adjusted to achieve an A-weighted sound level of 70 dB, ±� dB, at each listener’s head position, without listeners present.

8.27.5 Procedure. 8.27.5.1 The method for measuring word intelligibility shall be as

specified in ANSI S�.�, Method for Measuring the Intelligibility of Speech over Communication Systems, with the modified apparatus specified in 8.�7.4.

8.27.5.2 Where the voice communication system is equipped with an adjustable volume (gain) control, the volume control shall be set at the lowest level during testing.

8.27.5.3 The test material shall be the reading of one complete list of modified rhyme words as contained in Table � of ANSI S�.�, Method for Measuring the Intelligibility of Speech over Communication Systems.

8.27.5.3.1 The words shall be spoken singularly in the following carrier sentence: “Would you circle (list word) now?”

8.27.5.3.2 The rate shall be approximately one test word every 6 seconds.

8.27.5.3.3 The talkers shall be trained to talk at 75 dBA – 85 dBA without an SCBA facepiece, measured at 1.5 m, +�05 mm/-0 mm (5 ft, +1 ft/-0 ft), distance at the height of the listener’s ear, placing no unusual stress on any word.

8.27.5.3.4 Training shall include the use of background noise as defined in 8.�7.4.11 through 8.�7.4.15.

8.27.5.3.5 The talkers shall not vary their voice level from that used without the facepiece after the facepiece is donned.

8.27.5.3.6 The listeners shall circle each word as they hear it. 8.27.5.4 The talkers shall conduct two tests in the chamber having an

ambient noise field as specified in 8.�7.4.11 through 8.�7.4.15, using a different word list for each of the following conditions:

(1) With no SCBA (�) With SCBA worn and operated per the SCBA manufacturer’s

instructions 8.27.5.5 Talkers’ speech shall be monitored during the tests to determine

if the talkers conform to the word list specified for that test. 8.27.5.5 Each listener’s response form shall be scored as to the number

of correct responses out of the 50 words recited. 8.27.5.5.1 Listeners’ scores shall be based on the words actually spoken

by the talkers. 8.27.5.5.2 Listeners’ scores shall not be reduced because of speaking

mistakes of the talkers 8.27.5.5.3 All of the listeners’ scores without the SCBA used by the

talker shall be averaged and all of the listeners’ scores with the SCBA used by the talker shall be averaged.

8.27.5.5.4 The average score of the five listeners for the talker using the SCBA at a distance of � m, +�05 mm/-0 mm (10 ft, +1 ft/-0 ft) shall be divided by the average score of the five listeners for the talker without using the SCBA at a distance of 1.5 m, +�05 mm/-0 mm (5 ft, +1 ft/-0 ft), and the result shall be called the “score value.” This procedure shall be performed for each of the five talkers.

8.27.5.6 The average of the score values obtained in 8.�7.5.5.� and 8.�7.5.5.4 shall be calculated.

8.27.5.6.1 The average of the score values shall be >85 percent, this average score value shall be used to determine pass/fail.

8.27.5.6.2 Where the average of the score values is <85 percent, the sample standard deviation (s.d.) of the score values shall be calculated in the following manner:

[Existing Equation, 2002 ed. (no change)] where:x = score valuesN = sample size (5)

1981-�6

Report on Comments F2006 — Copyright, NFPA NFPA 19818.27.5.6.3 Where the calculated sample standard deviation of the test

score values is >10.0, the test shall be invalidated, and the procedures of 8.�7.5.� through 8.�7.5.6.� shall be repeated.

8.27.5.6.4 Where the calculated sample standard deviation of the test score values is <10.0, a test statistic, T-value, shall be calculated to determine if the average of the score values obtained is or is not equivalent to 85 percent

[Existing Equation, 2002 ed. (no change)] where:= average of the score values N = sample size (5) µ = 85 percent s.d. = sample standard deviation 8.27.5.6.5 For T-values =�.1�, the score value shall be considered to be

equivalent to a score value of 85 percent8.27.5.6.6 For T-values >�.1�, the score value shall be as calculated in

8.�7.5.6, and this calculated score value shall be used to determine pass/fail.

8.27.6 Report. The average of the score values obtained shall be calculated, recorded, and reported.

8.27.7 Interpretation. The average of the score value shall be used to determine pass or fail.

8.28 Low-Power Capacity Test. 8.28.1 Application. This test shall apply to all electronic devices

required for SCBA by the requirements of Chapter 6.8.28.2 Samples. Each sample to be tested shall be as specified in 4.�.9. 8.28.3 Specimen Preparation. Specimens shall be conditioned for a

minimum of 4 hours and tested at an ambient temperature of ��°C, ±�°C (7�°F, ±5°F), RH of 50 percent, ±�5 percent.

8.28.4 Apparatus. A variable power source that is capable of supplying dc voltage of at least �0 percent more than the nominal power supply voltage shall be provided.

8.28.5 Procedure. 8.28.5.1 Each electronic device shall be tested with a variable power

source to determine that the low-power source visual alert signal will activate at the voltage specified by the manufacturer, ±� percent.

8.28.5.2 Each electronic device shall be tested with a variable power source to determine that the electronic device will continue to operate down to the “cease-proper-operation voltage” specified by the manufacturer.

8.28.5.3 Where multiple electronic devices that are part of the SCBA share a common power source, the minimum amount of power that causes the activation of the low power source visual alert signal shall be determined with all electronics sharing the common power source operating at their respective maximum power consumption under normal use.

8.28.5.3.1 Each electronic device power source shall be tested by discharging it at the cumulative nominal operating current for all electronic devices utilizing the power source, as specified by the manufacturer, until the voltage falls to the level at which the electronic device low-power source visual alert signal illuminates as specified in 6.X.

8.28.5.3.2 Upon reaching this voltage, the current drain shall be increased to the cumulative peak current drain of all electronic devices utilizing the power supply, as specified by the manufacturer. Under these conditions and for a period of at least two hours, the power source voltage shall remain above the voltage that will cause the electronic device to cease proper operation.

8.28.6 Report. 8.28.6.1 The electronic device shall be observed for activation of the

low-power source visual alert signal. 8.28.6.2 The electronic device shall be observed for the display of the

low-power source visual alert signal down to the cease-proper-operation voltage.

8.28.6.3 The power source voltage shall be observed with respect to the cease-proper-operation voltage.

8.28.6.4 The events in 8.�8.6.1 through 8.�8.6.� shall be recorded and reported.

8.28.7 Interpretation. 8.28.7.1 Electronic device low-power source visual alert signal function

shall be evaluated to determine pass/fail. 8.28.7.2 Electronic device power source voltage greater than the “cease-

proper-operation voltage” shall constitute pass. Substantiation: The Committee revised text to allow the “mechanical speaking diaphragm” and the “voice communications system” to be one in the same where the mechanical speaking diaphragm can meet the requirements for both. Electronics are not required for the voice communication systems, however, electronics may very well be necessary in order to achieve the performance requirements for speech clarity and volume.Committee Meeting Action: Accept

____________________________________________________________1981-84 Log #�6 FAE-RPE Final Action: Reject(6.1.3)____________________________________________________________TCC Action: The Technical Correlating Committee REJECTS this comment. The TCC carefully reviewed the issues regarding the CBRN requirements being deleted from the proposed 2008 edition of NFPA 1981, including those expressed in the negative ballots on this issue, and the verbal positions heard from TC and TCC members. In accordance with the Regulations Governing Committee Projects (RGCPs), the TCC is taking the action it deems necessary in accordance with its authority as defined in 3.4.2, and in 4.4.7.1: “…The TCC shall be permitted to choose between alternatives presented by the TCs or develop text, as it deems necessary, to achieve correlation, consistence, and the correction of errors and omissions...” The TCC was concerned that some TC members expressed the opinion that while they did see a need for CBRN SCBA in their organization, they didn’t believe that it was necessary throughout the country and that individual departments should make their own determination, and another opinion was that it would be wrong to make other departments pay so much more for their SCBA when they don’t foresee a need for them. There is no way that anyone can predict where a future CBRN event will occur in this country. The terrorist threat is a reality not only in larger metropolitan areas but also in smaller communities and rural areas where terrorists would seek to severely affect the economy or bring it to a halt. While we can and should prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. In the Committee process, all members come to the table with a bias and represent their sponsoring organization’s feelings, but the safety, well being, and protection of the emergency responders must be the goal and local issues should take a secondary position to the improvement of safety for the emergency responders performing in the hazardous environments. In regards to cost, some TC members argued the point that municipalities should have a choice in what SCBA they purchase. In opposition to this stance, one TC member (King) stated, “There is no way that anyone can predict where a future CBRN event will occur in this country. While we can (and should) prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. It is interesting to note that a couple of the first responders who voted against having mandatory CBRN compliant SCBA in this standard acknowledge that their own department insists on CBRN compliant SCBA when purchasing new equipment.” Another TC member (Rossos) stated, “I disagree with the committee’s action regarding CBRN; therefore I must vote in the negative. I believe it is our purpose and responsibility as members of the Committee to strive to design SCBA standards and codes where the end user has the highest level of protection possible. I realize as an end user, that we need to strike a balance between best protection and secondary effects such as comfort, size, weight, etc. and in some regards even economics. We were given no evidence of any of the above compromises to mandating CBRN on all SCBAs. The only thing that we know for sure is that the end user would have a higher level of protection with CBRN as opposed to without. Very few end users have a choice in this matter. Most choices are made by purchasing agents or administrators who often base their decisions on the minimum legal standard available for the lowest price. I believe our first and most important responsibility on this committee is to those who wear SCBA, not to who buys SCBA. Regretfully, when there was no cost involved or reduction in protection, we voted to give the choice to the buyer and not the user.” This was based on the fact that all SCBA manufacturers present at the TC ROC meeting stated that the increased cost of CBRN protection for SCBA was negligible (under $100) or none. Also, TC Chairman Reed responded, “The argument during ROC was that many parts of the country may not have a need for CBRN protection. Unfortunately, in the post 9/11 world, I think this is being unrealistic. While major metropolitan areas may be more likely targets of a terrorist event, we have already seen that the terrorists themselves may reside in small communities while they await their opportunity to strike. They may have the chemical, biological, or nuclear material in their possession, making the possibility of exposure greater for even small, rural areas. But terrorist attacks aside, CBRN-certified SCBA offers greater protection for the fire fighter for a very minimal cost. If this protection is not required by the standard, many jurisdictions will not specify this for their fire fighters.” To the issue about CBRN compliant SCBA are uncomfortable to wear, this appears to be limited to one or two manufacturers’ chosen materials and the reality appears to be that first responders using

1981-�7

Report on Comments F2006 — Copyright, NFPA NFPA 1981CBRN SCBA are not reporting any significant difference relating to the comfort of the equipment and other manufacturers report no complaints from organizations who have purchased and use CBRN SCBA. And to the issue of CBRN compliant SCBA will not be as durable, there appears to be no reason to believe that CBRN compliant SCBA are any less durable than the non-CBRN compliant products on the market today and NIOSH has not received any complaints or identified any durability problems of CBRN SCBA over “regular” SCBA. To the issue of correlation and consistence, the TCC notes that other standards do require CBRN SCBA including NFPA 1500, Standard on Fire Department Occupational Safety and Health Program, 7.11.1.1 of the 2007 edition; 42 CFR 84, Respiratory Protective Devices, and the Statement of Standard for NIOSH CBRN SCBA Testing; and Section 5(A)(1) of the Occupational Safety and Health Act. The TCC believes that lack of correlation with these standards and regulations causes a strong potential decrease of safety for emergency responders due to purchasers believing that as NFPA 1981 is silent on CBRN requirements they do not to have that protection. The TCC further notes that the Department of Homeland Security (DHS) has formally adopted the NIOSH Statement of Standard for NIOSH CBRN SCBA Testing as one of the standards for first responder PPE. Only SCBA that have been approved by NIOSH as CBRN SCBA, which also requires certification to NFPA 1981, can be listed in the Authorized Equipment List (AEL), established by the DHS Office of Grants and Training as the list of recommended equipment for emergency responders. Purchase of SCBA with federal monies through several of the government grant programs requires that SCBA have CBRN approvals from NIOSH. In addition, the InterAgency Board for Equipment Standardization and Interoperability (the IAB) has established CBRN SCBA as the only qualified SCBA in its Standardized Equipment List (SEL). This SEL further provides detailed recommendations for first responder PPE. While NFPA 1500 provides requirements for fire departments, it does not provide requirements for non-fire based emergency responders. NFPA 1981, Standard for Open-Circuit Self-Contained Breathing Apparatus for Emergency Services, does provide SCBA requirements for any emergency services organization that needs protection from IDLH atmospheres. IDLH protection can only be provided by SCBA. The shortsightedness of the TC in removing the CBRN requirement leaves law enforcement responders, emergency medical responders, non-fire based hazardous materials response teams, and the skilled trades emergency responders without CBRN respiratory protection. CBRN protection offers verification of enhanced protection for emergency responders which is not otherwise available. Without CBRN protection evaluation, no SCBA components are tested for permeation, penetration, corrosion resistance, or other detrimental effects from exposure to hazardous chemical warfare atmospheres. NIOSH benchmark testing of non-CBRN hardened NIOSH certified SCBA against CBRN agents demonstrated that CWA agents could cause catastrophic failures within minutes of exposure. A comment by a TC member (Birch) stated, “…it is proper at this point in time to not require CBRN is because although NIOSH and other agencies make/made a good point of testing SCBAs against the list of chemical agents, there are missing tests. There are no tests to show that SCBAs as manufactured now, when altered to meet CBRN requirements, are still resistant to the ‘normal’ atmospheres and chemical agents in which they are currently used.” NIOSH (Boord) countered with, “The selection of the test challenge agents for CBRN protection was based on a comprehensive review of available technical data and consultations with other government agencies (e.g., DOD, DOJ, DOE, etc.). Various chemical data lists were analyzed, including lists from the EPA, ATSDR, NFPA 1994, U.S. Army Center for Health Promotion and Preventative Medicine (USACHPPM) Technical Guide 244, and classified sources. This review established a total of 151 toxic industrial chemicals and chemical warfare agents (TIC-CWA) as potential candidates for challenge agents. The candidate agents were evaluated for permeation (molecularly diffusing through material) and penetration (seeping through interfacing components) characteristics as part of a review of their physical properties.” “This evaluation concluded that Sarin (GB) and Sulfur Mustard (HD) could be selected as the two representative agents for the penetration/permeation test for the complete listing of 151 CWA and TICs due to their physical properties and molecular structure.” “NIOSH is unaware of any data that indicates the CBRN respirators provide less protection against TICs than their industrial counterparts. The evaluation for CBRN protection provides verification and assurance that the component and material combinations in the approved SCBA configurations provide high resistance to permeation and penetration of hazardous atmospheres of toxic industrial chemicals and materials into the breathing air. This is of importance to all responders subject to extreme exposures to any hazardous industrial chemicals and materials.”

The TCC, acting in accordance with 3.4.3(g) of the RGCPs, “Determining whether or not the TC has given due consideration to all evidence presented to it in connection with the preparation of its Report including all comments relating to negative votes” does not believe the TC gave full and appropriate review and due consideration to all the issues and, therefore has taken these actions. In addition to the action taken on 1981-59, the following comments will be affected by this change and, therefore, the following changes must be made to these comments 1981-34 In action #2, change action from “Reject” to “Accept” 1981-50 Change action from “Accept in Principle” to “Reject” 1981-51 Change action from “Accept in Principle” to “Reject” 1981-52 Change action from “Accept in Principle” to “Reject” 1981-53 Change action from “Accept in Principle” to “Reject” 1981-54 Change action from “Accept in Principle” to “Reject” 1981-55 Change action from “Accept in Principle” to “Reject” 1981-56 Change action from “Reject” to “Accept” 1981-57 Change action from “Accept in Principle” to “Reject” 1981-58 Change action from “Accept in Principle” to “Reject” 1981-84 Change action from “Accept in Principle” to “Reject” 1981-85 Change action from “Accept in Principle” to “Reject” 1981-86 Change action from “Accept in Principle” to “Reject” 1981-87 Change action from “Accept in Principle” to “Reject”Submitter: Mike Burner, Oklahoma City, OKComment on Proposal No: 1981-�Recommendation: CBRN certification should be an option, not a requirement.Substantiation: CBRN certification will add to the cost of future purchases. In addition, as bunker gear is not required to be CBRN, this will have personnel only partially protected. Committee Meeting Action: Accept in Principle See committee action on Comment 1981-59 (Log #16�).Committee Statement: While the committee does not agree with the submitters substantiation, the CBRN requirement is being deleted by the committee action on Comment 1981-59 (Log #16�).

____________________________________________________________1981-85 Log #�9 FAE-RPE Final Action: Reject(6.1.3)____________________________________________________________TCC Action: The Technical Correlating Committee REJECTS this comment. The TCC carefully reviewed the issues regarding the CBRN requirements being deleted from the proposed 2008 edition of NFPA 1981, including those expressed in the negative ballots on this issue, and the verbal positions heard from TC and TCC members. In accordance with the Regulations Governing Committee Projects (RGCPs), the TCC is taking the action it deems necessary in accordance with its authority as defined in 3.4.2, and in 4.4.7.1: “…The TCC shall be permitted to choose between alternatives presented by the TCs or develop text, as it deems necessary, to achieve correlation, consistence, and the correction of errors and omissions...” The TCC was concerned that some TC members expressed the opinion that while they did see a need for CBRN SCBA in their organization, they didn’t believe that it was necessary throughout the country and that individual departments should make their own determination, and another opinion was that it would be wrong to make other departments pay so much more for their SCBA when they don’t foresee a need for them. There is no way that anyone can predict where a future CBRN event will occur in this country. The terrorist threat is a reality not only in larger metropolitan areas but also in smaller communities and rural areas where terrorists would seek to severely affect the economy or bring it to a halt. While we can and should prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. In the Committee process, all members come to the table with a bias and represent their sponsoring organization’s feelings, but the safety, well being, and protection of the emergency responders must be the goal and local issues should take a secondary position to the improvement of safety for the emergency responders performing in the hazardous environments. In regards to cost, some TC members argued the point that municipalities should have a choice in what SCBA they purchase. In opposition to this stance, one TC member (King) stated, “There is no way that anyone can predict where a future CBRN event will occur in this country. While we can (and should) prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. It is interesting to note that a couple of the first responders who voted against having mandatory CBRN compliant SCBA in this standard acknowledge that their own department insists on CBRN compliant SCBA when purchasing new equipment.”

1981-�8

Report on Comments F2006 — Copyright, NFPA NFPA 1981 Another TC member (Rossos) stated, “I disagree with the committee’s action regarding CBRN; therefore I must vote in the negative. I believe it is our purpose and responsibility as members of the Committee to strive to design SCBA standards and codes where the end user has the highest level of protection possible. I realize as an end user, that we need to strike a balance between best protection and secondary effects such as comfort, size, weight, etc. and in some regards even economics. We were given no evidence of any of the above compromises to mandating CBRN on all SCBAs. The only thing that we know for sure is that the end user would have a higher level of protection with CBRN as opposed to without. Very few end users have a choice in this matter. Most choices are made by purchasing agents or administrators who often base their decisions on the minimum legal standard available for the lowest price. I believe our first and most important responsibility on this committee is to those who wear SCBA, not to who buys SCBA. Regretfully, when there was no cost involved or reduction in protection, we voted to give the choice to the buyer and not the user.” This was based on the fact that all SCBA manufacturers present at the TC ROC meeting stated that the increased cost of CBRN protection for SCBA was negligible (under $100) or none. Also, TC Chairman Reed responded, “The argument during ROC was that many parts of the country may not have a need for CBRN protection. Unfortunately, in the post 9/11 world, I think this is being unrealistic. While major metropolitan areas may be more likely targets of a terrorist event, we have already seen that the terrorists themselves may reside in small communities while they await their opportunity to strike. They may have the chemical, biological, or nuclear material in their possession, making the possibility of exposure greater for even small, rural areas. But terrorist attacks aside, CBRN-certified SCBA offers greater protection for the fire fighter for a very minimal cost. If this protection is not required by the standard, many jurisdictions will not specify this for their fire fighters.” To the issue about CBRN compliant SCBA are uncomfortable to wear, this appears to be limited to one or two manufacturers’ chosen materials and the reality appears to be that first responders using CBRN SCBA are not reporting any significant difference relating to the comfort of the equipment and other manufacturers report no complaints from organizations who have purchased and use CBRN SCBA. And to the issue of CBRN compliant SCBA will not be as durable, there appears to be no reason to believe that CBRN compliant SCBA are any less durable than the non-CBRN compliant products on the market today and NIOSH has not received any complaints or identified any durability problems of CBRN SCBA over “regular” SCBA. To the issue of correlation and consistence, the TCC notes that other standards do require CBRN SCBA including NFPA 1500, Standard on Fire Department Occupational Safety and Health Program, 7.11.1.1 of the 2007 edition; 42 CFR 84, Respiratory Protective Devices, and the Statement of Standard for NIOSH CBRN SCBA Testing; and Section 5(A)(1) of the Occupational Safety and Health Act. The TCC believes that lack of correlation with these standards and regulations causes a strong potential decrease of safety for emergency responders due to purchasers believing that as NFPA 1981 is silent on CBRN requirements they do not to have that protection. The TCC further notes that the Department of Homeland Security (DHS) has formally adopted the NIOSH Statement of Standard for NIOSH CBRN SCBA Testing as one of the standards for first responder PPE. Only SCBA that have been approved by NIOSH as CBRN SCBA, which also requires certification to NFPA 1981, can be listed in the Authorized Equipment List (AEL), established by the DHS Office of Grants and Training as the list of recommended equipment for emergency responders. Purchase of SCBA with federal monies through several of the government grant programs requires that SCBA have CBRN approvals from NIOSH. In addition, the InterAgency Board for Equipment Standardization and Interoperability (the IAB) has established CBRN SCBA as the only qualified SCBA in its Standardized Equipment List (SEL). This SEL further provides detailed recommendations for first responder PPE. While NFPA 1500 provides requirements for fire departments, it does not provide requirements for non-fire based emergency responders. NFPA 1981, Standard for Open-Circuit Self-Contained Breathing Apparatus for Emergency Services, does provide SCBA requirements for any emergency services organization that needs protection from IDLH atmospheres. IDLH protection can only be provided by SCBA. The shortsightedness of the TC in removing the CBRN requirement leaves law enforcement responders, emergency medical responders, non-fire based hazardous materials response teams, and the skilled trades emergency responders without CBRN respiratory protection. CBRN protection offers verification of enhanced protection for emergency responders which is not otherwise available. Without CBRN protection evaluation, no SCBA components are tested for permeation, penetration, corrosion resistance, or other detrimental effects from exposure to hazardous chemical warfare atmospheres.

NIOSH benchmark testing of non-CBRN hardened NIOSH certified SCBA against CBRN agents demonstrated that CWA agents could cause catastrophic failures within minutes of exposure. A comment by a TC member (Birch) stated, “…it is proper at this point in time to not require CBRN is because although NIOSH and other agencies make/made a good point of testing SCBAs against the list of chemical agents, there are missing tests. There are no tests to show that SCBAs as manufactured now, when altered to meet CBRN requirements, are still resistant to the ‘normal’ atmospheres and chemical agents in which they are currently used.” NIOSH (Boord) countered with, “The selection of the test challenge agents for CBRN protection was based on a comprehensive review of available technical data and consultations with other government agencies (e.g., DOD, DOJ, DOE, etc.). Various chemical data lists were analyzed, including lists from the EPA, ATSDR, NFPA 1994, U.S. Army Center for Health Promotion and Preventative Medicine (USACHPPM) Technical Guide 244, and classified sources. This review established a total of 151 toxic industrial chemicals and chemical warfare agents (TIC-CWA) as potential candidates for challenge agents. The candidate agents were evaluated for permeation (molecularly diffusing through material) and penetration (seeping through interfacing components) characteristics as part of a review of their physical properties.” “This evaluation concluded that Sarin (GB) and Sulfur Mustard (HD) could be selected as the two representative agents for the penetration/permeation test for the complete listing of 151 CWA and TICs due to their physical properties and molecular structure.” “NIOSH is unaware of any data that indicates the CBRN respirators provide less protection against TICs than their industrial counterparts. The evaluation for CBRN protection provides verification and assurance that the component and material combinations in the approved SCBA configurations provide high resistance to permeation and penetration of hazardous atmospheres of toxic industrial chemicals and materials into the breathing air. This is of importance to all responders subject to extreme exposures to any hazardous industrial chemicals and materials.” The TCC, acting in accordance with 3.4.3(g) of the RGCPs, “Determining whether or not the TC has given due consideration to all evidence presented to it in connection with the preparation of its Report including all comments relating to negative votes” does not believe the TC gave full and appropriate review and due consideration to all the issues and, therefore has taken these actions. In addition to the action taken on 1981-59, the following comments will be affected by this change and, therefore, the following changes must be made to these comments 1981-34 In action #2, change action from “Reject” to “Accept” 1981-50 Change action from “Accept in Principle” to “Reject” 1981-51 Change action from “Accept in Principle” to “Reject” 1981-52 Change action from “Accept in Principle” to “Reject” 1981-53 Change action from “Accept in Principle” to “Reject” 1981-54 Change action from “Accept in Principle” to “Reject” 1981-55 Change action from “Accept in Principle” to “Reject” 1981-56 Change action from “Reject” to “Accept” 1981-57 Change action from “Accept in Principle” to “Reject” 1981-58 Change action from “Accept in Principle” to “Reject” 1981-84 Change action from “Accept in Principle” to “Reject” 1981-85 Change action from “Accept in Principle” to “Reject” 1981-86 Change action from “Accept in Principle” to “Reject” 1981-87 Change action from “Accept in Principle” to “Reject”Submitter: Robert Sell, Draeger Safety, Inc.Comment on Proposal No: 1981-�Recommendation: Delete entire section: SCBA that are certified as compliant with NFPA 1981 shall also be certified by NIOSH as a CBRN SCBA.Substantiation: 1. The NFPA 1500 Technical Committee has already made this a requirement (Section 7.11.1.1) in their document for the next revision. �. CBRN certifications would increase the lead time for NFPA 1981 certifications and would require a longer implementation date for NFPA 1981. �. From discussions with many volunteer fire departments. CBRN certification is something that they feel is not needed for their operations.Committee Meeting Action: Accept in Principle See committee action on Comment 1981-59 (Log #16�).Committee Statement: While the committee does not agree with the submitters substantiation, the CBRN requirement is being deleted by the committee action on Comment 1981-59 (Log #16�).

1981-�9

Report on Comments F2006 — Copyright, NFPA NFPA 1981____________________________________________________________1981-86 Log #191 FAE-RPE Final Action: Reject(6.1.3)____________________________________________________________TCC Action: The Technical Correlating Committee REJECTS this comment. The TCC carefully reviewed the issues regarding the CBRN requirements being deleted from the proposed 2008 edition of NFPA 1981, including those expressed in the negative ballots on this issue, and the verbal positions heard from TC and TCC members. In accordance with the Regulations Governing Committee Projects (RGCPs), the TCC is taking the action it deems necessary in accordance with its authority as defined in 3.4.2, and in 4.4.7.1: “…The TCC shall be permitted to choose between alternatives presented by the TCs or develop text, as it deems necessary, to achieve correlation, consistence, and the correction of errors and omissions...” The TCC was concerned that some TC members expressed the opinion that while they did see a need for CBRN SCBA in their organization, they didn’t believe that it was necessary throughout the country and that individual departments should make their own determination, and another opinion was that it would be wrong to make other departments pay so much more for their SCBA when they don’t foresee a need for them. There is no way that anyone can predict where a future CBRN event will occur in this country. The terrorist threat is a reality not only in larger metropolitan areas but also in smaller communities and rural areas where terrorists would seek to severely affect the economy or bring it to a halt. While we can and should prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. In the Committee process, all members come to the table with a bias and represent their sponsoring organization’s feelings, but the safety, well being, and protection of the emergency responders must be the goal and local issues should take a secondary position to the improvement of safety for the emergency responders performing in the hazardous environments. In regards to cost, some TC members argued the point that municipalities should have a choice in what SCBA they purchase. In opposition to this stance, one TC member (King) stated, “There is no way that anyone can predict where a future CBRN event will occur in this country. While we can (and should) prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. It is interesting to note that a couple of the first responders who voted against having mandatory CBRN compliant SCBA in this standard acknowledge that their own department insists on CBRN compliant SCBA when purchasing new equipment.” Another TC member (Rossos) stated, “I disagree with the committee’s action regarding CBRN; therefore I must vote in the negative. I believe it is our purpose and responsibility as members of the Committee to strive to design SCBA standards and codes where the end user has the highest level of protection possible. I realize as an end user, that we need to strike a balance between best protection and secondary effects such as comfort, size, weight, etc. and in some regards even economics. We were given no evidence of any of the above compromises to mandating CBRN on all SCBAs. The only thing that we know for sure is that the end user would have a higher level of protection with CBRN as opposed to without. Very few end users have a choice in this matter. Most choices are made by purchasing agents or administrators who often base their decisions on the minimum legal standard available for the lowest price. I believe our first and most important responsibility on this committee is to those who wear SCBA, not to who buys SCBA. Regretfully, when there was no cost involved or reduction in protection, we voted to give the choice to the buyer and not the user.” This was based on the fact that all SCBA manufacturers present at the TC ROC meeting stated that the increased cost of CBRN protection for SCBA was negligible (under $100) or none. Also, TC Chairman Reed responded, “The argument during ROC was that many parts of the country may not have a need for CBRN protection. Unfortunately, in the post 9/11 world, I think this is being unrealistic. While major metropolitan areas may be more likely targets of a terrorist event, we have already seen that the terrorists themselves may reside in small communities while they await their opportunity to strike. They may have the chemical, biological, or nuclear material in their possession, making the possibility of exposure greater for even small, rural areas. But terrorist attacks aside, CBRN-certified SCBA offers greater protection for the fire fighter for a very minimal cost. If this protection is not required by the standard, many jurisdictions will not specify this for their fire fighters.” To the issue about CBRN compliant SCBA are uncomfortable to wear, this appears to be limited to one or two manufacturers’ chosen materials and the reality appears to be that first responders using

CBRN SCBA are not reporting any significant difference relating to the comfort of the equipment and other manufacturers report no complaints from organizations who have purchased and use CBRN SCBA. And to the issue of CBRN compliant SCBA will not be as durable, there appears to be no reason to believe that CBRN compliant SCBA are any less durable than the non-CBRN compliant products on the market today and NIOSH has not received any complaints or identified any durability problems of CBRN SCBA over “regular” SCBA. To the issue of correlation and consistence, the TCC notes that other standards do require CBRN SCBA including NFPA 1500, Standard on Fire Department Occupational Safety and Health Program, 7.11.1.1 of the 2007 edition; 42 CFR 84, Respiratory Protective Devices, and the Statement of Standard for NIOSH CBRN SCBA Testing; and Section 5(A)(1) of the Occupational Safety and Health Act. The TCC believes that lack of correlation with these standards and regulations causes a strong potential decrease of safety for emergency responders due to purchasers believing that as NFPA 1981 is silent on CBRN requirements they do not to have that protection. The TCC further notes that the Department of Homeland Security (DHS) has formally adopted the NIOSH Statement of Standard for NIOSH CBRN SCBA Testing as one of the standards for first responder PPE. Only SCBA that have been approved by NIOSH as CBRN SCBA, which also requires certification to NFPA 1981, can be listed in the Authorized Equipment List (AEL), established by the DHS Office of Grants and Training as the list of recommended equipment for emergency responders. Purchase of SCBA with federal monies through several of the government grant programs requires that SCBA have CBRN approvals from NIOSH. In addition, the InterAgency Board for Equipment Standardization and Interoperability (the IAB) has established CBRN SCBA as the only qualified SCBA in its Standardized Equipment List (SEL). This SEL further provides detailed recommendations for first responder PPE. While NFPA 1500 provides requirements for fire departments, it does not provide requirements for non-fire based emergency responders. NFPA 1981, Standard for Open-Circuit Self-Contained Breathing Apparatus for Emergency Services, does provide SCBA requirements for any emergency services organization that needs protection from IDLH atmospheres. IDLH protection can only be provided by SCBA. The shortsightedness of the TC in removing the CBRN requirement leaves law enforcement responders, emergency medical responders, non-fire based hazardous materials response teams, and the skilled trades emergency responders without CBRN respiratory protection. CBRN protection offers verification of enhanced protection for emergency responders which is not otherwise available. Without CBRN protection evaluation, no SCBA components are tested for permeation, penetration, corrosion resistance, or other detrimental effects from exposure to hazardous chemical warfare atmospheres. NIOSH benchmark testing of non-CBRN hardened NIOSH certified SCBA against CBRN agents demonstrated that CWA agents could cause catastrophic failures within minutes of exposure. A comment by a TC member (Birch) stated, “…it is proper at this point in time to not require CBRN is because although NIOSH and other agencies make/made a good point of testing SCBAs against the list of chemical agents, there are missing tests. There are no tests to show that SCBAs as manufactured now, when altered to meet CBRN requirements, are still resistant to the ‘normal’ atmospheres and chemical agents in which they are currently used.” NIOSH (Boord) countered with, “The selection of the test challenge agents for CBRN protection was based on a comprehensive review of available technical data and consultations with other government agencies (e.g., DOD, DOJ, DOE, etc.). Various chemical data lists were analyzed, including lists from the EPA, ATSDR, NFPA 1994, U.S. Army Center for Health Promotion and Preventative Medicine (USACHPPM) Technical Guide 244, and classified sources. This review established a total of 151 toxic industrial chemicals and chemical warfare agents (TIC-CWA) as potential candidates for challenge agents. The candidate agents were evaluated for permeation (molecularly diffusing through material) and penetration (seeping through interfacing components) characteristics as part of a review of their physical properties.” “This evaluation concluded that Sarin (GB) and Sulfur Mustard (HD) could be selected as the two representative agents for the penetration/permeation test for the complete listing of 151 CWA and TICs due to their physical properties and molecular structure.” “NIOSH is unaware of any data that indicates the CBRN respirators provide less protection against TICs than their industrial counterparts. The evaluation for CBRN protection provides verification and assurance that the component and material combinations in the approved SCBA configurations provide high resistance to permeation and penetration of hazardous atmospheres of toxic industrial chemicals and materials into the breathing air. This is of importance to all responders subject to extreme exposures to any hazardous industrial chemicals and materials.”

1981-40

Report on Comments F2006 — Copyright, NFPA NFPA 1981 The TCC, acting in accordance with 3.4.3(g) of the RGCPs, “Determining whether or not the TC has given due consideration to all evidence presented to it in connection with the preparation of its Report including all comments relating to negative votes” does not believe the TC gave full and appropriate review and due consideration to all the issues and, therefore has taken these actions. In addition to the action taken on 1981-59, the following comments will be affected by this change and, therefore, the following changes must be made to these comments 1981-34 In action #2, change action from “Reject” to “Accept” 1981-50 Change action from “Accept in Principle” to “Reject” 1981-51 Change action from “Accept in Principle” to “Reject” 1981-52 Change action from “Accept in Principle” to “Reject” 1981-53 Change action from “Accept in Principle” to “Reject” 1981-54 Change action from “Accept in Principle” to “Reject” 1981-55 Change action from “Accept in Principle” to “Reject” 1981-56 Change action from “Reject” to “Accept” 1981-57 Change action from “Accept in Principle” to “Reject” 1981-58 Change action from “Accept in Principle” to “Reject” 1981-84 Change action from “Accept in Principle” to “Reject” 1981-85 Change action from “Accept in Principle” to “Reject” 1981-86 Change action from “Accept in Principle” to “Reject” 1981-87 Change action from “Accept in Principle” to “Reject”Submitter: John F. Heffren, Burgess Fire Equipment Co.Comment on Proposal No: 1981-�Recommendation: SCBA that are certified as compliant with NFPA 1981 shall also be certified by NIOSH as a CBRN SCBA.Substantiation: SCBA covered under this standard will primarily be used for firefighting, complete CBRN safety dictates the use of other clothing other than current technology structural firefighting technology. Testing for NIOSH CORN compliance will significantly lengthen and increase the cost of testing, thereby limiting needed future innovation of SCBA equipment. Many small communities are currently having difficulty affording SCBA under the current standard.Committee Meeting Action: RejectCommittee Statement: The submitter did not clearly communicate what the recommendation was. See committee action on Comment 1981-59 (Log #16�).

____________________________________________________________1981-87 Log #19� FAE-RPE Final Action: Reject(6.1.3)____________________________________________________________TCC Action: The Technical Correlating Committee REJECTS this comment. The TCC carefully reviewed the issues regarding the CBRN requirements being deleted from the proposed 2008 edition of NFPA 1981, including those expressed in the negative ballots on this issue, and the verbal positions heard from TC and TCC members. In accordance with the Regulations Governing Committee Projects (RGCPs), the TCC is taking the action it deems necessary in accordance with its authority as defined in 3.4.2, and in 4.4.7.1: “…The TCC shall be permitted to choose between alternatives presented by the TCs or develop text, as it deems necessary, to achieve correlation, consistence, and the correction of errors and omissions...” The TCC was concerned that some TC members expressed the opinion that while they did see a need for CBRN SCBA in their organization, they didn’t believe that it was necessary throughout the country and that individual departments should make their own determination, and another opinion was that it would be wrong to make other departments pay so much more for their SCBA when they don’t foresee a need for them. There is no way that anyone can predict where a future CBRN event will occur in this country. The terrorist threat is a reality not only in larger metropolitan areas but also in smaller communities and rural areas where terrorists would seek to severely affect the economy or bring it to a halt. While we can and should prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. In the Committee process, all members come to the table with a bias and represent their sponsoring organization’s feelings, but the safety, well being, and protection of the emergency responders must be the goal and local issues should take a secondary position to the improvement of safety for the emergency responders performing in the hazardous environments. In regards to cost, some TC members argued the point that municipalities should have a choice in what SCBA they purchase. In opposition to this stance, one TC member (King) stated, “There is no way that anyone can predict where a future CBRN event will occur in this country. While we can (and should) prioritize where we think an event is most likely to occur, that certainly does not ensure that an event cannot occur somewhere else. In addition, as local first responders become overwhelmed by an event, back up responders may come from greater distances especially in rural areas. It is interesting to note that a couple of the first responders who voted

against having mandatory CBRN compliant SCBA in this standard acknowledge that their own department insists on CBRN compliant SCBA when purchasing new equipment.” Another TC member (Rossos) stated, “I disagree with the committee’s action regarding CBRN; therefore I must vote in the negative. I believe it is our purpose and responsibility as members of the Committee to strive to design SCBA standards and codes where the end user has the highest level of protection possible. I realize as an end user, that we need to strike a balance between best protection and secondary effects such as comfort, size, weight, etc. and in some regards even economics. We were given no evidence of any of the above compromises to mandating CBRN on all SCBAs. The only thing that we know for sure is that the end user would have a higher level of protection with CBRN as opposed to without. Very few end users have a choice in this matter. Most choices are made by purchasing agents or administrators who often base their decisions on the minimum legal standard available for the lowest price. I believe our first and most important responsibility on this committee is to those who wear SCBA, not to who buys SCBA. Regretfully, when there was no cost involved or reduction in protection, we voted to give the choice to the buyer and not the user.” This was based on the fact that all SCBA manufacturers present at the TC ROC meeting stated that the increased cost of CBRN protection for SCBA was negligible (under $100) or none. Also, TC Chairman Reed responded, “The argument during ROC was that many parts of the country may not have a need for CBRN protection. Unfortunately, in the post 9/11 world, I think this is being unrealistic. While major metropolitan areas may be more likely targets of a terrorist event, we have already seen that the terrorists themselves may reside in small communities while they await their opportunity to strike. They may have the chemical, biological, or nuclear material in their possession, making the possibility of exposure greater for even small, rural areas. But terrorist attacks aside, CBRN-certified SCBA offers greater protection for the fire fighter for a very minimal cost. If this protection is not required by the standard, many jurisdictions will not specify this for their fire fighters.” To the issue about CBRN compliant SCBA are uncomfortable to wear, this appears to be limited to one or two manufacturers’ chosen materials and the reality appears to be that first responders using CBRN SCBA are not reporting any significant difference relating to the comfort of the equipment and other manufacturers report no complaints from organizations who have purchased and use CBRN SCBA. And to the issue of CBRN compliant SCBA will not be as durable, there appears to be no reason to believe that CBRN compliant SCBA are any less durable than the non-CBRN compliant products on the market today and NIOSH has not received any complaints or identified any durability problems of CBRN SCBA over “regular” SCBA. To the issue of correlation and consistence, the TCC notes that other standards do require CBRN SCBA including NFPA 1500, Standard on Fire Department Occupational Safety and Health Program, 7.11.1.1 of the 2007 edition; 42 CFR 84, Respiratory Protective Devices, and the Statement of Standard for NIOSH CBRN SCBA Testing; and Section 5(A)(1) of the Occupational Safety and Health Act. The TCC believes that lack of correlation with these standards and regulations causes a strong potential decrease of safety for emergency responders due to purchasers believing that as NFPA 1981 is silent on CBRN requirements they do not to have that protection. The TCC further notes that the Department of Homeland Security (DHS) has formally adopted the NIOSH Statement of Standard for NIOSH CBRN SCBA Testing as one of the standards for first responder PPE. Only SCBA that have been approved by NIOSH as CBRN SCBA, which also requires certification to NFPA 1981, can be listed in the Authorized Equipment List (AEL), established by the DHS Office of Grants and Training as the list of recommended equipment for emergency responders. Purchase of SCBA with federal monies through several of the government grant programs requires that SCBA have CBRN approvals from NIOSH. In addition, the InterAgency Board for Equipment Standardization and Interoperability (the IAB) has established CBRN SCBA as the only qualified SCBA in its Standardized Equipment List (SEL). This SEL further provides detailed recommendations for first responder PPE. While NFPA 1500 provides requirements for fire departments, it does not provide requirements for non-fire based emergency responders. NFPA 1981, Standard for Open-Circuit Self-Contained Breathing Apparatus for Emergency Services, does provide SCBA requirements for any emergency services organization that needs protection from IDLH atmospheres. IDLH protection can only be provided by SCBA. The shortsightedness of the TC in removing the CBRN requirement leaves law enforcement responders, emergency medical responders, non-fire based hazardous materials response teams, and the skilled trades emergency responders without CBRN respiratory protection.

1981-41

Report on Comments F2006 — Copyright, NFPA NFPA 1981 CBRN protection offers verification of enhanced protection for emergency responders which is not otherwise available. Without CBRN protection evaluation, no SCBA components are tested for permeation, penetration, corrosion resistance, or other detrimental effects from exposure to hazardous chemical warfare atmospheres. NIOSH benchmark testing of non-CBRN hardened NIOSH certified SCBA against CBRN agents demonstrated that CWA agents could cause catastrophic failures within minutes of exposure. A comment by a TC member (Birch) stated, “…it is proper at this point in time to not require CBRN is because although NIOSH and other agencies make/made a good point of testing SCBAs against the list of chemical agents, there are missing tests. There are no tests to show that SCBAs as manufactured now, when altered to meet CBRN requirements, are still resistant to the ‘normal’ atmospheres and chemical agents in which they are currently used.” NIOSH (Boord) countered with, “The selection of the test challenge agents for CBRN protection was based on a comprehensive review of available technical data and consultations with other government agencies (e.g., DOD, DOJ, DOE, etc.). Various chemical data lists were analyzed, including lists from the EPA, ATSDR, NFPA 1994, U.S. Army Center for Health Promotion and Preventative Medicine (USACHPPM) Technical Guide 244, and classified sources. This review established a total of 151 toxic industrial chemicals and chemical warfare agents (TIC-CWA) as potential candidates for challenge agents. The candidate agents were evaluated for permeation (molecularly diffusing through material) and penetration (seeping through interfacing components) characteristics as part of a review of their physical properties.” “This evaluation concluded that Sarin (GB) and Sulfur Mustard (HD) could be selected as the two representative agents for the penetration/permeation test for the complete listing of 151 CWA and TICs due to their physical properties and molecular structure.” “NIOSH is unaware of any data that indicates the CBRN respirators provide less protection against TICs than their industrial counterparts. The evaluation for CBRN protection provides verification and assurance that the component and material combinations in the approved SCBA configurations provide high resistance to permeation and penetration of hazardous atmospheres of toxic industrial chemicals and materials into the breathing air. This is of importance to all responders subject to extreme exposures to any hazardous industrial chemicals and materials.” The TCC, acting in accordance with 3.4.3(g) of the RGCPs, “Determining whether or not the TC has given due consideration to all evidence presented to it in connection with the preparation of its Report including all comments relating to negative votes” does not believe the TC gave full and appropriate review and due consideration to all the issues and, therefore has taken these actions. In addition to the action taken on 1981-59, the following comments will be affected by this change and, therefore, the following changes must be made to these comments 1981-34 In action #2, change action from “Reject” to “Accept” 1981-50 Change action from “Accept in Principle” to “Reject” 1981-51 Change action from “Accept in Principle” to “Reject” 1981-52 Change action from “Accept in Principle” to “Reject” 1981-53 Change action from “Accept in Principle” to “Reject” 1981-54 Change action from “Accept in Principle” to “Reject” 1981-55 Change action from “Accept in Principle” to “Reject” 1981-56 Change action from “Reject” to “Accept” 1981-57 Change action from “Accept in Principle” to “Reject” 1981-58 Change action from “Accept in Principle” to “Reject” 1981-84 Change action from “Accept in Principle” to “Reject” 1981-85 Change action from “Accept in Principle” to “Reject” 1981-86 Change action from “Accept in Principle” to “Reject” 1981-87 Change action from “Accept in Principle” to “Reject”Submitter: John F. Heffren, Burgess Fire Equipment Co.Comment on Proposal No: 1981-�Recommendation: SCBA that are certified as compliant with NFPA 1981 shall also be certified by NIOSH as a CBRN SCBA.Substantiation: Why worry about CBRN whenever the government is turning the seaports over to Al-Qaeda.Committee Meeting Action: RejectCommittee Statement: The submitter is not clear on his recommendation and the committee doubts the White House will respond or clarify. See committee action on Comment 1981-59 (Log #16�).

____________________________________________________________1981-88 Log #96 FAE-RPE Final Action: Accept(6.1.4)____________________________________________________________Submitter: Neal A. Baluha, Fir Prtoectoin AlternativesComment on Proposal No: 1981-�Recommendation: Revise text to read as follows: SCBA shall consist of all the components necessary for NIOSH certification in accordance with 4� CFR 84, and an interchangeable SCBA cylinder and valve assembly, at least two independent End-of-Service-Time indicators (EOSTI), etc.

Substantiation: Interchangeable cylinders are not possible with multiple pressure platforms (��16)(4500)(�000) psi. There is no guarantee from manufacturers of backward compatibility with current SCBA models, thereby creating any interchangeable problem within same department using new and existing SCBA can stifle design creativity with new SCBA models or long duration SCBA.Committee Meeting Action: Accept

____________________________________________________________1981-89 Log #186 FAE-RPE Final Action: Accept(6.1.4)____________________________________________________________Submitter: Dwayne Wolfe, Anchorage International Airport Police and Fire DepartmentComment on Proposal No: 1981-�Recommendation: Revise as follows: SCBA shall consist of all the components necessary for NIOSH certification in accordance with 4� CFR 84, and an interchangeable SCBA cylinder and valve assembly, at least two independent end-of-service-time indicators (EOSTI), heads up display (HUD), communications enhancement and a rapid intervention crew/company universal air connection (RIC UAC).Substantiation: By deleting the wording proposed, hidden costs of the NFPA 1981 new proposal in terms of new equipment purchases, training costs, and the financial strain on small departments like mine will be avoided, more research and dialogue with the user community on cylinder interchangeability is required before such design requirements are officially included in the NFPA 1981 standard.Committee Meeting Action: Accept

____________________________________________________________1981-90 Log #�05 FAE-RPE Final Action: Accept in Principle(6.1.4)____________________________________________________________Submitter: Salvatore Cassano, New York City Fire DepartmentComment on Proposal No: 1981-�Recommendation: Eliminate all references to the requirement for interchangeable SCBA breathing air cylinders as well as associated references and testing requirements.Substantiation: The changes recommended by this standard cold decrease rather enhance firefighter safety. The requirement for interchangeable cylinders could have a negative effect on product innovation at a cost to firefighter safety. There has not been any evidence presented to document the need for interchangeability. Not all Fire Departments use the same pressure; therefore interchangeability will only be achieved via a single universal pressure. Forward/backward compatibility will not be assured placing departments in a position of lacking compatibility among existing vendors.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-91 Log #� FAE-RPE Final Action: Reject(6.1.5)____________________________________________________________Submitter: David Hodson, Draeger Ltd.Comment on Proposal No: 1981-1Recommendation: Remove the words “independently operating”.Substantiation: Manufactures that choose an electronic solution to this requirement do not want to duplicate the electronic systems and hence give significant logistic and cost implications to the end user. The goal of the manufacture is to make a reliable robust system which meets the needs of the end user. The pressure monitoring device and its power supply does not need to be duplicated but simply made to meet requirements of the fire service. A single monitoring device and power supply which is robust and reliable and perhaps rechargeable is a better end user solution than having a complex multi monitoring/power supply system. The standard already accommodates lower battery warning this is sufficient to ensure a functional design. The logistics of a single robust monitoring device and power source significantly improves end user maintenance and will give a reduction in SCBA downtime.Committee Meeting Action: RejectCommittee Statement: The committee feels it is necessary to have a “back up” should the HUD fail.

____________________________________________________________1981-9� Log #7� FAE-RPE Final Action: Accept(6.1.5)____________________________________________________________Submitter: David Hodson, Draeger Ltd.Comment on Proposal No: 1981-�Recommendation: Revise text to read:

6.1.5 In addition to the HUD and the cylinder mounted breathing air pressure gauge, all SCBA shall have another independently operating breathing air pressure gauge that shall be capable of being viewed

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Report on Comments F2006 — Copyright, NFPA NFPA 1981by the wearer when the SCBA is worn in accordance with the SCBA manufacturer’s instructions.

6.1.5.1 The design of this independently operatig breathing air pressure gauge shall be such that the failure of one breathing air pressure gauge shall not affect the activation and operation of other breathing air pressure gauge.

6.1.5.2 A failure mode and effects analysis shall be provided to the certification organization for each independently operating breathing air pressure gauge.

6.1.5.3 The failure mode and effects analysis shall identify each potential failure mode for each component necessary for the independently operating breathing air pressure gauge to function.

6.1.5.4 The failure mode and effects analysis shall demonstrate that the activation and operation of the independently operating breathing air pressure gauge specified in 6.1.5 is not affected by any of the potential failure modes, as identified in accordance with 6.1.5.�, of all other breathing air pressure gauges.Substantiation: Independence defined as power source. This will ensure function of either the HUD or the gauge should one of the power sources fail.Committee Meeting Action: Accept

____________________________________________________________1981-9� Log #165 FAE-RPE Final Action: Accept in Principle(6.1.5)____________________________________________________________Submitter: John Morris, International Safety Instruments, Inc.Comment on Proposal No: 1981-�Recommendation: Change “independently operating” to “remote”. 6.1.5 In addition to the HUD and cylinder pressure gauge, all SCBA shall have a remote breathing air pressure gauge that is capable of being viewed by the wearer when the SCBA is properly worn in accordance with the SCBA manufacturer’s instructions.Substantiation: “Independently operating” would prohibit digital gauges operating off the same pressure transducer as the HUD. Digital gauges provide superior viewing in low light versus pneumatic gauges. Failure of a pneumatic gauge could result in loss of breathing air. HUD failure should indicate need for user to exit IDLH atmosphere.Committee Meeting Action: Accept in Principle See committee action on Comment 1981-9� (Log #7�).Committee Statement: See committee action on Comment 1981-9� (Log #7�).

____________________________________________________________1981-94 Log #11 FAE-RPE Final Action: Accept(6.1.7)____________________________________________________________Submitter: Fred H. Rascoe, International Safety Instruments, Inc.Comment on Proposal No: 1981-4Recommendation: Revise text to read as follows: 6.1.7 All electric circuits integral to an SCBA or to any SCBA accessories shall be certified to the requirements for Class I, Groups C and D; Class �, Groups E, F, and G; Division I hazardous locations specified in ANSI/UL 91�, Standard for Intrinsically Safe Apparatus and Associated Apparatus for Use in Class I, II, and II, Division I Hazardous Locations.Substantiation: While in the process of drafting the �007 edition of NFPA 198� (for PASS) it was the consensus of opinion that we should take a good look at our current level of intrinsic safety. Many, if not all of the enhancements we discussed such as, increased sound pressure, new and innovative form factors, extended battery life and the addition of future capabilities such as transmitters, evacuators, data logging and personnel locators would face serious design restrictions given the current level of intrinsic safety. During our research we learned that intrinsically safe portable radios currently used by the fire service do not include groups A and B. The radio manufacturers do not include these groups because they would experience the very same design restrictions. The portable radio and the PASS Device are going to be exposed to the same environmental conditions. It seems logical to us that both products should require the same level of intrinsic safety. By eliminating Groups A and B from the requirements it will allow manufacturers to design the electronics with more flexibility to meet the current and future demands by the end users. This does not mean that the electronics will not be safe for limited operations in Group A (acetylene) and Group B (hydrogen) enriched atmospheres. It means that they will not be tested for two fault conditions in the Class A and B environments. (A test performed by a laboratory that would be nearly impossible to recreate on the emergency scene.) The electronics will be tested for groups C and D which represent approximately 85 percent of all the other combustible elements. After careful review by end users, manufacturers, testing laboratories (ETL, UL) and the third party compliance organization (SEI), the Technical Committee for ESE/PASS voted to propose elimination of groups A and B for intrinsic safety. This vote was taken during ESE TC November �005 meeting.

After thorough discussion the ESE TC also agreed that this change in intrinsic safety should extend to NFPA 1981 for RPE where current and future design would be subject to the same restrictions.Committee Meeting Action: Accept

____________________________________________________________1981-95 Log #100 FAE-RPE Final Action: Accept(6.1.7)____________________________________________________________Submitter: Jack Jarboe, Grace IndustriesComment on Proposal No: 1981-�Recommendation: Revise text to read as follows: All electric circuits integral to an SCBA or to any SCBA accessories shall be certified to the requirements for Class I, Groups C and D: Class �, Groups E, F and G: Division I hazardous locations specified in ASNI/UL 91�, Standard for Intrinsically Safe Apparatus and Associated Apparatus for use in Class I, II, and III, Division I Hazardous Locations.Substantiation: While in the process of drafting the �007 edition of NFPA 1981 (for PASS) it was the consensus of opinion that we should take a good look at our current level of intrinsic safety. Many, if not all of the enhancements we discussed such as, increased sound pressure, new and innovative form factors, extended battery life and the addition of future capabilities such as transmitters, evacuators, data logging and personnel locators would face serious design restrictions given the current level of intrinsic safety. During our research we learned that intrinsically safe portable radios currently used by the fire service do not include groups A and B. The radio manufacturers do not include these groups because they would experience very same design restrictions. The portable radio and the PASS Device are going to be exposed in the same environmental conditions. It seems logical to us that both products should require the same level of intrinsic safety. By eliminating Groups A and B from the requirements it will allow manufacturers to design the electronics with more flexibility to meet the current and future demands by the end users. This does not mean that the electronics will not be safe for limited operations in Group A (acetylene) and Group B (hydrogen) enriched atmospheres. It means that they will not be tested for two fault conditions in the Class A and B environments. (A test performed by a laboratory that would be nearly impossible to recreate on the emergency scene). The electronics will be tested for groups C and D which represent approximately 85 percent of all the other combustible elements. After careful review by end users, manufacturers, testing laboratories (ETL, UL) and the third party compliance organization (SEI), the Technical Committee for ESE / PASS voted to propose elimination of groups A and B for intrinsic safety. This vote was taken during ESE TC November �005 meeting. After thorough discussion the ESE TC also agreed that this change in intrinsic safety should extend to NFPA 1981 for RPE where current and future design would be subject to the same restrictions.Committee Meeting Action: Accept

____________________________________________________________1981-96 Log #104 FAE-RPE Final Action: Accept in Principle(6.1.7)____________________________________________________________Submitter: Michael T. Rupert, MSAComment on Proposal No: 1981-�Recommendation: Revise text as follows: 6.1.7 All electric circuits integral to an SCBA or to any SCBA accessories shall be certified to the requirements for Class I, Division I hazardous locations specified in ANSI/UL 91�, Standard for Intrinsically Safe Apparatus and Associated Apparatus for Use in Class I, II and III, Division I Hazardous Locations.

6.1.7 All electronic circuits integral to the SCBA shall be tested for intrinsic safety as specified in UL 91�, Standard for Intrinsically Safe Apparatus and Associated Apparatus for Use in Class I, II, and III, Division 1 Hazardous Locations, and shall meet the requirements for Class I, Groups C, and D; and Class �, Groups E, F, and G; Division 1 hazardous locations.Substantiation: Remove intrinsic safety groups A and B, to reflect decisions at committee meetings, which should be documented in previous meeting minutes. This is also reflected in the NFPA 198� PASS standard.Committee Meeting Action: Accept in Principle See committee action on Comment 1981-94 (Log #11).Committee Statement: See committee action on Comment 1981-94 (Log #11).

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Report on Comments F2006 — Copyright, NFPA NFPA 1981____________________________________________________________1981-97 Log #148 FAE-RPE Final Action: Reject(6.1.7)____________________________________________________________Submitter: A. Paul Bull, Fairfax County Fire and Rescue DepartmentComment on Proposal No: 1981-�Recommendation: Revise text to read as follows: “...for SCBA accessories (communication device) change Intrinsic Safety level to Class 1, Division II.”Substantiation: The proposed performance benefits outweigh the minimum risk with changing this level. There is no documentation we are aware of that Class I, Division I is necessity in fire ground operations.Committee Meeting Action: RejectCommittee Statement: See committee action on Comment 1981-94 (Log #11).

____________________________________________________________1981-98 Log #158 FAE-RPE Final Action: Reject(6.1.7)____________________________________________________________Submitter: A. Paul Bull, Fairfax County Fire and Rescue DepartmentComment on Proposal No: 1981-�Recommendation: For SCBA accessories (communication device) change Intrinsic Safety level to Class I, Division II.Substantiation: The proposed performance benefits out-way the minimum risk with changing this level. There is no documentation we are aware of that Class I, Division I is a necessity in fire ground operations.Committee Meeting Action: RejectCommittee Statement: See committee action on Comment 1981-94 (Log #11).

____________________________________________________________1981-99 Log #160 FAE-RPE Final Action: Reject(6.1.7)____________________________________________________________Submitter: John Morris, International Safety Instruments, Inc.Comment on Proposal No: 1981-�Recommendation: Remove 6.1.7 - Intrinsic Safety requirements.Substantiation: Elimination of Intrinsic Safety requirements will allow for manufacturers to improve the power output, battery life and sound pressure levels at high temperatures. Since Section “8.�6 Immersion Leakage Test” requires the electronics to be sealed to a depth of 5 ft, the electronics are adequately protected from the environment for fire fighting applications. Furthermore, additional equipment such as some flash lights and radios are not intrinsically safe.Committee Meeting Action: RejectCommittee Statement: See committee action on Comment 1981-94 (Log #11) where intrinsic safety classification was revised.

____________________________________________________________1981-100 Log #109 FAE-RPE Final Action: Accept(6.3.3, 7.13.1.2, and 8.1.5.6)____________________________________________________________Submitter: Michael T. Rupert, MSAComment on Proposal No: 1981-�Recommendation: Revise text to read: 6.�.� Change 17.0 bar (�50 psi) to read “�0 bar (�90 psi)”. 7.1�.1.� After activation of the unblocked EOSTI, the alarm signal shall remain active at least until the cylinder pressure drops below �0 bar (�90 psi). 17.0 bar (�50 psi). 8.1.5.6 The air flow performance test shall begin after 5 cycles of the breathing machine and continue to operate through at least �0 bar (�90 psi) of cylinder inlet pressure. �0 cycles of the breathing machine after actuation of each EOSTI specified in Section 6.�, End of Service Time Indicator.Substantiation: The ROP has an editing error. The �0 bar (�90 psi) is what was agreed upon in the Burlington meeting, however the Burlington meeting minutes did not have this level of detail. This was documented however in Mike Rupert’s personal meeting notes.Committee Meeting Action: Accept

____________________________________________________________1981-101 Log #7� FAE-RPE Final Action: Accept in Principle(6.3.8.6)____________________________________________________________Submitter: Jeffrey L. Landis, Tyco/Scott Health and SafetyComment on Proposal No: 1981-�Recommendation: Replace 6.�.8.6 to read: 6.�.8.6 Where a portable power source is used for HUD to comply with the requirements of this standard, HUD shall display a visual alert signal for low power source when the remaining power source life will provide a minimum of � hours of operation of the HUD at maximum current draw.Substantiation: A comment was submitted proposing changes to paragraphs in Section 8.16, HUD Low-Power Supply Visual Alert Signal Test. The proposed wording would replace “Power Supply” with “Power Source” throughout the text. This proposal also removed the references to “battery power supply” in 8.16.7.�, and replaced the text with “portable power source”.Committee Meeting Action: Accept in Principle See committee action on Comment 1981-�1� (Log #�49).Committee Statement: See committee action on Comment 1981-�1� (Log #�49).

____________________________________________________________1981-10� Log #74 FAE-RPE Final Action: Accept in Principle(6.3.8.6.1 and 6.3.8.6.2)____________________________________________________________Submitter: Jeffrey L. Landis, Tyco/Scott Health and SafetyComment on Proposal No: 1981-�Recommendation: 6.�.8.6.1 Replace “low-battery” with “low-power source”. Replace 6.�.8.6.� with the following: 6.�.8.6.� The low-power source visual alert signal shall be displayed at all times when the power source condition is below the level specified in 6.�.8.6, while the HUD is activated.Substantiation: A comment was submitted proposing changes to paragraphs in Section 8.16, HUD Low-Power Supply Visual Alert Signal Test. The proposed wording would replace “Power Supply” with “Power Source” throughout the text. This proposal also removed the references to “battery power supply” in 8.16.7.�, and replaced the text with “portable power source”.Committee Meeting Action: Accept in Principle See committee action on Comment 1981-�1� (Log #�49).Committee Statement: See committee action on Comment 1981-�1� (Log #�49).

____________________________________________________________1981-10� Log #115 FAE-RPE Final Action: Accept(6.4 through 6.4.8.3)____________________________________________________________Submitter: David Williams, North Kansas City Fire DepartmentComment on Proposal No: 1981-�Recommendation: The Missouri Association of Fire Chiefs supports all of the language that requires Universal Air Connection (RIC UAC) System Design Requirements.Substantiation: The Missouri Association of Fire Chiefs supports Rapid Intervention Crew/Company Universal Air Connection (RIC UAC) System Design Requirements. The combined experience of the Missouri Fire Chiefs membership believe that a universal connection will improve fire fighter safety.Committee Meeting Action: Accept

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Report on Comments F2006 — Copyright, NFPA NFPA 1981____________________________________________________________1981-104 Log #8 FAE-RPE Final Action: Accept(Figure 6.4.5.1)____________________________________________________________Submitter: Gary Lisenbec, Eaton CorporationComment on Proposal No: 1981-�Recommendation: FIGURE 6.4.5.1 RIC UAC Male Fitting (all measurements in inches). [Existing Figure 6.4.5.1, �00� ed. (no change)]

Number Current Proposed Comment1 0.�187 Dia. Gauge ball 0.�500 Dia. Gauge ball2 0.0875+/-0.015 0.084+/-0.0193 0.760+/-0.015 0.750+/-0.0�54 1.14�8+/-0.0075 1.1�5+/-0/0155 0.150+/-0.010 0.1875+/-0.04756 0.�5�+/-0.001 0.�5�+/-0.001 Error in line art from current specification.

Represent measurement of part ID.

Substantiation: The proposed changes have been made to Figure 6.4.5.1 to enable improved sealing capabilities which would allow for lower temperature performance from -��°C (-�5°F to -40°C (-40°F). The proposal also allows complete interchangeability with existing RIC UAC female coupling halves (Eaton Corporation will warrant this statement in writing). The proposed changes will have zero negative impact on RIC UAC couplings currently in the field. All paragraphs within 6.4.5 and 6.4.6 will remain current and require no changes.Committee Meeting Action: Accept

____________________________________________________________1981-105 Log #�0 FAE-RPE Final Action: Accept in Principle(6.4.7.16, 8.23 through 8.26)____________________________________________________________Submitter: Robert DeBold, Aberdeen, NJComment on Proposal No: 1981-�Recommendation: Delete entire section.Substantiation: My department is fully capable of recharging existing cylinders of our town and all mutual aid towns. There is no known problems with filling cylinders in the entire county of Monmouth, NJ.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-106 Log #6 FAE-RPE Final Action: Accept in Principle(6.5)____________________________________________________________Submitter: James Hinton, City of FoleyComment on Proposal No: 1981-1Recommendation: The idea of interoperability between air cylinders needs to be deleted.Substantiation: It seems as though the people appointed to the NFPA Technical Committees more often than not miss the mark, as has been done in this case. It is ludicrous to think that a drastic change such as this would be made, when integrated PASS devices are still not required on SCBA units. What is killing more firefighters? The fact that SCBA bottles are not interoperable, or the fact we cannot find them because their PASS device was not on? As for the gentlemen’s comment pertaining to MS and LA, there were much larger problems there than interoperability of cylinders. There is only one manufacturer at present that makes a cylinder that is not interoperable with other SCBA units. We were forced to comply with the HUD and we did, although in my opinion you can’t beat an analog pack strap gauge, that is not electronic and now not required to be on an SCBA. Don’t make us comply with another unfunded mandate, especially now that DHS has backed out on their original statement.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-107 Log #�7 FAE-RPE Final Action: Accept in Principle(6.5)____________________________________________________________Submitter: Mike Burner, Oklahoma City, OKComment on Proposal No: 1981-�Recommendation: Interchangeable air cylinders should be removed from the proposed �007 edition.

Substantiation: Cylinder interchangeability has not been an issue in our metro area. In addition, the costs to upgrade current inventory could be substantial. There has not been factual data presented to support this proposal.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-108 Log #�5 FAE-RPE Final Action: Accept in Principle(6.5)____________________________________________________________Submitter: Jeffrey Pells, Arlington Fire Dist., NYComment on Proposal No: 1981-�Recommendation: Interoperability between SCBA air packs and cylinders should not be addressed in this document. Substantiation: Standards that can have a severe financial impact without some sort of financial assistance will not make compliance but will cause interoperability within departments as well as inter department for many years while departments try to come in compliance due to added equipment or attrition of equipment. Ideas should be directed at making all air cylinders capable of being filled and managed instead of universal compliance. Regional air filling systems should be pursued. Adapters can be used to facilitate filling of cylinders that have different connections and limit the costs associated with this. Systems can then be compatible with filling SCUBA bottles if able to deliver the appropriate class air. Many areas already have a way to fill cylinders and costs to have these changed to allow them to fill all cylinders will be more effective and less intrusive. Using existing connection as the models and not allowing additional ones to be developed would limit the number of adapters needed and allow manufacturers flexibility for production. Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-109 Log #�7 FAE-RPE Final Action: Accept in Principle(6.5)____________________________________________________________Submitter: Denis Pilon, Weyburn Fire DepartmentComment on Proposal No: 1981-�Recommendation: Delete entire Section 6.5.Substantiation: The proposed Section 6.5 does not answer the current need by the fire service for interchangeable cylinders. We are not asking that the cylinder be redesigned, but that we be allowed to use cylinders by manufacturers other than the one who made the SCBA. Most cylinders are already physically able to fit on other SCBA’s but are not allowed to be used because of NIOSH certification rules. What the fire service needs, is a relaxation of the rule requiring only the SCBA manufacturers cylinders can be used, not a redesigned cylinder. If the rule is relaxed, the manufacturers will come up with a useable design on their own and the market place will dictate what is purchased in the future. Meanwhile, current SCBA users will be able to interchange any cylinders that fit properly when operating at mutual aid incidents. Finally, many small departments will purchase SCBA once every 40 or 50 years. It could be years before any newly designed cylinder is in adequate supply to meet the needs of fire departments for interchangeable cylinder use.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-110 Log #70 FAE-RPE Final Action: Accept in Principle(6.5)____________________________________________________________Submitter: David Hodson, Draeger Ltd.Comment on Proposal No: 1981-�Recommendation: Revise Section 6.5 and all other sections which pertain to interchangeable breathing air cylinder and valve assembly.Substantiation: It is the goal of a manufacture to meet the needs of the end user using both unique and progressive design. Advances in material

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Report on Comments F2006 — Copyright, NFPA NFPA 1981and design tools give the ability to extent and progress the boundaries of current design to satisfy new demands set by the market. Having a standard cylinder and valve assembly will stop innovation and stagnate advances in ergonomics and functionality for a long time perhaps as long as �0 years. It is felt that benefits of standardization although tangible (but limited by different cylinder pressures) are outweighed by the need to continue with new and advanced design.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-111 Log #79 FAE-RPE Final Action: Reject(6.5)____________________________________________________________Submitter: William Troup, United States Fire AdministrationComment on Proposal No: 1981-�Recommendation: DHS USFA supports the concept of SCBA Air Cylinder Interoperability and strongly recommends that the language in Section 6.5 of the proposed �007 edition of NFPA 1981 regarding SCBA Interchangeable Breathing Air Cylinder and Valve Assembly Design Requirements remain in its entirety in the standard.Substantiation: Air cylinder interoperability for SCBA is essential for both firefighter health and safety and effective fire service operations. Such interoperability is important in any instance where multiple fire departments using SCBA from different manufacturers are working together. By having interoperable air cylinders, response efforts are not encumbered by firefighters having to find an air cylinder that fits. This would also reduce the burden of logistical support for such events by eliminating the need for a supply of multiple types of air cylinders to support emergency response operations. In many communities of the United States, fire departments are dependent on automatic and mutual aid to respond to regular small-scale emergencies such as a room-and-contents fire in a single family home. The argument for air cylinder interoperability in large scale events applies equally to the regular day-to-day operations of thousands of smaller departments where mutual aid units may not have compatible air cylinders. Having interoperable air cylinders that ensure air supplies are readily available will greatly enhance the health and safety of emergency responders. This is why it is essential for the language supporting interoperable air cylinders in Section 6.5 remain in NFPA 1981. Committee Meeting Action: RejectCommittee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-11� Log #97 FAE-RPE Final Action: Accept in Principle(6.5)____________________________________________________________Submitter: Frank Hilbert, Mystic Connecticut Fire DepartmentComment on Proposal No: 1981-�Recommendation: Delete in entirety Section 6.5. Proposal creates more problems than it solves. Issues of differing cylinders should be addressed at mobile and stationary fill stations and not by creating a cylinder capability debacle.Substantiation: None given.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-11� Log #156 FAE-RPE Final Action: Accept in Principle(6.5)____________________________________________________________Submitter: A. Paul Bull, Fairfax County Fire and Rescue DepartmentComment on Proposal No: 1981-�Recommendation: Delete entire section and all reference to Interchangeable Breathing Air cylinder and Valve assembly requirements.Substantiation: This requirement is not needed at the current time by the fire service and its cost cannot be justified. There are other means to assist departments in maintaining their bottle inventories. While the concept is interesting, there are other areas of fire fighting equipment that would benefit more from interchangeability and at a reduced cost than SCBA’s. Additionally we have not shown any benefit for fire fighter safety with this issue.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-114 Log #�0� FAE-RPE Final Action: Accept in Principle(6.5)____________________________________________________________Submitter: Salvatore Cassano, New York City Fire DepartmentComment on Proposal No: 1981-�Recommendation: Eliminate all references to the requirement for interchangeable SCBA breathing air cylinders as well as associated references and testing requirements.Substantiation: The changes recommended by this standard could decrease rather enhance firefighter safety. The requirement for interchangeable cylinders could have a negative effect on product innovation at a cost to firefighter safety. There has not been any evidence presented to document the need for interchangeability. Not all fire departments use the same pressure; therefore interchangeability will only be achieved via a single universal pressure. Forward/backward compatibility will not be assured placing departments in a position of lacking compatibility among existing vendors.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-115 Log #�16 FAE-RPE Final Action: Reject(6.5)____________________________________________________________Submitter: Les Boord, NIOSHComment on Proposal No: 1981-�Recommendation: New bullet Section 6.5” The cylinder valve provided as part of the SCBA manufacturer’s breathing air cylinder and valve assembly shall be operable by the right hand of he SCBA wearer when the SCBA is properly worn in accordance with the SCBA manufacturer’s instructions and with the breathing air cylinder securely retained in the SCBA backframe.Substantiation: The cylinder valve orientation was not adequately defined.Committee Meeting Action: RejectCommittee Statement: Section 6.5 has been deleted as it applied to cylinder interchangeability. See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-116 Log #��1 FAE-RPE Final Action: Reject(6.5)____________________________________________________________Submitter: William FitzGerald, District of Columbia Fire & EMS DepartmentComment on Proposal No: 1981-�Recommendation: Add new text to read: Air cylinders must be forwards and backwards within manufacturer’s product lines. All �007 air cylinders must be approved for use on earlier versions of a manufacturer’s SCBA, and �007 SCBA must be approved when using air cylinders manufactured for earlier versions.Substantiation: Reengineering air cylinder valves and retention systems will make SCBA in use non interchangeable with newer versions. Modifying this requirement will reduce the impact on SCBA users with large inventories, and will support systems presently in place that ensure interoperability on a local and regional level.Committee Meeting Action: RejectCommittee Statement: The requirements for cylinder interchangeability have been deleted. See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-117 Log #��� FAE-RPE Final Action: Accept in Principle(6.5)____________________________________________________________Submitter: Todd Birkel, Ashippun VFDComment on Proposal No: 1981-�Recommendation: Remove the requirement of standardized interchangeable bottles.Substantiation: The concept of interchangeability is noble but not driven by the fire service. If it was major incident reviews would be exclaiming the need for a change. After 9/11/01 the biggest concern was over communications. This change will take decades, not just several years, and will be quite costly. My department is updating and purchasing new SCBA this year with an anticipated service life of 10-15 years. This new requirement will cause noncompliance within a couple of years. The issue would be better handled by having OSHA and NIOSH certify existing systems, with existing bottles interchanged. The existing bottles all use the same fittings now, why change what is not broken. I think the financial impact as well as a more realistic time frame needs to be considered before proceeding with the proposed changes.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

1981-46

Report on Comments F2006 — Copyright, NFPA NFPA 1981____________________________________________________________1981-118 Log #��5 FAE-RPE Final Action: Accept in Principle(6.5)____________________________________________________________Submitter: James Roudebush, Dover FireFighters IAFF local ��4Comment on Proposal No: 1981-�Recommendation: Currently I recommend that the proposed change to Section 6.5 Interchangeable Breathing Air Cylinder and Valve assembly Design Requirements be deleted. Before implementing such a change I feel that there must be more research done to determine if a need does exist for a standard such as Section 6.5.Substantiation: The idea of having an air cylinder that is interchangeable may be desirable but the logistic of implementing such a change will be devastating to many fire departments. the department I serve with makes a prime example of such a case. Our department is a small career department with only fifteen firefighters. Recently our department upgraded all of its Scabs from low pressure to high pressure. This change has left us with half of our inventory of air cylinders needing replacement with 4500 psi cylinders. due to budgetary issues our department can only replace a maximum of 6 cylinders a year At this rate, it will be a minimum of three to four years before all of our air cylinders are replaced. Complicating this process is the possibility that after �007 air cylinders will no longer be compatible with the air packs currently in use by our department. What are departments to do when they are unable to replace aging cylinders/ Regarding rapid intervention teams and the use of Scabs, our department has made the decision to have a full air pack with face piece ready to take in for rescue of a downed firefighter during the rescue operations of a downed firefighter should be that only possible time, that personnel would change their air source in a contaminated atmosphere.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-119 Log #89 FAE-RPE Final Action: Accept in Principle(6.5, 7.15, 8.23 through 8.25)____________________________________________________________Submitter: Richard S. Tobin, Jr., Fire Department City of New YorkComment on Proposal No: 1981-�Recommendation: Eliminate all references to the requirement for an interchangeable SCBA breathing air cylinder as well as associated references and testing requirements.Substantiation: The changes recommended by this standard could decrease rather than enhance firefighter safety. Innovation has greatly enhanced firefighter safety. The requirement for interchangeable cylinders could have a negative effect on future product innovation at a cost to the firefighters safety. There has not been any evidence presented to document the need for interchangeability. Not all fire departments use the same pressure, therefore interchangeability will only be achieved via a single universal pressure. Forward/backward compatibility will not be assured placing departments in the position of lacking compatibility among their existing inventories. No evidence has been presented that indicates how such a requirement will enhance firefighter safety.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-1�0 Log #10 FAE-RPE Final Action: Accept in Principle(6.5, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: Gregory Payson, Brunswick Fire DepartmentComment on Proposal No: 1981-�Recommendation: I am writing in regards to the proposed change to NFPA 1981. I do not believe that making this change would benefit neither this community nor any in our mutual aid response area.Substantiation: Here are some of my reasons for not supporting your proposed change. We the Brunswick Fire Department have currently received a fire act grant to replace our aging air packs. The grant given was approximately $1�0,000 to make the new purchase. We did a lot of research on air packs to make sure that we had the best product for our department that was currently on the market. I can foresee budgets taking a huge hit trying to bring our air bottles up to this compliance. How does the NFPA propose to help the small towns and cities out there afford this new compliance issue? We live in a time where budgets are being cut further and further every year. Just for our department alone it will cost us approximately 4�,000 dollars to bring everything up to this compliance with the bottles alone. This is not taking into consideration of what may be needed for our twenty-nine packs that are in-service. Our town government will be extremely upset to think that we just spent moneys for new purchases of these air packs. When in two years time of the original purchase the air packs are out of date and in need of a substantial amount of money to bring them up to your specifications. This is poor at best. The money that the American people have spent on the Fire Act Grant program should not be wasted as your proposal suggests. Our community

(as well as most in our state) can’t afford that kind of hit to the budget in one year. Since this is the case I bring to you the possibility of our own interchangeability issues in the same department. With the mention of the Fire Act Grant, will departments be penalized in the future for not being compliant to NFPA 1981 because they could not afford the hit to their budget? How can you force a manufacturer to share their research and devolvement with another company that doesn’t have as good a reputation on the market? You take SCOTT for example; they currently have a patented bottle innovation that fire departments have chosen because of the ease of changing these bottles. When purchasing these items, these departments are well aware of the lack of interchangeability of their pack with their mutual aid departments. They believe the benefit to this advancement is worth the sacrifice of interchangeability within their mutual aid response. You have proposed this upgrade to NFPA 1981 without any thought of what this may mean to the companies we trust with our lives. I believe you will bring upgrades to our equipment to a staggering halt. Companies may go out of business because of money spent on research for higher standards. I believe interchangeability is a huge concern, however I believe some research needs to be done prior to placing such a new standard into place. The answer should not lie with the many manufacturers to come up with an idea to make this so. This would be an issue in itself. Who is to say what the best system on the market is. Interchangeability issues will always be out there. Thermal Imagining batteries aren’t interchangeable from manufacturer to manufacturer. Our air masks aren’t interchangeable from manufacturer to manufacturer. I could go on and on about interchangeability problems throughout our equipment. Please don’t put this huge budget item in front of the fire service. Most of our communities can’t afford this change. We choose our equipment based on the design and the needs of the community. Don’t force us into something we have no choice over nor can we afford.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-1�1 Log #1� FAE-RPE Final Action: Accept in Principle(6.5, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: Glenn Grove, Adams and Jefferson County Hazardous Response AuthorityComment on Proposal No: 1981-�Recommendation: Delete all references to mandatory compliance with, or requirements for, interchangeable SCBA air bottles between manufacturers or mutual aid agencies.Substantiation: This is a problem that must be addressed over the long term and should be a consideration in all future SCBA standards. If implemented at this time, this standard would become a logistical and financial hardship for agencies such as mine. We are in the middle of a transition period of trying to retrofit current SCBAs to meet the CBRNE standards. This standard is seen as mandatory for all future Department of Homeland Security (DHS) grant funding and is leaving many smaller agencies with both compliant and non-compliant equipment in the same inventories. This NFPA standard, which becomes an “industry standard” does not directly require nonfire based disciplines such as law enforcement SWAT Teams and Bomb Squads to comply but does add a level of complexity when attempting to build interagency equipment interoperability. As an “industry standard”, it is expected that all users of SCBA would comply, not just those that are fire based. This is already occurring with the CBRNE, PASS and “Heads-Up display” standards which are not needed and even detrimental to some disciplines. Attempting to comply with the most current standards has precluded passing down of older, albeit serviceable equipment to smaller rural areas that are not good candidates for DHS money. If accepted, this standard would then apply for all non-interchangeable bottles as well requiring the purchase of new, compliant equipment by all agencies whether grant funded or not. As the Coordinator of a multi-agency, multi-county response authority, I strive for interagency equipment interoperability. We are surrounded by agencies that all have their own preferences for equipment; mostly Scott, some Survivair and some MSA, but all have high pressure refill capability and this is how we address this problem. I would urge you to encourage both the end user and the manufacturers to work toward this goal of interchangeable bottles, but unless NIOSH and OSHA are on board it is premature to require it.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

1981-47

Report on Comments F2006 — Copyright, NFPA NFPA 1981____________________________________________________________1981-1�� Log #16 FAE-RPE Final Action: Accept in Principle(6.5, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: Peter Grivins, Hamlin Township FireComment on Proposal No: 1981-�Recommendation: I feel that there is no real reason for the cylinder interchangeability standard. This is a solution to a question that no one asked.Substantiation: The expense alone for small fire departments would be too much to bear. In the last five years, we have been unable to secure funding from the federal government, forcing us to keep older equipment. We do not have the run volume or tax base to buy cylinders that would comply with this standard. Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-1�� Log #17 FAE-RPE Final Action: Accept in Principle(6.5, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: Rob Soderlund, Sparta Fire DepartmentComment on Proposal No: 1981-�Recommendation: Recommendation to cease and abandon the cylinder interchangeability proposal to the �007 edition of NFPA 1981 due to a lack of need, lack of local resources (i.e. funding), impracticality, and the overall waste it will generate in man hours for changing and adopting the code, unnecessary research, funding that is much needed elsewhere in the emergency services, and the disposal of hundreds of thousands of cylinders currently in service or at manufacturer’s facilities. Substantiation: Along with my own experiences in the fire service, including being dispatched to the New Orleans area in the aftermath of Hurricane Katrina, and speaking with an FDNY Battalion Chief after the 9/11 tragedy, never has the outcome of an emergency scene been dictated, affected, or decided by a lack of SCBA cylinder interchangeability. Mutual aid companies provide their own equipment and resources, including their own SCBA packs and cylinders. Air compressors on fire apparatus and on trailers have taken care of filling cylinders at large incidents. The resources being used to push for the interchangeability should be redirected to areas that need it more, such as communications interoperability, funding for apparatus to get first responders where they need to go, training, and research to continually improve what we have now, including excellent SCBA packs and cylinders, turn out gear and other protective ensembles, and the needed equipment to assist the first responders in handling any and all possible emergencies that can and will come our way. This all seems wasteful to me. We are trying to fix a problem that does not exist. Let the local first responders dictate what is needed. An easy way to do this is to look at what is being asked for through the Fire Act Grant Program, and send additional funding to that program.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-1�4 Log #�0 FAE-RPE Final Action: Accept in Principle(6.5, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: Fred Gandolfo, Coastal Fire Systems, Inc.Comment on Proposal No: 1981-�Recommendation: Delete entire sections.Substantiation: The proposed change nets no positive benefit to the fire fighting industry in safety or functionality. History has shown that SCBA interoperability has never hindered mutual aid responses. Therefore, the cost associated with this proposal is obscene and unwarranted. The proposal hinders industry from developing new and improved systems as there is no competitive advantage to do so. SCBA’s will become cheap commodities based on meeting a restrictive specification as determined by NFPA. This country and the fire industry has strived on the innovation of American Enterprise. NFPA’s proposal will take the American advantage away from SCBA design and innovation.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-1�5 Log #�4 FAE-RPE Final Action: Accept in Principle(6.5, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: Kevin Flynn, Forked River Fire DepartmentComment on Proposal No: 1981-�Recommendation: Delete entire sections.Substantiation: It is too costly and absolutely unnecessary.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-1�6 Log #57 FAE-RPE Final Action: Accept in Principle(6.5, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: David T. Bernzweig, Columbus, OHComment on Proposal No: 1981-�Recommendation: Eliminate the requirement for an interchangeable SCBA Breathing Air Cylinder and all associated references and testing requirements.Substantiation: The change recommended by this standard is not a fir service driven need. Furthermore, the potential costs (financial and operationally) far outweigh any potential benefit that may be gained by the adoption of the proposed interchangeability provision of NFPA 1981. A universal interchangeable SCBA breathing air cylinder will result in the following negative consequences: ● Forward compatibility of pre-2007 cylinders with 2007 SCBA systems may not be possible in all cases, and certainly not possible without a potentially costly upgrade of existing cylinders to the �007 standard. ● Backward compatibility of 2007 compliant cylinders with pre-2007 SCBA systems may not be possible in all cases, and certainly not possible without a potentially costly upgrade of existing pre-�007 SCBA systems. ● Cylinder interchangeability is not actually achieved by the proposed new standard because “like” volume and pressures are still required for interchangeability to occur. ● There is no proof showing that a true fire service need for SCBA cylinder interchangeability actually exists. Any cases of inadequate air supplies at an emergency scene could be more easily remedied by addressing the refilling capabilities of the departments in question. Furthermore, addressing refilling capability results in a solution for all cylinder volumes and pressures, not just those that meet the NFPA standard. ● The costs associated with this proposal are not justified by the hypothetical need. Any future costs savings that may occur are purely hypothetical and cannot be shown to offset potential costs. ● Future product innovation will be greatly hampered if this proposal is adopted.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-1�7 Log #77 FAE-RPE Final Action: Accept in Principle(6.5, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: Sam Smith, Wayne Township Volunteer Fire DepartmentSteven Farus, Wayne Twp. Vol. Fire Department (Log #��0)Roy Williams, Wayne Twp. Vol. Fire Department (Log #��1)Steve Tye, Wayne Township (Log #���)Kevin DeMent, Duncan Falls Fire Department (Log #���)Walter Woodruff, Duncan Falls Volunteer, Fire Department (Log #��4)Donald Alexander, Wayne Twp. Vol. Fire Department (Log #��5)Dave Wortman, Adamsville Comm. Fire Department (Log #��6)Harold Ridgley, Adamsville Community Fire Department (Log #��7)Timoth Titon, Adamsville Community Fire Department (Log #��8)Raymond Wortman, Adamsville Fire Department (Log #��9)Jim Lashbrook, Adamsville Fire Department (Log #�40)IComment on Proposal No: 1981-�Recommendation: Delete Sections 6.5 SCBA Interchangeable Breathing Air Cylinder and Valve Assembly Design Requirements; 7.16 Interchangeable Breathing Air Cylinder Performance Requirements; 8.�� Interchangeable Cylinder Valve Flow Rate Test; 8.�4 Breathing Air Cylinder and Valve Assembly Retention Test; and 8.�5 Cylinder Connections Accessibility Test.Substantiation: New technology will suffer because manufacturers will be reluctant to design anything new in SCBA units as other manufacturers benefit from the technology. Current technology allows everybody to use a standard CGA thread and bottles can be refilled quickly, enough spare cylinders are in existence to keep an adequate air supply on the fire ground.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-1�8 Log #78 FAE-RPE Final Action: Accept in Principle(6.5, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: Charles Ryan, Fairfax County Professional Fire & Rescue Officers AssociationComment on Proposal No: 1981-�Recommendation: Delete entire sections.Substantiation: As President of the Association representing the professional officers of the Fairfax County, Virginia Fire & Rescue Department, I am writing to express our opposition to the proposed revision to NFPA 1981 to require interoperability of SCBA cylinders.

1981-48

Report on Comments F2006 — Copyright, NFPA NFPA 1981It has been the experience of the members of this association that there will be no recognizable benefit to mandating on a “global” scale the interoperability of SCBA cylinders. Our members operate at multi-jurisdictional events on a daily basis, and we have never encountered a problem with respect to IDLH operations viz-a-viz SCBA cylinder interoperability with our mutual and automatic aid partners. To impose a national interoperability standard, without allowing sufficient time for research, testing, and phased-in purchasing plans is a poor decision which will place undue hardship on the fire service at the local level. We thus object to the proposed revision in its entirety.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-1�9 Log #81 FAE-RPE Final Action: Accept in Principle(6.5, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: Lori Rammel, City of Trotwood Fire & RescueComment on Proposal No: 1981-�Recommendation: Eliminate the requirement for an interchangeable SCBA breathing air cylinder and all associated references and testing requirements.Substantiation: The change recommended by this standard is not a fire service driven need. Furthermore, the potential costs (financial and operationally) far outweigh any potential benefit that may be gained by the adoption of the proposed interchangeability provision of NFPA 1981. A universal interchangeable SCBA breathing air cylinder will result in the following negative consequences: ● Forward compatibility of pre-2007 cylinders with 2007 SCBA systems may not be possible in all cases, and certainly not possible without a potentially costly upgrade of existing cylinder to the �007 standard. ● Backward compatibility of 2007 compliant cylinders with pre-2007 SCBA systems may not be possible in all cases, and certainly not possible without a potentially costly upgrade of existing pre-�007 SCBA systems. ● Cylinder interchangeability is not actually achieved by the proposed new standard because “like” volume and pressures are still required for interchangeability to occur. ● This is no proof showing that a true fire service need for SCBA cylinder interchangeability actually exists. Any cases of inadequate air supplies at an emergency scene could be more easily remedied by addressing the refilling capabilities of the departments in question. Furthermore, addressing refilling capability results in a solution for all cylinder volumes and pressures, not just those that meet NFPA standards. ● The costs associated with this proposal are not justified by the hypothetical need. Any future costs savings that may occur are purely hypothetical and cannot be shown to offset potential costs. ● Future product innovation will be greatly hampered if this proposal is adopted.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-1�0 Log #8� FAE-RPE Final Action: Accept in Principle(6.5, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: Lawrence Petrick, Ohio Association of Professional FirefightersComment on Proposal No: 1981-�Recommendation: Eliminate the requirement for an interchangeable SCBA breathing air cylinder and all associated references and testing requirements.Substantiation: The change recommended by this standard is not a fire service driven need. It is creating equipment that is not based on risk management and actual experience of the fire service. The potential financial costs far outweigh any benefit gained by the adoption of the proposed interchangeability provision of NFPA 1981. It will cause operational issues and confusion at emergency scenes for years to come because it will take years to convert or purchase all SCBA and cylinders to the proposed standard. A universal interchangeable SCBA breathing air cylinder will result in the following negative consequences: 1) The current inventory is largely incompatible with the interoperability mandate. Forward and backward compatibility of pre-�007 cylinders with �007 SCBA systems may not be possible in all cases, and certainly not possible without a costly upgrade. �) Volume and pressure are still required for interchangeability to occur, therefore actual cylinder interchangeability still won’t be accomplished. �) The SCBA was designed for actual everyday fire service needs - firefighting. Changing it to meet the challenge of a rarely occurring event is not proper risk assessment of the fire service. It is a disservice. 4) Inadequate air supplies at an emergency scene could be more readily addressed by focusing on the refilling capabilities of a department. In addition, refilling capability results in solutions for all types of cylinders.

5) The potential costs associated with this proposal far outweigh the supposed value need behind the reasons for this proposal. 6) This proposal will force a generic one-type fits all SCBA, thus hampering, if not eliminating, any future SCBA innovations and market competition.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-1�1 Log #86 FAE-RPE Final Action: Accept in Principle(6.5, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: Chris Powers, Whitchurch-Stouffville Fire and Emergency ServicesComment on Proposal No: 1981-�Recommendation: Delete entire sections.Substantiation: The need for this change is not supported by substantial justification of problems in the field. The changes made to this standard in �00� have not been fully implemented and introducing the proposed changes would effectively obsolete many SCBA that are currently compliant as they could not be upgraded to the new standard. The possibility of poor air quality in air bottles from other departments’ compressor systems is not addressed and could be a safety hazard.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-1�� Log #91 FAE-RPE Final Action: Accept in Principle(6.5, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: Tomas Kane, Westfiled Fire DepartmentComment on Proposal No: 1981-�Recommendation: We are against the proposed change of standardizing bottles on all SCBA’s.Substantiation: We have never had a problem running out of bottles. We have many spares. The cost would be prohibitive and if forced may place the department’s budget at risk.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-1�� Log #95 FAE-RPE Final Action: Accept in Principle(6.5, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: Barry Malmsten, Ontario Association of Fire ChiefsComment on Proposal No: 1981-�Recommendation: Delete entire sections.Substantiation: Revision to NFPA 1981 in �00� included significant changes to SCBA including the provision of RIC connections to facilitate air transfer between users or spare cylinders, as well as Heads Up Display (HUD). These new features added substantial cost to each new SCBA being purchased as well as the need for batteries to operate the electronics in the SCBA. The changes from the �00� edition are still having significant impact across the Province of Ontario. Many departments have begun changing SCBA to meet the �00� standard and have a mix of SCBA. If the proposed �007 standard were adopted some fire departments may end up with three or more styles of SCBA. This presents major challenges for training and safety of firefighters who may have to use any of these styles. The introduction of new SCBA that have cylinders that are not interchangeable with the current inventory creates problems to ensure provision of adequate number of cylinders to supply both current and new style SCBA and therefore is counterproductive to the stated purpose of improving fire ground interoperability. It also appears that the cylinders will only be cross-applicable within any given pressure band - 4500 PSI cylinders can still only be used in 4500 PSI packs. Given the equipment differences that exist in both automatic and mutual aid situations between departments, SCBA equipment pressure differences will negate any interoperability benefit. Given that this upgrade or retrofit would require changes to both the SCBA and the Cylinder, this is not even as simple as the requirements to upgrade current SCBA to add RIC/UAC and HUD. The costs of this upgrade would be extreme. An additional concern is the possibility of poor quality breathing air being provided and interchanged. Breathing air quality problems were identified in Ontario in recent years and there is still concern that some departments are operating air compressors that do not provide compressed breathing air that meets the CSA Z94.4 Standard. Interchange of cylinders before assurance that the air meets the required standards could result in SCBA that is contaminated and presents a danger to firefighters.

1981-49

Report on Comments F2006 — Copyright, NFPA NFPA 1981 It is the opinion of the OAFC that what is required is a period of stability within this standard so that departments can both logistically and financially manage the retrofit process to the �00� edition. While there is technically no mandate to retrofit existing equipment, a number of progressive departments, diligently strive to maintain equipment so that it is consistent with the newest trends in efficiency, operation and certainly health and safety. Introducing yet another major functional revision to SCBA will simply be financially prohibitive.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-1�4 Log #101 FAE-RPE Final Action: Accept in Principle(6.5, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: Rodney Clary, Clearcreek Fire DistrictComment on Proposal No: 1981-�Recommendation: Eliminate the requirement for an interchangeable SCBA breathing air cylinder and all associated references and testing requirements.Substantiation: The change recommended by this standard is not a fire service driven need. Furthermore, the potential costs (financial and operationally) far outweigh any potential benefit that may be gained by the adoption of the proposed interchangeability provision of NFPA 1981. A universal interchangeable SCBA breathing air cylinder will result in the following negative consequences., ● Forward compatibility of pre-2007 cylinders with 2007 SCBA systems nay not be possible in all cases, and certainly not possible without a potentially costly upgrade of existing cylinders to the �007 standard. ● Backward compatibility of pre-2007 SCBA systems may not be possible in all cases, and certainly not possible without a potentially costly upgrade of existing pre-�007 SCBA systems. ● Cylinder Interchangeability is not actually achieved by the proposes new standard because “like” volume and pressures are still required for interchangeability to occur. ● There is no proof showing that a true fire service need for SCBA cylinder interchangeability actually exits. Any cases of inadequate air supplies at an emergency scene could be more easily remedied by addressing the refilling capabilities of the departments in question. Furthermore, addressing refilling capability results in a solution for all cylinder volumes and pressures, not just those that meet the NFPA standard. ● The costs associated with this proposal are not justified by the hypothetical need. Any future costs savings that may occur are purely hypothetical and cannot be shown to offset potential costs. ● Future product innovation will be greatly hampered if this proposal is adopted.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-1�5 Log #105 FAE-RPE Final Action: Accept in Principle(6.5, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: Michael T. Rupert, MSAComment on Proposal No: 1981-�Recommendation: Delete the following text:

6.5 SCBA Interchangeable Breathing Air Cylinder and Valve Assembly Design Requirements.

6.5.1 SCBA manufacturers’ breathing air cylinders and valve assemblies shall be inspected and evaluated for interchangeable dimension conformance and volume as specified in Figure 6.5.1 for the dimensional parameters and volume requirements.

6.5.� The SCBA backframe and cylinder retention device shall be designed to accommodate and securely retain an infinite range of cylinders within the dimensions specified in 6.5.1.

6.5.� The SCBA backframe, cylinder retention device, and harness shall not require use of special adapters, tools, or other appliances that are not a permanently affixed part of the NIOSH certified SCBA. Other adjustments or alternations to the SCBA backframe, cylinder retention device, and harness shall be permitted provided the modification is compatible with the surrogate cylinder and valve assemblies.

6.5.4 The removal of any component of the SCBA to achieve cylinder interchangeability shall not be permitted.

6.5.5 The pressure gauge provided as part of the SCBA manufacture’s breathing air cylinder and valve assembly shall be readable by a person other than the wearer of the SCBA when the SCBA is properly worn in accordance with the SCBA manufacturer’s instructions and with the breathing air cylinder securely retained in the SCBA backframe.

Figure 6.5.17.16 Interchangeable Breathing Air Cylinder Performance

Requirements.

7.16.1 The SCBA manufacturer’s cylinder valve assembly shall be tested for flow rate as specified in Section 8.��, Interchangeable Cylinder Valve Assembly Flow Rate Test, and shall have each valve deliver not less than 400 LPM.

7.16.� The SCBA backframe and cylinder retention device shall tested for cylinder and valve assembly retention security as specified in Section 8.�4, Breathing Air Cylinder and Valve Assembly Retention, and the cylinder and valve assembly shall not change position by more than �5 mm (1 in.).

7.16.� The SCBA CGA cylinder valve handwheel connection shall be tested for attachment and detachment as specified in Section 8.�5, Cylinder Connections and Accessibility Test, and the CGA handwheel shall fully connect in a maximum of �0 seconds, and shall fully disconnect in a maximum of �0 seconds.

7.16.� The SCBA CGA cylinder valve handwheel connection shall be tested for clearance as specified in Section 8.�5, Cylinder Connections and Accessibility Test, and the CGA handwheel shall have a clearance between the outer diameter of the handwheel of not less than �5 mm (1 in.) from any other surface of the SCBA.

8.�� Interchangeable Cylinder Valve Flow Rate Test.8.��.1 Application. This test method shall apply to the manufacturer’s

interchangeable cylinder valve assembly.8.��.� Samples. One sample of each valve assembly shall be provided.8.��.� Specimen Preparation.8.��.�.1 Specimens for conditioning shall be complete valve assemblies.8.��.�.� Prior to testing, specimens shall be conditioned for a minimum

of 4 hours at an ambient temperature of ��°C, ±�°C(7�°F, ±5°F), with a relative humidity (RH) of 50 percent, ±�5 percent.

8.��.4 Procedure. Each valve shall deliver no less than 400 L/min with a continuous input pressure of 100 psi.

8.��.5 Report. The flow rate of each specimen shall be recorded and reported.

8.��.6 Interpretation. One or more specimens failing this test shall constitute failing performance.

8.�4 Breathing Air Cylinder and Valve Assembly Retention Test.8.�4.1 Application. This test method shall apply to complete SCBA

assemblies.8.�4.� Samples.8.�4.�.1 Samples shall be complete SCBA.8.�4.�.� Samples shall be fitted with surrogate cylinder and valve

assembles.8.�4.� Specimen Preparation.8.�4 �.1 One SCBA sample shall be tested with each surrogate cylinder

and valve assembly as specified in 8.�4.x.8.�4.�.� Prior to testing, specimens shall be conditioned for a minimum

of 4 hours at an ambient temperature of ��°C, ±�°C(7�°F, ±5°F), with a relative humidity (RH) of 50 percent, ±�5 percent.

8.�4.4 Apparatus.Table 8.�4.4.�8.�4.4.1 A test bench or similar fixture that can firmly fix a fully

assembled SCBA to the test bench or fixture that will not allow movement of the SCBA.

8.�4.4.� Surrogate cylinders shall meet the specifications of Table 8.�4.4.�.

8.�4.4.� Measurements will be taken with a calibrated measuring device having a resolution of better than +/0.�5 mm (+/0.010 in.).

8.�4.4.4 Loops, straps, or pads shall be positioned on the valve to facilitate the application and measurement of an applied load to the intersection of the CGA plane with the center line of the breathing air cylinder body.

8.�4.5 Procedure.8.�4.5.1 The specimen, fitted with the surrogate cylinder and valve

assembly, shall be fixed to the backplate and harness assembly in accordance with the manufacturer’s instruction in the user instructions provided with the SCBA for the end users.

8.�4.5.� The fully assembled SCBA shall be firmly fixed to the test bench or fixture in a manner that prevents movement of the SCBA but shall not interfere with the interoperable breathing air cylinder and valve assembly retention method.

8.�4.5.� The distances for each of the six directions specified in 8.�4.5.4, the original starting positions, shall be measured and recorded.

8.�4.5.4 A force of �00 N (45 lbf) shall be applied to the intersection point specified in 8�4.4.�, in the six directions shown in Figure 8.�4.5.4. The force shall be applied for a period of 10 seconds, ±5/0 seconds allowing the measurements to be taken.

Figure 8.�4.5.4 (Caption and art to come)8.�4.5.5 Following the application of force for each direction, the

distances for each of the six directions shall be measured and recorded.8.�4.6 Report.8.�4.6.1 The distance moved from the original starting position for each

of the six directions shall be recorded and reported.8.�4.6.� No portion of the surrogate cylinder and valve assembly shall

show movement greater than �5 mm (in.) from its original position prior to load application.

1981-50

Report on Comments F2006 — Copyright, NFPA NFPA 19818.�4.7 Interpretation. Movement of any part of the cylinder and valve

assembly that exceeds �5 mm (1 in.) shall constitute failing performance.8.�5 Cylinder Connections Accessibility Test.8.�5.1 Application. This test method shall apply to complete SCBA

assemblies.8.�5.� Samples.8.�5.�.1 Samples shall be complete SCBA.8.�5.�.� Samples shall be fitted with surrogate cylinder and valve

assemblies.8.�5.� Specimen Preparation.8.�5.�.1 The interoperable cylinder and valve assembly shall be fixed to

the backplate harness assembly following the manufacturer’s instruction indicated in the User Instructions.

8.�5.�.� Prior to testing, specimens shall be conditioned for a minimum of 4 hours at an ambient temperature of ��°C, ±�°C (7�°F, 5°F), with a relative humidity (RH) of 50 percent, ±�5 percent.

8.�5.4 Procedure.8.�5.4.1 Surrogate cylinders shall meet the specifications of Table

8.�4.4.�.8.�5.4.� The specimen, fitted with the surrogate cylinder and valve

assembly, shall be fixed to the backplate and harness assembly in accordance with the manufacturer’s instruction in the user instructions provided with the SCBA for the end user.

8.�5.4.� Specimens shall be evaluated for accessibility by an individual with a hand that would be categorized as large while wearing a size large NFPA 1971 compliant glove.

8.�5.4.1 Surrogate cylinders shall meet the specifications of Table 8.�4.4.�.

8.�5.4.� The specimen, fitted with the surrogate cylinder and valve assembly, shall be fixed to the backplate and harness assembly in accordance with the manufacturer’s instruction in the user instructions provided with the SCBA for the end user.

8.�5.4.� Specimens shall be evaluated for accessibility by an individual with a hand that would be categorized as large while wearing a size large NFPA 1971 compliant glove.

8.�5.4.4 The test subject shall be able to fully connect the CGA handwheel in less than �0 seconds. Removal shall be accomplished within �0 seconds.

8.�5.4.5 The test subject shall be able to full attach the RIC / UAC connection in less than 15 seconds. Removal shall be accomplished within 15 seconds.

8.�5.4.6 The clearance between the handwheel and the SCBA shall be measured, recorded, and reported.

8.�5.5 Report.8.�5.5.1 The time to attach the specimens shall be recorded and

reported.8.�5.5.� The clearance distance for the valve handwheel shall be

recorded and reported.8.�5.6 Interpretation. One or more specimens failing this test shall

Substantiation: Removal of all sections associated with the interoperable cylinder. As the interoperable cylinder concept has been discussed through the public comment process, the majority of feedback from MSA users has been against the incorporation of an interoperable cylinder in the standard.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-1�6 Log #110 FAE-RPE Final Action: Reject(6.5, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: John O’Shea, Springfield Fire DepartmentComment on Proposal No: 1981-�Recommendation: None given.Substantiation: Problem: Backward compatibility. In �004, the SFD purchased replacement Scoot Airpaks for the entire department. Our concern is that, under the proposal, if we purchase replacement air bottles in �007 or later, they will be incompatible with our current equipment. This would present a severe logistical problem or great expense to our department.Committee Meeting Action: RejectCommittee Statement: The submitter did not provide any recommendation for the committee to consider. See also Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-1�7 Log #187 FAE-RPE Final Action: Accept in Principle(6.5, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: Russell Thomas, Jr., Charleston Fire DepartmentComment on Proposal No: 1981-�Recommendation: Delete entire sections.Substantiation: We agree with the major consensus of the fire service that the events of 911 and other recent events have demonstrated that the financial cost far outweighs the benefit of the standard.

Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-1�8 Log #188 FAE-RPE Final Action: Accept in Principle(6.5, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: John J. Caussin, Fairfax County Fire & Rescue DepartmentComment on Proposal No: 1981-�Recommendation: Delete entire sections.Substantiation: The proposed revision has a tremendous financial impact on the fire service without any direct benefit to firefighters operating within the IDLH. there has not been sufficient study or analysis to justify this revision. The fire service has addressed capacity for extended operations through the use of apparatus equipment spare cylinders, cascade systems and/or breathing air compressors. Extensive experience with multi-jurisdictional response to the Pentagon on 9-11 and in the Gulf Region post hurricane Katrina has not revealed the need for interoperability of cylinders.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-1�9 Log #198 FAE-RPE Final Action: Accept in Principle(6.5, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: Richard Kranich, Phillipsburg Fire DepartmentComment on Proposal No: 1981-�Recommendation: Delete entire sections.Substantiation: In my view, the proposed change: 1) Is costly and absolutely unnecessary �) As an active firefighter for (�6) years in my own experience I am unaware of any instance where cylinders of any type could not be filled, even on mutual aid calls. �) If the Federal Government really wanted to do something from which we would all benefit, and save lives, they would address communications, not air pak cylinders, After all communications was the real problem on September 11, �001.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-140 Log #199 FAE-RPE Final Action: Accept in Principle(6.5, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: Kevin Guimond, South Portland Fire DepartmentComment on Proposal No: 1981-�Recommendation: Delete all proposed new text.Substantiation: Cylinder interchangeability has not been a major issue. Most departments have solved the issue on the fill side of the equation. Many departments have purchased mobile fill stations to fill cylinders while working an event on a regional basis. It is already a requirement to have spare cylinders on your trucks. With the mobile fill stations now available, running out of bottles should not be an issue worthy of a large investment. My department works with industry and three vendors for air packs and cylinders. The purchase of adapters to allow you to fill any bottle makes far more economic sense. We have not asked for this change and it is a total waste of taxpayers money.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-141 Log #�00 FAE-RPE Final Action: Accept in Principle(6.5, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: Andrew Rammel, Huber Heights Fire DivisionComment on Proposal No: 1981-�Recommendation: Delete these sections of the proposed change.Substantiation: Most SCBA cylinders are already interchangeable. The only reason this has not been allowed is because of the NIOSH approval process of the SCBA. The issue of interchangeability is not a issue that is going to save lives or make a huge difference on the fireground. Making a standard operating pressure would make a bigger difference than what is currently proposed. Changing the standard will have little effect immediately. Many Fire Departments across the country have received Fire Act Grants to upgrade their SCBA. It will take at least two more revision cycles for the standard for many departments to consider replacing their SCBA because of age. This proposed change could affect many departments that can only afford to upgrade a portion of their units. This means all their units will not be interchangeable and could have ill effects on these departments.

1981-51

Report on Comments F2006 — Copyright, NFPA NFPA 1981 The proposed change to the standard will not benefit the fire service as a whole. We have interoperability issues with communications that is more of a issue than interoperability of SCBA.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-14� Log #�01 FAE-RPE Final Action: Accept in Principle(6.5, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: Bob Platts, Mason City Fire DepartmentComment on Proposal No: 1981-�Recommendation: Delete entire sections.Substantiation: In my �� years in the fire service I cannot remember a time that we utilized a SCBA Bottle from another department. With the need to make sure that our members are safe we do not take the chance that other departments keep their hydro’s current and they properly test their compressors for both maintenance and sampling. If this standard is implemented you will be creating a standard to make us do something we will never do.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-14� Log #�08 FAE-RPE Final Action: Accept in Principle(6.5, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: David Trivette, Flowes Store Fire DepartmentComment on Proposal No: 1981-�Recommendation: Delete entire text found in sections 6.5, 7.16, 8.�� through 8.�5.Substantiation: In the proposed standard, the ability for a firefighter to easily change cylinders between different manufacturers of SCBA raises many safety concerns: 1. Most, if not all departments have specific SOP/SOG for the number of cylinders a firefighter can use before reporting to mandatory rehab. For example, department “A: may allow for two �0-minute cylinders before a mandatory rehab, while department “B” allows for two 45-minute cylinders. If both departments responded to an incident, what’s stopping a firefighter from using a cylinder from department “B” as a second cylinder? �. Without standardizing on a single pressure, what controls are in place if two neighboring departments use different pressure (i.e., ��16 and 4500) It would be easy to grab a 4500 pig cylinder and put it on an SCBA that is only capable of handling ��16. This would further lead to unsafe fire ground conditions. �. By allowing this, the time that is typically used to fill cylinders (giving the firefighter a brief rest period) is decreased. By decreasing this rest time and potentially allowing increased time in the SCBA (see #1); more stress is put on the firefighter. With increased stress levels on the body, the risks for a stress induced injury or fatality (i.e. cardiac or stroke) is increased. Every year, the USFA reports on the number of firefighter fatalities, and consistently the number one cause is stress related. Allowing cylinder interchangeability could potentially raise there numbers; which are already unacceptable. This Technical Committee should be writing standards that promote safer development of breathing apparatus that would reduce the stress on the firefighter; and this change has not proven that would be the case.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-144 Log #��� FAE-RPE Final Action: Accept in Principle(6.5, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: Gary Greenwell, City of Ocean City, NJComment on Proposal No: 1981-�Recommendation: Delete entire proposal for following: Cylinder interoperability - reference 6.5, 7.16, 8.�� through 8.�5.Substantiation: I am a career Fire Captain with the Ocean City New Jersey Department of Fire & Rescue Services. I have �� years on the job. I am a New Jersey Certified Instructor Level II. I feel that this proposal addresses no known need. My department works very closely with surrounding departments, both volunteer and career. These departments operate SCBA from various manufacturers including Scott, Draeger, MSA and Interspiro. I have never known of, or been made aware of any problems with cylinder interchangeability. In general, departments tend to keep their SCBA for their personnel. Cylinders have been refilled using cascade systems or mobile air compressor units, with no known problems. I feel that this proposal is unnecessary and will stifle research and innovation.

This proposal has no mention of funding, and therefore would place a very unreasonable cost burden on departments. Many departments are already fighting for what little funding they can get. they would then have to choose between items of higher importance, and premature replacement of items that would be deemed noncompliant by this proposal. An example of the hardship this would cause is as follows: A department has to replace a cylinder due to damage or end of service life. The cylinders this proposal calls for would not operate with the department’s existing SCBA. That department would then have to replace the cylinder, as well as purchase an entire new SCBA unit to be able to use the cylinder. As you can see, this would be unnecessary if the cylinder was of the same style as the existing SCBA. I feel that there are other problems of greater importance to interoperability, then SCBA cylinders. A bank of National Emergency Radio Frequencies or a trunked National Radio Frequency system would be of much more value. large scale incidents could then be handled by means of frequencies dedicated to a region, with a crossover to a national band if necessary. this could be programmed into existing, as well as new radios. Another issue, is establishment of a true National Standard Hose Coupling. After a certain date, all hose could be made to this specification and would have to be compliant, including major cities. Existing hose could be grandfathered. As new apparatus are ordered, new hose can be ordered to fit the plumbing of the apparatus. Coupling adapters can be obtained for a lot less cost than new SCBA.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-145 Log #��7 FAE-RPE Final Action: Accept in Principle(6.5, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: Brian J. Thibeault, Plymouth Fire RescueComment on Proposal No: 1981-�Recommendation: Delete all proposed language on cylinder operability changes and leave existing language in existing code.Substantiation: Cylinder interoperability language as drafted is not in the best interest of the Fire Service and Public Safety. While we wholeheartedly support and encourage al aspects of interoperability, we do not believe that the new standard, as drafted, will increase our capabilities substantially and may stifle research and development in the cylinder industry.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-146 Log #�� FAE-RPE Final Action: Reject(6.5, 7.16, 8.23 through 8.26)____________________________________________________________Submitter: Pete Schroeder, Netcong Fire DepartmentComment on Proposal No: 1981-�Recommendation: While the concept of this proposal change is good, a better way to implement this must be found. Eliminating the manufacture of all current style cylinders, at the end of �007, will cause many problems.Substantiation: A fixed date where current cylinders will no longer be available will make it financially impossible to covert all equipment by the end of �007. Additionally this would create an environment of less standardization. Most organizations will look to delay or spread this change out over a long period of time. So we may see many years of a mix of new and old SCBAs and cylinders. Lastly with a growing market of refurbished equipment, many departments may purchase used cylinders to further delay the cost of upgrade/replacement.Committee Meeting Action: RejectCommittee Statement: The submitter did not provide specific text for the committee to consider. Also, the submitter should see Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-147 Log #18 FAE-RPE Final Action: Accept in Principle(6.5 and 7.16)____________________________________________________________Submitter: Chris Nunnery, Lancaster, SCComment on Proposal No: 1981-�Recommendation: Delete any reference to interchangeability in Sections 6.5 and 7.16.Substantiation: The adoption of this code with the referenced changes can in no way be met by a vast majority of departments in our country. The mandated change to universal cylinders will place lives in danger by making the fireground a fiasco. Currently our department utilizes 46 Scott units. We would not be able to incorporate this new code into our organization for 15 or �0 years, thereby forcing our personnel to try to effectively operate with SCBA’s and cylinders that are not interchangeable with each other. This will have detrimental effects on the efficiency of departments everywhere.

1981-5�

Report on Comments F2006 — Copyright, NFPA NFPA 1981Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-148 Log #116 FAE-RPE Final Action: Accept(6.5 through 6.5.4)____________________________________________________________Submitter: David Williams, North Kansas City Fire DepartmentComment on Proposal No: 1981-�Recommendation: The Missouri Association of Fire Chiefs does not support the language that requires SCBA Interchangeable Breathing Air Cylinder and Valve Assembly Design. All of the wording in Section 6.5 to 6.5.4 should be deleted.Substantiation: The Missouri Association of Fire Chiefs does not support SCBA Interchangeable Breathing Air Cylinder and Valve Assembly Design. The combined experience of the Missouri Fire Chiefs membership does not believe that SCBA Interchangeable Breathing Air Cylinder and Valve Assembly Design has been adequately studied to be included in the �007 standard.Committee Meeting Action: AcceptCommittee Statement: Also see Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-149 Log #�� FAE-RPE Final Action: Accept in Principle(6.5.1)____________________________________________________________Submitter: Walter Schoonmaker, Hartsdale Fire Dist.Comment on Proposal No: 1981-�Recommendation: Delete “interchangeable”.Substantiation: There is no point that interchangeability of cylinders would increase firefighters safety, in fact it could stifle progress in safety features. I have over 46 years in the paid fire service and have never seen a need to change cylinders from one brand of SCBA to a different brand. This change makes no sense at all.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-150 Log #�15 FAE-RPE Final Action: Reject(6.5.1)____________________________________________________________Submitter: Les Boord, NIOSHComment on Proposal No: 1981-�Recommendation: New bullet Section 6.5? Each SCBA backframe shall be equipped with an operational female CGA connection to achieve cylinder interchangeability. Each breathing air cylinder and valve assembly certified as complaint with NFPA 1981, �007, edition shall be equipped with an operational male CGA connection to achieve cylinder interchangeability.Substantiation: A manufacturer with a proprietary cylinder and cylinder valve connection cold dimensionally accept an interchangeable cylinder and cylinder valve assembly onto the backframe without providing the operational female CGA connection under the currently proposed standard.Committee Meeting Action: RejectCommittee Statement: The requirements for cylinder interchangeability were deleted. See committee action on Comment 1981-16 (Log #111). These changes recommended by the submitter can not be used.

____________________________________________________________1981-151 Log #10� FAE-RPE Final Action: Reject(Figure 6.5.1)____________________________________________________________Submitter: Michael T. Rupert, MSAComment on Proposal No: 1981-�Recommendation: Revise the figure as shown on the following page.Substantiation: The figure provides accurate description of the lower profile of cylinders.Committee Meeting Action: RejectCommittee Statement: The requirements for cylinder interchangeability were deleted. See committee action on Comment 1981-16 (Log #111). These changes recommended by the submitter can not be used.

____________________________________________________________1981-15� Log #�10 FAE-RPE Final Action: Reject(Figure 6.5.1)____________________________________________________________Submitter: Les Boord, NIOSHComment on Proposal No: 1981-�Recommendation: 1. Dimension R (cylinder radius) needs to be added to the dimension block. �. Current Text The dimension block reads “CGA Valve Connection (Details 1 and �)” Revised text: Add a footnote to the title ‘“CGA Valve Connection (Details 1 and �)1 stating the following”1 American Standard Association, compressed Gas Cylinder Valve Outlet and Inlet Connections, B57.1-1965.” �. Current Text On detail 1 a leader note reads “Bleed holes required per standard”. Revised text: The leader note should read “Bleed holes required per CGA Valve Connections Standard1”. the footnote describe in item #� should be referenced. 4. Current Text Dimensions AA, BB, CC, and DD need to have additional information added to provide clarity. Revised text:

CGA Valve Connection (Detail 1 and 2)1

Dimensions CGA 346 CGA 347AA 0.505 in. ± .005 0.505 in. ± .005BB 70 deg ± .05 70 deg ± .05CC �� µ” RMS Surface

Finish�� µ” RMS Surface Finish

DD .8�5 – 14NGP-RH-EXT .8�5 – 14NGO-RH-EXT

5. Comment Identify the cylinder to and bottom with the appropriate txt or graphic. 6. Comment Define the gauge dimension on the front and bottom views similar to dimension D on the side view or redefine dimension D as a diameter with tolerances. 7. Comment Dimension C (Valve handle) needs to be defined as a diameter. 8. Comment The 1/� in. drive specified on the bottom view provides insufficient data required to define the dimensional parameters. The standard dimensions of a 1/� in. drive are defined in ‘Attachment A”.

Substantiation: Insufficient data in Figure 6.5.1 and additional comments to provide clarity to the figure.Committee Meeting Action: RejectCommittee Statement: The requirements for cylinder interchangeability were deleted. See Committee Comment 1981-76 (Log #CC1). These changes recommended by the submitter can not be used.

1981-5�

Report on Comments F2006 — Copyright, NFPA NFPA 1981

1981-151 (Log #102) Recommendation

FIGURE 6.5.1 SCBA Interchangeable breathing air cylinder dimensional and volume requirements.

1981-54

Report on Comments F2006 — Copyright, NFPA NFPA 1981____________________________________________________________1981-15� Log #� FAE-RPE Final Action: Reject(6.5.1 and 8.24.4.2)____________________________________________________________Submitter: David Hodson, Draeger Safety UK Ltd.Comment on Proposal No: 1981-1Recommendation: Add new Figure 6.5.1. 8.�4.4.� Surrogate valve and cylinder assemblies to meet the specification in Figure 6.5.1. Replace Table 8.�4.4.� with reference to Figure 6.5.1. No requirement for both figure and table. These figures are shown on the following pages.Substantiation: Insufficient data in the diagrams to control the valve dimension see marked in red. Dimension from CGA standard removed and standard referred to only.Committee Meeting Action: RejectCommittee Statement: Requirements for cylinder interchangeability have been deleted by Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-154 Log #�1 FAE-RPE Final Action: Accept(6.5.2)____________________________________________________________Submitter: Daniel Raftery, Greenville Fire DistrictComment on Proposal No: 1981-�Recommendation: Delete all of 6.5.�: 6.5.� The SCBA backframe and cylinder retention device shall be designed to accommodate and securely retain an infinite range of cylinders within the dimensions specified in 6.5.1. Substantiation: I have ��+ years in the fire service, 19+ as a career chief/NYC metro area extensive mutual aid experience including WTC on 9/11. This standard will negatively affect fire fighter safety by causing incompatibility within my department and also our mutual aid system - it may also cause firefighters to enter IDLH areas w/ equipment with which they are neither trained nor familiar. Solve this issue without stifling technological innovation.Committee Meeting Action: Accept

____________________________________________________________1981-155 Log #1�6 FAE-RPE Final Action: Reject(6.5.2)____________________________________________________________Submitter: John F. Heffren, Burgess Fire Equipment Co.Comment on Proposal No: 1981-�Recommendation: Add text to read as follows: A cylinder retention device is defined as a device that is attached to the SCBA backframe assembly and encompasses or supports the cylinder shell to secure the cylinder to the backframe. Cylinder valves shall provide retention function via the cylinder valve discharge threads only. Cylinder valve threads may be located at either 180 or 90 degrees from the cylinder valve handle.Substantiation: The primary reason for the inclusion in NFPA 1981, �007 edition of interchangeable cylinder valves is the utilization of clips on the cylinder that provide cylinder retention. A backframe that utilizes a clip for cylinder retention cannot accommodate a cylinder that has no clip. Cylinders with clips do not work on backframes that do not require clips. Some SCBA manufacturers’ valves are not 180 or 90 degrees from valve control. Using 90 or 180 degree locations only and clip elimination provides interchangeability without the excessive costs of the redesign proposed.Committee Meeting Action: RejectCommittee Statement: Requirements for cylinder interchangeability were deleted by Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-156 Log #�9 FAE-RPE Final Action: Accept in Principle(6.5.7, 7.16, 8.23 through 8.25)____________________________________________________________Submitter: Keith Badler, Robertsville Volunteer Fire Co. #1Comment on Proposal No: 1981-�Recommendation: Delete entire sections.Substantiation: Our department not being as large as some others still has �5 Scott �.� Airpacks ranging from age � years old up to 8 years. Each air pack has a minimum of � air bottles available at all times, plus additional on each apparatus. For approx 85 Total bottles thru out. If we had to retrofit every air pack and replace every air bottle it would take an extreme cost factor at approx $900 per air bottle without the retrofit fees. Or having � types of air bottles for � types of air packs, which would have to be designated. With a roster of �5 members, safety would be a concern, confusion on a fire scene would occur during an incident due to someone needing to replace an air bottle in an emergency situation or having to wait for a cascade unit to arrive to fill the limited supply of “blue” bottles during the infancy stages of replacing, rather than retrofitting the department supply. After up to 15 years the transition would be complete. A fire department has many regulations and standards to uphold and a volunteer dept operates just as professional as a career dept. But, doesn’t

necessarily have the manpower and the consistent manpower due to rotation of membership. So training, re-training on air bottle selection would interfere with basic firefighting operations and skills.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-157 Log #80 FAE-RPE Final Action: Accept in Principle(6.5.7, 7.16. 8.23 through 8.25)____________________________________________________________Submitter: Harold Hoskins, Scott County Fire DepartmentComment on Proposal No: 1981-�Recommendation: The requirement for interoperable cylinders should be deleted. If the Committee feels that this is a necessity, then the standard should be written to take effect in 15 years, the end of expected life for new cylinders. A method of phase in over this 15 year period should be developed.Substantiation: The interoperable cylinder mandate is an unfunded mandate, creating a financial hardship on departments of any size. By developing a 15 year phase in method, manufacturers could develop a bridge that would allow use of existing cylinders until their life is over, and use of new compliant cylinders throughout this 15 year period until a department has cycled through their cylinder inventory. Immediate implementation of this mandate should only be passed with a funding measure to allow all departments to be able to meet the standard.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-158 Log #15 FAE-RPE Final Action: Accept in Principle(6.5.7, 7.17, 8.23 through 8.25)____________________________________________________________Submitter: Howard Twining, Piper Creek Twp, VFDComment on Proposal No: 1981-�Recommendation: The standard needs to be left as is as it relates to interchangeability. It has taken us in the rural fire service(read as volunteer) many, many years and hundreds of pancake sales, along with a small smattering of federal grants, to be able to outfit our firefighters with SCBA. Every time you change the standard it costs us money we don’t have. If you need to cause the metro departments to be able to share equipment then find a way to leave us alone. The manufacturing (SCBA)community will build to a revised standard then stop supporting existing systems. My department along with those I have spoken to will not be able to fund the purchase of new bottles for many years. There is no money tree for the small departments. There are no reasons to tell us we need to change our �005 current SCBA’s. I can’t buy fuel for my trucks at this point, let alone air pack up grades. Don’t cause the rural fire departments to become non NFPA supporting departments, We would be forced to buy non NFPA equipment or forgo replacing it when its life cycle is expended. Substantiation: Rural fire service is not invited to be part of the urban CBRN issue. Interoperability is already good with low pressure systems or high pressure systems. Costs of the up grade will prohibit most departments from the up grade.Federal funds will not be available for the bulk of the rural departments. I think the percentage of departments I am speaking of is in the 70 percent range of the total number of departments. IAB is way off course on this one. They can build/demand many stockpiles of equipment that never will get used however, they should not try to become desk experts on how to run a fire department. This change would lead to more departments disregarding the NFPA as a standard that we would like to follow. The “Consensus” is that NFPA must work for the fire service not against.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-159 Log #6� FAE-RPE Final Action: Reject(6.6)____________________________________________________________Submitter: Karen Lehtonen, Lion ApparelComment on Proposal No: 1981-�Recommendation: Delete the entire section.Substantiation: Accessories are no longer being addressed by the product standards in this project.Committee Meeting Action: RejectCommittee Statement: Accessories are covered for SCBA in NFPA 1981.

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Report on Comments F2006 — Copyright, NFPA NFPA 1981

1981-153 (Log #2) Recommendation

FIGURE 6.5.1

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Report on Comments F2006 — Copyright, NFPA NFPA 1981

1981-153 (Log #2) Recommendation

FIGURE 6.5.1 (continued)

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Report on Comments F2006 — Copyright, NFPA NFPA 1981____________________________________________________________1981-160 Log #154 FAE-RPE Final Action: Accept in Principle(6.6)____________________________________________________________Submitter: A. Paul Bull, Fairfax County Fire and Rescue DepartmentComment on Proposal No: 1981-�Recommendation: Add text to read as follows: Communication Device. Chapter 6 Design Requirements 6.x Communication Device. 6.x.x All SCBA shall have a means of enhancing the users’ voice/speech that meets or exceeds the performance requirements as stated in 7.10. 6.x.x Should an SCBA make use of electronics to meet the performance requirements of 7.10, the SCBA shall also have a secondary system which shall meet the test performance standards under Section 8.10.x. 6.x.x If a secondary system is present it shall work independently of the primary system. Note: the mechanical speech diaphragm is provided only for minimum communication ability during emergency exit from hazardous environments when the electronic communication system fails. 6.x.x The SCBA manufacture shall clearly state in their users instructions that (1) Should the user experience an electronic communication system failure they are to immediately leave the hazardous environment. (�) Failure of the electronic communication system shall render the SCBA uncertified for use. 6.x.x Electronic communications device shall have a continuous means to inform the user that the system is on. 6.x.x If the primary communications system requires a battery, it shall meet Section 8.10 for communications requirements while in the low battery condition for a minimum of 60 minutes. 6.x.x Electronic communication device shall remain in place during the test for the mechanical speech diaphragm test.Substantiation: New section on communications not in draft proposal.Committee Meeting Action: Accept in Principle See Committee Comment 1981-8� (Log #CC�).Committee Statement: See Committee Comment 1981-8� (Log #CC�).

____________________________________________________________1981-161 Log #159 FAE-RPE Final Action: Reject(6.7)____________________________________________________________Submitter: John Morris, International Safety Instruments, Inc.Comment on Proposal No: 1981-�Recommendation: Add text to read as follows: 6.7 Communication System. 6.7.1 All SCBA’s primary communications system shall be activated with no other procedures than those required to activate the SCBA breathing system.Substantiation: If required to pass communications test, it should have auto activation.Committee Meeting Action: RejectCommittee Statement: The committee recognizes that being able to turn the device off is very desirable during certain incidents.

____________________________________________________________1981-16� Log #64 FAE-RPE Final Action: Accept(Chapter 7)____________________________________________________________Submitter: Karen Lehtonen, Lion ApparelComment on Proposal No: 1981-�Recommendation: 7.1.� The reference to 6.�.9 should be 6.�.9.5. 7.�.�.1 The reference to 6.�.9 should be 6.�.9.5. 7.�.�.� The reference to 6.�.9 should be 6.�.9.5. 7.�.�.� The reference to 6.�.9 should be 6.�.9.5. 7.�.�.4 The reference to 6.�.9 should be 6.�.9.5. 7.�.� The reference to 6.�.9 should be 6.�.9.5. 7.7.4 The reference to 6.�.9 should be 6.�.9.5. 7.8.� The reference to 6.�.9 should be 6.�.9.5. 7.11.6 The reference to 6.�.9 should be 6.�.9.5. 7.14.� The reference to 6.�.9 should be 6.�.9.5. 7.14.� The reference to 6.�.9 should be 6.�.9.5.Substantiation: Since the performance requirement is to evaluate the visual information for the breathing air cylinder content, the reference in these performance requirements should be specifically to the design requirement in 6.�.9.5 instead of all the performance requirements in 6.�.9.Committee Meeting Action: Accept

____________________________________________________________1981-16� Log #4 FAE-RPE Final Action: Reject(7.10)____________________________________________________________Submitter: David Hodson, Draeger Ltd.Comment on Proposal No: 1981-1Recommendation: In Section 7.10 remove all reference to primary communication device and performance at 4.6 m (15 ft).Substantiation: Draeger believe that by increasing the distance that a firefighter can communicate is not a proven safe practice. Fire fighters

must adhere to the two man rule and have close if not actual contact at all times. Allowing fire fighters to be further apart during any operation will allow the pair to become easily separated and this causes a safety issue. Until it is clear and proven that firefighters can be 15 ft apart and not become more easily separated from each other, it would be safer to keep communication distance at its current level. Evidence from the field must clearly indicate that any additional distance to communicate would not put firefighters at risk.Committee Meeting Action: RejectCommittee Statement: Paragraph 7.10.1 does not address the distance where the performance is evaluated. These specifications are contained in the referenced test method.

____________________________________________________________1981-164 Log #1�� FAE-RPE Final Action: Accept in Principle(7.10.1 and 7.10.2)____________________________________________________________Submitter: Stephen R. Sanders, Safety Equipment Institute (SEI)Comment on Proposal No: 1981-�Recommendation: Revise text to read:

7.10.1 The SCBA primary communication means, as identified by the SCBA manufacturer, shall be tested for communications performance as specified in Section 8.10, Communication Test, and shall have a an average calculated value of not less than 85 percent.

7.10.2 The SCBA secondary communication means, as identified by the SCBA manufacturer shall be tested for communications performance as specified in Section 8.10, Communication Test, and shall have a an average calculated value of not less than 75 percent.Substantiation: 7.10.1 and 7.10.� were revised to clarify that the communications performance is an average calculated value, as noted in the test method, 8.10.6 and 8.10.7.Committee Meeting Action: Accept in Principle Revise 7.10.1 to read: The SCBA voice communications system shall be tested for communications performance as specified in Section 8.10, Voice Communications Test, and shall have an average score value of not less than 85 percent. Delete 7.10.�.Committee Statement: The committee modified the text to reflect modifications made during the ROC. Paragraph 7.10.� is being deleted.

____________________________________________________________1981-165 Log #19 FAE-RPE Final Action: Accept in Principle(7.10.1.1 (New) )____________________________________________________________Submitter: Dave Haston, US Forest ServiceComment on Proposal No: 1981-�Recommendation: Add new text to read as follows: 7.10.1.1 If the output level of the SCBA primary communication means is adjustable by the user, the primary communications test specified in Section 8.10 shall be performed with the output set at the maximum level.Substantiation: If the primary communications test is not performed with the output (of an adjustable device) set to its lowest level, the SCBA may not meet the requirements of Section 8.10 at the minimum output level. Firefighter safety may be compromised.Committee Meeting Action: Accept in Principle See Committee Comment 1981-8� (Log #CC�).Committee Statement: See Committee Comment 1981-8� (Log #CC�). The testing at the “maximum level” will be in the test method, Section 8.10.

____________________________________________________________1981-166 Log #141 FAE-RPE Final Action: Reject(7.10.2)____________________________________________________________Submitter: Mark Miller, Ultra/AudiopackComment on Proposal No: 1981-�Recommendation: Revise text to read as follows: 7.10.� The SCBA secondary communication means, as identified by the SCBA manufacturer, shall be tested for communications performance as specified in Section 8.10, Communication Test, and shall have a value of not less than 75 percent. (Add the following): “The primary means of communication can be removed to conduct testing on the secondary means of communications (so long as this can be done without tools)”.Substantiation: There is no wording specifically spelling out that the primary means of communication can be removed to facilitate use and testing of the secondary means of communication (especially if it was designed to be removable in the field).Committee Meeting Action: RejectCommittee Statement: See Committee Comment 1981-8� (Log #CC�).

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Report on Comments F2006 — Copyright, NFPA NFPA 1981____________________________________________________________1981-167 Log #1�4 FAE-RPE Final Action: Accept in Principle in Part(7.14.3, 7.14.4, 7.17.1, 8.17, 8.26.2.1, 8.26.3, and 8.26.5.11)____________________________________________________________Submitter: Stephen R. Sanders, Safety Equipment Institute (SEI)Comment on Proposal No: 1981-�Recommendation: Revise text to read:

7.14.3 HUD shall be tested for splash resistance as specified in Section 8.17, HUD Liquid Splash Resistance Test, and shall display the visual information for the breathing air cylinder content as specified in 6.�.9, and shall display the visual alert signal as specified in 6.�.8.5.

7.14.4 Where batteries are used for HUD to comply with the requirements of this standard, HUD shall be tested for splash resistance as specified in Section 8.17, HUD Liquid Splash Resistance Test, and shall have no water in the battery compartment at the completion of the test.

7.17.1 SCBA shall be tested for proper functioning of all electronics water immersion into each electronic device of the SCBA required to meet Section 6, Design Requirements, as specified in Section 8.�6, Immersion Leakage Tests, and the electronics shall function properly as before the testing, and the electronics and power supply compartments or enclosures shall remain dry.

Delete Section 8.17 in its entirety.8.26.2.1 Each sample to be tested shall be as specified in 4.X.X 4.�.9.8.26.3 Specimens. One specimen shall be tested after conditioning

within an oven specified within 8.�6.4 at 177ºC, +5ºC/-0ºC, (�50ºF, +10ºF/-0ºF) for 5 minutes. Prior to testing, specimens shall be conditioned for a minimum of 4 hours at an ambient temperature of ��ºC, ±�ºC (7�ºF, ±5ºF), with a relative humidity (RH) of 50 percent, ±�5 percent.

8.26.5.11 The electronic device shall be tested for proper function to determine pass/fail.Substantiation: Based on discussions at the Jacksonville, FL, TC meeting regarding addition of the Immersion Leakage Test to NFPA 1981-�007, the HUD Liquid Splash Resistance Test should be deleted. This is because of the discussion that the Immersion Leakage Test could be considered the worst case scenario for water ingress testing. The revisions contained in this comment serve to accomplish the task of deleting the HUD Liquid Splash Resistance Test (Section 8.17) as well as its associated performance requirements 7.14.� and 7.14.4). Additionally, the Immersion Leakage Test and its associated performance requirements have been revised to clarify that it’s a test for the ingress of water only, not for functionality. Committee Meeting Action: Accept in Principle in Part 1. Accept in Principle. See committee action on Comment 1981-174 (Log #107). �. Accept. �. Accept.Committee Statement: 1. See committee action on Comment 1981-174 (Log #107). �. This will amend text of action on 1981-174 (Log #107) for 8.�6.� 8.�6.�.1, and 8.�6.5.11.

____________________________________________________________1981-168 Log #108 FAE-RPE Final Action: Accept(7.14.3 and 8.17)____________________________________________________________Submitter: Michael T. Rupert, MSAComment on Proposal No: 1981-�Recommendation: Delete the following text:7.14.� HUD shall be tested for splash resistance as specified in Section 8.17, HUD Liquid Splash Resistance Test, and shall display the visual information for the breathing air cylinder content as specified in 6.�.9, and shall display the visual alert signal as specified in 6.�.8.5.8.17 HUD Liquid Splash Resistance Test.Substantiation: Should be deleted because the immersion test is more severe, therefore the splash test is not needed. Note that 7.14.� is related to this section, therefore it should also be removed.Committee Meeting Action: Accept

____________________________________________________________1981-169 Log #190 FAE-RPE Final Action: Accept(7.14.3 and 8.17)____________________________________________________________Submitter: Jeffrey L. Landis, Tyco/Scott Health and SafetyComment on Proposal No: 1981-�Recommendation: Remove HUD Liquid Splash Resistance requirement specified in 7.14.�, and test specified in Section 8.17.Substantiation: With the addition of the more stringent Immersion leakage Requirements specified in Sections 7.17 and 8.�6, the benefit of having the Liquid Splash Test is negated.Committee Meeting Action: Accept

____________________________________________________________1981-170 Log #�0� FAE-RPE Final Action: Accept in Principle(7.16)____________________________________________________________Submitter: Salvatore Cassano, New York City Fire DepartmentComment on Proposal No: 1981-�Recommendation: Eliminate all references to the requirement for interchangeable SCBA breathing air cylinders as well as associated references and testing requirements.Substantiation: The changes recommended by this standard could decrease rather enhance firefighter safety. The requirement for interchangeable cylinders could have a negative effect on product innovation at a cost to firefighter safety. There has not been any evidence presented to document the need for interchangeability. Not all fire departments use the same pressure; therefore interchangeability will only be achieved via a single universal pressure. Forward/backward compatibility will not be assured placing departments in a position of lacking compatibility among existing vendors.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-171 Log #��6 FAE-RPE Final Action: Accept in Principle(7.16, 7.16.4)____________________________________________________________Submitter: William T. Mundy, Fire Department City of New YorkComment on Proposal No: 1981-�Recommendation: Delete text in entire Section 7.16 titled Interchangeable Breathing Air Cylinder Performance Requirements. Delete all related subsections (1-4) in Section 7.16.Substantiation: Interchangeability already exists and is approved by OSHA in an emergency situation where the need for breathing air is urgent. OSHA approves the use of a different manufacturer’s air cylinder on a different manufacturer’s SCBA. In a true emergency, interchangeability does exist. If that is the core concern of NFPA, then the text in Section 7.16 is unnecessary and burdensome to the fire service due to the lack of forward and backward capability of the stated text and proposed cylinder. this radical approach does not enhance firefighting safety or effectiveness. new standards and designs must interface seamlessly with existing equipment to become effective. Introducing a new cylinder design, that voids, the NIOSH and NFPA approvals, of an existing SCBA is unjustifiable.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-17� Log #1�� FAE-RPE Final Action: Accept in Part(7.16.2 and 7.16.3)____________________________________________________________Submitter: Stephen R. Sanders, Safety Equipment Institute (SEI)Comment on Proposal No: 1981-�Recommendation: Revise text to read:

7.16.2 The SCBA backframe and cylinder retention device shall be tested for cylinder and valve assembly retention security as specified in Section 8.�4, Breathing Air Cylinder and Valve Assembly Retention Test, and the cylinder and valve assembly shall not change position by more than �5 mm (1 in.).

7.16.3 4 The SCBA CGA cylinder valve handwheel connection shall be tested for clearance as specified in Section 8.�5, Cylinder Connections and Accessibility Test, and the CGA handwheel shall have a clearance between the outer diameter of the handwheel of not less than �5 mm (1 in.) from any other surface of the SCBA.Substantiation: Editorial “clean-up” corrections to Section 7.16.Committee Meeting Action: Accept in Part 1. Accept. �. Reject. See Committee Comment 1981-76 (Log #CC1).Committee Statement: �. See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-17� Log #71 FAE-RPE Final Action: Reject(7.17.1)____________________________________________________________Submitter: David Hodson, Draeger Ltd.Comment on Proposal No: 1981-�Recommendation: Revise text to read: SCBA shall be tested for leak tightness of the electronics that are used to meeting the requirements of this standard. Tests are as specified in Section 8.�6, Immersion Leakage Test. The electronics and power source compartments and enclosures shall remain dry. Electronic components which are fully enclosed in the facemask are exempt from this test.Substantiation: Testing is confined to a leak test. This will ensure that the leakage is checked shortly after the test is completed and gives little

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Report on Comments F2006 — Copyright, NFPA NFPA 1981time for water which may have ingressed to evaporate or disperse. Test of components fully mounted internally to the facemask will not be subjected to the extremes of temperature and water immersion and need not be subject to the test.Committee Meeting Action: RejectCommittee Statement: See committee action on Comment 1981-174 (Log #107) and 1981-167 (Log #1�4).

____________________________________________________________1981-174 Log #107 FAE-RPE Final Action: Accept(7.17.1, 8.26.3, 8.2.6.5.7, and 8.26.5.11)____________________________________________________________Submitter: Michael T. Rupert, MSAComment on Proposal No: 1981-�Recommendation: Revise text to read as follows: 7.17.1 SCBA electronics shall be tested for resistance to heat and water ingress as specified in Section 8.�6, Heat and Immersion Test, and the electronics shall function properly in accordance with the SCBA manufacturers’ instructions for normal use, and all power source compartments or enclosures shall remain dry. 8.�6.� Specimens. One specimen Two specimens shall be tested after conditioning within an oven specified within 8.�6.4 at 177°C, +5°/-0°C, (�50°F,+10°/-0°F) for 5 minutes. 8.�6.5.7 On one of the two specimens, all electronic components shall be operated in accordance with the manufacturer’s instructions for normal use to determine the proper functioning. 8.�6.5.11 The electronic device shall be tested for proper function to determine pass or fail.Substantiation: The proposed language adds an additional specimen for the purpose of conducting the functionality tests. The other specimen must be opened within �0 seconds to inspect for water immersion, therefore it cannot be used for functional testing.Committee Meeting Action: Accept

____________________________________________________________1981-175 Log #41 FAE-RPE Final Action: Accept(Chapter 8)____________________________________________________________Submitter: Robert Sell, Draeger Safety, Inc.Comment on Proposal No: 1981-�Recommendation: Revise appropriate sections where “Samples” are identified to: Each sample to be tested as specified in 4.�.5 4.�.9 The affected sections are: 8.1.�, 8.�.�, 8.�.�, 8.7.�, 8.8.�, 8.10.�, 8.11.�, 8.1�.�, 8.14.�, 8.15.�, 8.16.�, 8.17.�, 8.18.1.�, 8.18.�.�, 8.19.�, 8.�0.�, 8.�1.�, and 8.��.�.Substantiation: Correct testing section is identified. The incorrect reference section is from NFPA 1981, �00� edition and with the revision to this ROP the new section has now been renumbered as 4.�.9.Committee Meeting Action: AcceptCommittee Statement: See committee action on Comment 1981-1 (Log #69).

____________________________________________________________1981-176 Log #CC� FAE-RPE Final Action: Accept(8.1.3.3)____________________________________________________________Submitter: Technical Committee on Respiratory Protection Equipment Comment on Proposal No: 1981-1Recommendation: Revise text to read as follows: 8.1.3.3 The air used in the SCBA breathing air cylinders shall comply with the air quality requirements of NFPA 1989, Standard on Breathing Air Quality for Fire and Emergency Services Respiratory Protection.Substantiation: The text has revised to change the referenced document for breathing air quality from the CGA standard to the NFPA 1989 standard which covers all the requirements for breathing air quality for SCBA for emergency responders.Committee Meeting Action: Accept

____________________________________________________________1981-177 Log #1�4 FAE-RPE Final Action: Accept(8.1.4.10.9)____________________________________________________________Submitter: Stephen R. Sanders, Safety Equipment Institute (SEI)Comment on Proposal No: 1981-�Recommendation: Revise text to read: 8.1.4.10.9 The construction of the breathing machine shall be such that the respiration rate, tidal volume, peak flow, and facepiece pressure measurement system accuracy are unaffected by temperature changes caused by the environmental air flow performance tests as specified in Section 8.�, End-of-Service-Time-Indicator (EOSTI) Environmental Temperature Tests.Substantiation: Editorial “clean-up” correction to 8.1.4.10.9.Committee Meeting Action: Accept

____________________________________________________________1981-178 Log #18� FAE-RPE Final Action: Accept in Principle(8.1.5.6)____________________________________________________________Submitter: Jason L. Allen, IntertekComment on Proposal No: 1981-�Recommendation: Delete “�0 cycles of the breathing machine” and replace with “down to �0 Bar”.Substantiation: Task group felt that the airflow performance should be monitored down closer to end of cylinder air content.Committee Meeting Action: Accept in Principle See committee action on Comment 1981-100 (Log #109).Committee Statement: See committee action on Comment 1981-100 (Log #109).

____________________________________________________________1981-179 Log #179 FAE-RPE Final Action: Accept(8.2.4.2)____________________________________________________________Submitter: Jason L. Allen, IntertekComment on Proposal No: 1981-�Recommendation: Delete “A test headform as specified in 8.1.4 shall be equipped with a thermocouple or other temperature sensing element to monitor SCBA test chamber temperature”. Replace with “During the environmental exposures within 8.�.5.5, 8.�.5.6, 8.�.5.7, and 8.�.5.8, the SCBA shall be mounted on a Scott Aviation Model No. 80�608-01 or 80�608-0� test headform or equivalent.”Substantiation: This test requires a headform other than the one specified in 8.1.4.Committee Meeting Action: Accept

____________________________________________________________1981-180 Log #180 FAE-RPE Final Action: Accept(8.2.4.3)____________________________________________________________Submitter: Jason L. Allen, IntertekComment on Proposal No: 1981-�Recommendation: Delete “attached to the test headform in a manner in which it will be exposed directly to the chamber atmosphere” and replace with “mounted within the chamber in a manner in which it will be exposed directly to the chamber atmosphere”.Substantiation: Mounting to the headform could cause inaccurate readings of the chamber environment due to heat sinking/sourcing of the headform.Committee Meeting Action: Accept

____________________________________________________________1981-181 Log #176 FAE-RPE Final Action: Accept(Figure 8.3.4.7)____________________________________________________________Submitter: Jason L. Allen, IntertekComment on Proposal No: 1981-�Recommendation: Delete “Stepanofoam RI-9619” and “System” from item � within the Figure.Substantiation: An alternate supplier for foam was found who produces an easier to work with product, but the density is different from density specified in table. This change will not effect test as the cylinder will still maintain correct total weight.Committee Meeting Action: Accept

____________________________________________________________1981-18� Log #44 FAE-RPE Final Action: Accept(8.3.4.9)____________________________________________________________Submitter: Robert Sell, Draeger Safety, Inc.Comment on Proposal No: 1981-�Recommendation: Revise to read: The attachment of the cylinder valve shall be tightened to a torque value of 5 N-m +0.5/-0.0 N-m (45 in.-lbs +5/-0 in.-lbs).Substantiation: Including the metric torque value would remain consistent with the standard and equivalent measurement values that are used throughout the document.Committee Meeting Action: AcceptCommittee Statement: This amends the portion of text in 8.�.4.9 committee action on Comment 1981-18� (Log #�41) to give the metric values.

____________________________________________________________1981-18� Log #�41 FAE-RPE Final Action: Accept(8.3.4.9)____________________________________________________________Submitter: Daniel N. Rossos, City of Portland Fire BureauComment on Proposal No: 1981-�Recommendation: Change to read: The attachment of the cylinder valve shall be permitted to be wrench tightened prior to the test. Change to read: The attachment of the cylinder valve shall be tightened to a torque setting of 45 in. pounds prior to the test. An opposing line

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Report on Comments F2006 — Copyright, NFPA NFPA 1981no wider than 1/8 in., shall be placed on both the male and female GCA fitting prior to starting the test. This will identify the relationship between the male and the female CGA fitting when tightened at the proper torque setting. During the test, the movement of either the male or female CGA fitting causing a break in the line of any width will constitute a failure.Substantiation: The CGA fitting on an SCBA is not used wrench tight in the field. This torque setting used for the test will better represent field use and identify CGA fittings that may become loose under normal use.Committee Meeting Action: AcceptCommittee Statement: See committee action on Comment 1981-18� (Log #44).

____________________________________________________________1981-184 Log #1�5 FAE-RPE Final Action: Accept(8.5.5.5)____________________________________________________________Submitter: Stephen R. Sanders, Safety Equipment Institute (SEI)Comment on Proposal No: 1981-�Recommendation: Revise text to read: 8.5.5.5 The test exposure time shall begin when the test thermocouple recovers to the temperature of �60ºC, +6ºC or -0ºC +6ºC/-0ºC (500ºF, +10ºF or -0ºF +10ºF/-0ºF).Substantiation: Editorial “clean-up” correction to 8.5.5.5.Committee Meeting Action: Accept

____________________________________________________________1981-185 Log #1�6 FAE-RPE Final Action: Accept(8.5.8)____________________________________________________________Submitter: Stephen R. Sanders, Safety Equipment Institute (SEI)Comment on Proposal No: 1981-�Recommendation: Revise text to read: 8.5.8 Specific Requirements for Testing Fabrics less than 75 380 mm (3 15 in.) Wide.Substantiation: Editorial “clean-up” correction to the title for 8.5.8.Committee Meeting Action: Accept

____________________________________________________________1981-186 Log #178 FAE-RPE Final Action: Accept(8.8.4.1)____________________________________________________________Submitter: Jason L. Allen, IntertekComment on Proposal No: 1981-�Recommendation: Delete “The test headform as specified in 8.1.4” and replace with “A Scott Aviation model No. 80�608-01 or 80�608-0� test headform or equivalent”.Substantiation: This test requires a headform other than the one specified in 8.1.4.Committee Meeting Action: Accept

____________________________________________________________1981-187 Log #45 FAE-RPE Final Action: Accept(8.9.5.12.2)____________________________________________________________Submitter: Robert Sell, Draeger Safety, Inc.Comment on Proposal No: 1981-�Recommendation: Revise to read: The center of the stroke shall be within +/-� mm (+1/- 1/16 in.) (+/- 1/16 in.).Substantiation: Incorrect equivalent value listed for � mm.Committee Meeting Action: Accept

____________________________________________________________1981-188 Log #1�7 FAE-RPE Final Action: Accept(8.9.5.12.2)____________________________________________________________Submitter: Stephen R. Sanders, Safety Equipment Institute (SEI)Comment on Proposal No: 1981-�Recommendation: Revise text to read: 8.9.5.12.2 The center of the stroke shall be within ± � mm (± 1 1/16 in.) of the center of the specimen.Substantiation: Editorial “clean-up” correction for 8.9.5.1�.�.Committee Meeting Action: Accept

____________________________________________________________1981-189 Log #149 FAE-RPE Final Action: Accept in Principle(8.10)____________________________________________________________Submitter: A. Paul Bull, Fairfax County Fire and Rescue DepartmentComment on Proposal No: 1981-�Recommendation: Add text to read as follows: Low battery test method 8.10.x Electronic communication device shall be tested under the parameters as stated in 6.5.4 for low battery warning and performance level.

8.10.x Before starting the test, the specimen ECD battery shall be discharged to the level at which the ECD first emits the low battery warning. 8.10.x The ECD shall perform at the stated test level for a minimum of 60 minutes while in the low battery warning mode.

Substantiation: Proposal currently does not have low battery test for the communication device.Committee Meeting Action: Accept in Principle See Committee Comment 1981-8� (Log #CC�).Committee Statement: See Committee Comment 1981-8� (Log #CC�).

____________________________________________________________1981-190 Log #14� FAE-RPE Final Action: Accept(8.10.2)____________________________________________________________Submitter: Mark Miller, Ultra/AudiopackComment on Proposal No: 1981-�Recommendation: Revise text to read as follows: Samples. Each sample to be tested shall be as specified in 4.�.9 (referencing 4.�.5 does not make any sense. Substantiation: This reference does not make any sense: Section 4.�.5 says: Inspection by the certification organization shall include a review of all product labels to ensure that all required label attachments, compliance statements, certification statements and other product information are at least as specified for the protective ensemble and ensembles in Section 5.1. How do the label requirements fit Section 8.10.�?Committee Meeting Action: AcceptCommittee Statement: See committee action on Comment 1981-1 (Log #69).

____________________________________________________________1981-191 Log #164 FAE-RPE Final Action: Accept(8.10.2)____________________________________________________________Submitter: Bruce A. Hefner, International Safety InstrumentsComment on Proposal No: 1981-�Recommendation: Reference to “4.�.5” should be “4.�.9”.Substantiation: Correction.Committee Meeting Action: AcceptCommittee Statement: See committee action on Comment 1981-1 (Log #69).

____________________________________________________________1981-19� Log #155 FAE-RPE Final Action: Accept in Principle(8.10.3.1)____________________________________________________________Submitter: A. Paul Bull, Fairfax County Fire and Rescue DepartmentComment on Proposal No: 1981-�Recommendation: Add “preconditioning, to discharge the battery (if applicable) to the low-battery level. Only one test needs to be conducted, which would be on low battery (if unit has battery).Substantiation: None given.Committee Meeting Action: Accept in Principle See Committee Comment 1981-8� (Log #CC�).Committee Statement: See Committee Comment 1981-8� (Log #CC�).

____________________________________________________________1981-19� Log #14� FAE-RPE Final Action: Reject(8.10.4.10)____________________________________________________________Submitter: Mark Miller, Ultra/AudiopackComment on Proposal No: 1981-�Recommendation: Revise text to read: 8.10.4.10 The distance between the talker and the listener(s) for the primary system shall be 4.6 m, +�00 mm/-0 mm (15 ft, +1 ft/-0 ft) and they shall be facing each other. (4.6 m, +�00 mm/-0 mm (15 ft, +1 ft/-0 ft) should be replaced with: 1.5 m, �05 mm/-0 mm (5 ft +1 ft/-0 ft).Substantiation: In 1981-�007 Section 8.10; the distance specified in Section 8.10 for the intelligibility testing should be changed from 15 ft to 5 ft for the following reasons: (1) Reason: Since the distance was increased from 5 ft (per NFPA 1981-�00�) to 15 ft (per NFPA 1981-�007) the intelligibility level cannot be met because of the drastic increase in power requirements. To make the required loudness level above the background noise the power delivered to the amplifier must be increased well beyond what I.S. allows (even with I.S. classes C&D removed): Substantiation: Because the distance has been increased by a factor of � (from 5 ft to 15 ft) the power required to keep the same loudness must be increased by a factor of 9. (See the illustration and Graph on the following page.

1981-61

Report on Comments F2006 — Copyright, NFPA NFPA 1981

“Graph #1” depicts the acoustic power VS distance graphically which is illustrated in “Illustration #1”. Using the 5 ft specified in NFPA 1981-�00� as “r” and NFPA 1981-�007 specifies 15 ft (� times “r”, or �r). The intensity (and power) needs to be 9 times greater to have the same perceived loudness (so that it could be heard above the background noise).

________________1From hyperphysics.phy-astr.gsu.edu�From hyperphysics.phy-astr.gsu.edu

Because the distance has been increased by a factor of � (from 5 ft to 15 ft) the power required to keep the same loudness at the new distance has been increased by a factor of 9 (not achievable). If it was, the sound level emitted at the Voice Amplifier would be extremely loud (91.6 dB) when considering that the Voice Amplifier is mounted close to the ear. I = P/(4*�.14*r^�) Where: I = intensity (watts/ft^�) P = Acoustic power (watts) R = distance from acoustic power source (feet) I(dB) = 10*log10(I/Io) Where: Io=10^-1� watts/m^� = 9.� x 10^-14 I(dB)=SPL

Table 1: Calculated SPL required for distances specified in NFPA 1981-2002:

Acoustic Power(watts)

Distance(feet)

SPL(dB)

0.00116 �.5 8�.00.00116 5 76.00.00116 10 70.00.00116 15 66.5

(Distance per NFPA 1981-�00�)

Table 2: Calculated SPL required for distances specified in NFPA 1981-2007:

Acoustic Power(watts)

Distance(feet)

SPL(dB)

0.01046 �.5 91.60.01046 5 85.50.01046 10 79.50.01046 15 76.0

(Distance per NFPA 1981-�007)

• Note: 76 dB is required at the specified distance because 6 dB above the background noise is required for the signal to be heard clearly.• Note: The power required in NFPA 1981-�007 is 9 times what is required in NFPA 1981-�00�.• Note: Acoustic Power (watts) is the sound output from the speaker in watts, not the power consumed. The amplifiers that meet the current NFPA 1981-�00� specification conform to I.S. without substantial head room in power consumption.

(�) Reason: The requirement that for the primary communication device, 85 percent can be achieved and should be included in the latest NFPA 1981 specification, is not valid for the distances and the background noise levels specified in NFPA 1981-�007. We believe the new specification was based on a test conducted by CWRU titled “An Exploratory Study of NFPA Speech Intelligibility Testing Using Six NFPA Approved SCBA Face-pieces Equipped with Audio Mask Amplifiers” (dated 10/�0/�00�). This test was doe with the assistance of Audiopack, using a test procedure written by NIOSH (test report and procedure that has been submitted). Substantiation: The results of the CWRU study show that 84 percent can be achieved, but only under significantly lower background noise and shorter distance (background noise was 60 dB not 70 dB (60 dB to 70 dB is twice as loud). Distance was 10 feet, not 15 feet). Using the lower background noise allows the distances higher than 5 feet. If you look at “Table 1” you will see that the calculated amplifier output was able to produce 66 dB at 15 feet. This made the sound produced by the amplifier louder than the background noise. If the background noise was 70 dB, the amplifier could not be heard above the background noise. Conclusion #� of the CWRU study says: “Again, independent of the mask but with the mask amplifier ON, from the distance of 10 ft to the distance of 15 ft, the value of the average (correct) score decreased. The average reduction, across all six masks, was (8�.11%-74.1�%) = 7.98%.” Conclusion: As a result, we strongly recommend changing the distance from 15 feet to 5 feet and keeping the 70 dB background noise and 85% (using MRT, circle the word) intelligibility. This change is a reasonable requirement for primary communications for NFPA 1981-�007. Note: Supporting material is available for review at NFPA Headquarters.Committee Meeting Action: RejectCommittee Statement: See Committee Comment 1981-8� (Log #CC�).

____________________________________________________________1981-194 Log #5� FAE-RPE Final Action: Reject(8.10.4.10, 8.10.4.15, 8.10.4.16, 8.10.5.2.3, and 8.10.5.2.4)____________________________________________________________Submitter: Robert Sell, Draeger Safety, Inc.Comment on Proposal No: 1981-�Recommendation: Revise 8.10.4.10, 8.10.4.15, and 8.10.5.�.� as follows and include new sections/text: 8.10.4.10 The distance between the talker and listener(s) for the primary system shall be 4.6 m, +�05 mm/-0 mm (15 ft, +1 ft/-0 ft), 1.5 m +�05 mm/-0 mm (5 ft, +1 ft/-0 ft), and they shall be facing each other. The distance between the talker and listener(s) for the secondary system shall be 1.5 m +�05 mm/-0 mm (5 ft, +1 ft/-0 ft), and they shall be facing each other. 8.10.4.15 For the primary system, the gain of the power amplifier shall be adjusted to achieve an A-weighted sound level of 80 dB, +/-� dB, at each listener’s head position, without listener’s present. 8.10.4.16 For the secondary system, the gain of the power amplifier shall be adjusted to achieve an A-weighted sound level of 70 dB, +/0� dB, at each listener’s head position, without listener’s present. 8.10.5.�.� For the primary system, the talkers shall be trained to talk at 85 dBA - 95 dBA without a SCBA facepiece, measured at the listener’s ear, placing no unusual stress on any word. 8.10.5.�.4 For the secondary system, the talkers shall be trained to talk at 75 dBA - 85 dBA without a SCBA facepiece, measured at the listener’s ear, placing no unusual stress on any word. Revise section numbering accordingly after 8.10.5.�.4.Substantiation: Increasing the distance that a fire fighter can communicate may not increase fire fighters safety. Increasing the background noise will improve the primary communication system.

1981-6�

Report on Comments F2006 — Copyright, NFPA NFPA 1981Committee Meeting Action: RejectCommittee Statement: See Committee Comment 1981-8� (Log #CC�).

____________________________________________________________1981-195 Log #144 FAE-RPE Final Action: Accept in Principle(8.10.4.15)____________________________________________________________Submitter: Mark Miller, Ultra/AudiopackComment on Proposal No: 1981-�Recommendation: Revise text to read: 8.10.4.15 The gain of the power amplifier shall be adjusted to achieve an A-weighted sound level of 70 dB, +/-� dB, at each listener’s head position, without listeners present. (“power amplifier” should be replaced with; “power amplifier used to generate the pink noise”).Substantiation: The term “power amplifier” alone could be misunderstood to be the voice amplifier or VPU (editorial error). Note: Supporting material is available for review at NFPA Headquarters.Committee Meeting Action: Accept in Principle See Committee Comment 1981-8� (Log #CC�).Committee Statement: See Committee Comment 1981-8� (Log #CC�).

____________________________________________________________1981-196 Log #15� FAE-RPE Final Action: Accept in Principle(8.10.5.1)____________________________________________________________Submitter: A. Paul Bull, Fairfax County Fire and Rescue DepartmentComment on Proposal No: 1981-�Recommendation: Change test to: “MRT, Modified Rhyme Test both for primary and secondary systems.”Substantiation: This test was used in the preliminary communication testing done by the TC on communication, committee discussions agree on this change.Committee Meeting Action: Accept in Principle See Committee Comment 1981-8� (Log #CC�).Committee Statement: See Committee Comment 1981-8� (Log #CC�).

____________________________________________________________1981-197 Log #145 FAE-RPE Final Action: Accept(8.10.5.2 and 8.10.5.2.1)____________________________________________________________Submitter: Mark Miller, Ultra/AudiopackComment on Proposal No: 1981-�Recommendation: In 8.10.5.�: The test material shall be the reading of one complete list of phonetically balanced words as contained in Table 1 of ANSI S�.� (“phonetically balanced” should replaced with; “Modified Rhyme”. “Table 1” should be replaced with “Table �”. In 8.10.5.�.1: The words shall be spoken singularly in the following carrier sentence: “Would you circle (list word) now?”. (“write” should be replaced with “circle”.)Substantiation: In 1981-�007 Section 8.10: The ANSI S�.� Phonetically Balanced test (write the word test) specified in is not as good of a choice as the ANSI S�.� Modified Rhyme test (circle the word test). The reasons and substantiation are listed below: (1) Reason: The assumption that the Phonetically Balanced test (write the word test) is better at qualifying intelligibility than the Modified Rhyme Test (circle the word test) is false: Substantiation: ANSI S�.� specifically says in Section 8.1 (page 10) that the � test methods called out in ANSI S�.� are equally highly correlated with vocabularies representative of military communications. All � tests listed in ANSI S�.� have demonstrated sensitivity to degraded speech. (�) Reason: The Modified Rhyme Test (circle the word test) is a better match for communications systems: Substantiation: The Appendix of ANSI S�.� specifically states that the Modified Rhyme Test (circle the word test) is better than the Phonetically Balanced test (write the word) at identifying the sources of poor intelligibility of communications systems. (�) Reason: The Phonetically Balanced Test (write the word test) requires a significantly more time to implement: Substantiation: The Appendix of ANSI S�.� also specifically says that the Phonetically Balanced Test requires significantly more man hours to train test subjects (at least 10 hours of training is required for each test subject). They are required to hear a list of 1000 words several times during training. More hours are needed to conduct the test and more hours are needed to score the test. The scoring cannot be easily automated and is more likely to include errors. Conclusion: Because of what is listed above we highly recommend using the Modified Rhyme test specified in ANSI S�.� (Circle the word) instead of the Phonetically Balanced Test specified in ANSI S�.� (Write the word). Note: Supporting material is available for review at NFPA Headquarters.Committee Meeting Action: AcceptCommittee Statement: See Committee Comment 1981-8� (Log #CC�).

____________________________________________________________1981-198 Log #18� FAE-RPE Final Action: Accept in Principle(8.10.5.2 and 8.10.5.6)____________________________________________________________Submitter: Jason L. Allen, IntertekComment on Proposal No: 1981-�Recommendation: 8.10.5.� - Delete current wording “Table 1” and replace with “Six word lists developed according to Table �”. 8.10.5.6 - Delete “write” and replace with “circle”.Substantiation: A Modified Rhyme Test will be more accurate by eliminating spelling errors.Committee Meeting Action: Accept in Principle See Committee Comment 1981-8� (Log #CC�).Committee Statement: See Committee Comment 1981-8� (Log #CC�).

____________________________________________________________1981-199 Log #15� FAE-RPE Final Action: Accept in Principle(8.10.5.2.1)____________________________________________________________Submitter: A. Paul Bull, Fairfax County Fire and Rescue DepartmentComment on Proposal No: 1981-�Recommendation: Change from “write the word” to “circle the word”Substantiation: This testing method was used in the preliminary communication testing done by the TC on communication, committee discussions agree on this change.Committee Meeting Action: Accept in Principle See Committee Comment 1981-8� (Log #CC�).Committee Statement: See Committee Comment 1981-8� (Log #CC�).

____________________________________________________________1981-�00 Log #46 FAE-RPE Final Action: Accept(8.10.5.2.3)____________________________________________________________Submitter: Robert Sell, Draeger Safety, Inc.Comment on Proposal No: 1981-�Recommendation: Revise to read: The talkers shall be trained to talk at 75 dBA - 85 dBA without a SCBA facepiece, measured at the listener’s ear, placing no unusual stress on any word.Substantiation: Allows for a tolerance on the speaker training and the statement would be the same as what is referenced in NFPA 1981, �00� edition.Committee Meeting Action: Accept

____________________________________________________________1981-�01 Log #17� FAE-RPE Final Action: Accept in Principle(8.10.5.2.3)____________________________________________________________Submitter: Bruce A. Hefner, International Safety InstrumentsComment on Proposal No: 1981-�Recommendation: Change from “75 dBA” to “75-85 dBA”.Substantiation: “75-85 dBA” is �00� edition. “75 dBA” wording would lower the speaking volume from an average of 80 dBA to an average of 75 to 76 dBA which would put it too close to the background noise.Committee Meeting Action: Accept in Principle See Committee Comment 1981-8� (Log #CC�).Committee Statement: See Committee Comment 1981-8� (Log #CC�).

____________________________________________________________1981-�0� Log #181 FAE-RPE Final Action: Reject(8.10.5.2.3)____________________________________________________________Submitter: Jason L. Allen, IntertekComment on Proposal No: 1981-�Recommendation: Add range of “70 dBA - 80 dBA” to spoken level.Substantiation: A range is needed when dealing with human subjects speaking to account for voice fluctuations.Committee Meeting Action: RejectCommittee Statement: See Committee Comment 1981-8� (Log #CC�).

____________________________________________________________1981-�0� Log #1�7 FAE-RPE Final Action: Accept(8.10.5.2.4 and 8.10.5.3)____________________________________________________________Submitter: Mark Miller, Ultra/AudiopackComment on Proposal No: 1981-�Recommendation: In 8.10.5.�.4: Training shall include the use of background noise as defined in 8.10.4.11 through 8.10.4.15. In 8.10.5.�: The talkers shall conduct two tests in the chamber having an ambient noise field as specified in 8.10.4.11 through 8.10.4.15 using a different word list for each of the following conditions.Substantiation: 8.10.4.11 only specifies frequency content. 8.10.4.11 through 8.10.4.15 are required to fully define the background noise. (Editorial error).Committee Meeting Action: Accept

1981-6�

Report on Comments F2006 — Copyright, NFPA NFPA 1981____________________________________________________________1981-�04 Log #151 FAE-RPE Final Action: Accept in Principle(8.10.5.2.6)____________________________________________________________Submitter: A. Paul Bull, Fairfax County Fire and Rescue DepartmentComment on Proposal No: 1981-�Recommendation: Change from “write each word” to “circle the word from the list of words.”Substantiation: This testing method was used in the preliminary communication testing done by the TC on communication, committee discussions agree on this change.Committee Meeting Action: Accept in Principle See Committee Comment 1981-8� (Log #CC�).Committee Statement: See Committee Comment 1981-8� (Log #CC�).

____________________________________________________________1981-�05 Log #177 FAE-RPE Final Action: Accept(8.10.5.4)____________________________________________________________Submitter: Jason L. Allen, IntertekComment on Proposal No: 1981-�Recommendation: Delete “recorded” and replace with “monitored”.Substantiation: Its not necessary to record the speech.Committee Meeting Action: Accept

____________________________________________________________1981-�06 Log #47 FAE-RPE Final Action: Accept(8.10.5.6)____________________________________________________________Submitter: Robert Sell, Draeger Safety, Inc.Comment on Proposal No: 1981-1Recommendation: Revise to read: The average score values obtained in 8.10.5.4.� 8.10.5.5.� and 8.10.5.5.4 shall be calculated.Substantiation: The section currently referenced does not exist in the document and the new section appears to be the appropriate text. This was also incorrectly identified in NFPA 1981, �00� edition.Committee Meeting Action: AcceptCommittee Statement: See committee action on Comment 1981-1 (Log #69).

____________________________________________________________1981-�07 Log #1�8 FAE-RPE Final Action: Accept in Principle(8.10.5.6)____________________________________________________________Submitter: Stephen R. Sanders, Safety Equipment Institute (SEI)Comment on Proposal No: 1981-�Recommendation: Revise text to read:

8.10.5.6 The average of the score values obtained in 8.10.5.4.� 8.10.5.5.� and 8.10.5.5.4 shall be calculated.

8.10.5.6.1 Where the average of the score values for the primary system is >85 percent, this average score value shall be used to determine pass/fail as specified in Section 7.10.1. Where the average of the score values for the secondary system is >75 percent, this average score value shall be used to determine pass/fail as specified in Section 7.10.�.

8.10.5.6.5 For T-values =�.1�, the score value shall be considered to be equivalent to a score value of 85 percent for the primary system and 75 percent for the secondary system and shall be used to determine pass/fail as specified in Sections 7.10.1 and 7.10.�, respectively.

8.10.5.6.6 For T-values >�.1�, the score value shall be as calculated in 8.10.5.6, and this calculated score value shall be used to determine pass/fail as specified in Section 7.10.Substantiation: Editorial “clean-up” corrections for 8.10.5.6.Committee Meeting Action: Accept in Principle See Committee Comment 1981-8� (Log #CC�).Committee Statement: See Committee Comment 1981-8� (Log #CC�).

____________________________________________________________1981-�08 Log #174 FAE-RPE Final Action: Accept in Principle(8.10.5.6.1)____________________________________________________________Submitter: Bruce A. Hefner, International Safety InstrumentsComment on Proposal No: 1981-�Recommendation: Change “>85” to “>=85” an “>75” to “>=75”.Substantiation: To conform to 7.10.1 which allows 85 and 7.10.� which allows 75. As stated 8.10.5.6.1 would not allow 85 and 75.Committee Meeting Action: Accept in Principle See Committee Comment 1981-8� (Log #CC�).Committee Statement: See Committee Comment 1981-8� (Log #CC�).

____________________________________________________________1981-�09 Log #150 FAE-RPE Final Action: Accept in Principle(8.10.5.6.4)____________________________________________________________Submitter: A. Paul Bull, Fairfax County Fire and Rescue DepartmentComment on Proposal No: 1981-�Recommendation: Add text: where: µ = 7� percent - should read “µ = 85 percent for primary systems and 75 percent for secondary systems”.Substantiation: This testing method was used in the preliminary communication testing done by the TC on communication, committee discussions agree on this change.Committee Meeting Action: Accept in Principle See Committee Comment 1981-8� (Log #CC�).Committee Statement: See Committee Comment 1981-8� (Log #CC�).

____________________________________________________________1981-�10 Log #184 FAE-RPE Final Action: Accept(8.11.4.2 through 8.11.4.2.15)____________________________________________________________Submitter: Jason L. Allen, IntertekComment on Proposal No: 1981-�Recommendation: Replace 8.11.4.� through 8.11.4.�.15 (ROP text) with the following:

8.11.4.2 Both the calibration mannequin and the heat and flame test mannequin shall have protective coverings.

8.11.4.2.1 The protective coverings shall be a weld blanket made of fireproof silica cloth of a minimum weight of 18 oz/sq yard.

8.11.4.2.2 The protective coverings shall be designed and constructed to provide coverage over the surface of the mannequins.

8.11.4.2.3 Where additional insulation is needed to protect the mannequin electronics, an additional thermal liner underlayer shall be permitted.

8.11.4.2.4 The complete protective covering shall be discarded and shall not be used where the damage to any portion indicates the covering can no longer provide thermal protection for the test mannequin.Substantiation: Silica cloth would create a more repeatable test and bring this standard in line with next edition of NFPA 198�.Committee Meeting Action: Accept

____________________________________________________________1981-�11 Log #185 FAE-RPE Final Action: Accept(8.11.4.6.1)____________________________________________________________Submitter: Jason L. Allen, IntertekComment on Proposal No: 1981-�Recommendation: Add range of flow “�8-76 m/min (1�5-�50 ft/min)” and delete “61 M/min �00 ft/min”.Substantiation: A range is needed when specifying convective flows due to turbulence.Committee Meeting Action: Accept____________________________________________________________1981-�1� Log #�49 FAE-RPE Final Action: Accept in Principle in Part(8.16 through 8.16.72)____________________________________________________________Submitter: Jeffrey L. Landis, Tyco/Scott Health and SafetyComment on Proposal No: 1981-�Recommendation: In entire section, replace the wording “power supply” with “power source”. In 8.16.7.� replace wording “battery power supply”, with “portable power source”.Substantiation: The following definitions for power supply and power source, clearly indicate that batteries, generators, solar panels, etc., portable sources of power, should fall under the definition of power source. Power Source. Point of origin where electrical energy is generated through the conversion of other forms of energy. Power Supply. Electrical component or components that transform or control the electrical energy from a power source. The above definitions were compiled using information from the Electrochemistry Dictionary (http://electrochem/cwru.edu/ed/dict.htm) Revision date: December �1, �005. Hosted by the Ernest B. Yeager Center for Electrochemical Sciences (YCES) and the Chemical Engineering Department, Case Western Reserve University, Cleveland, Ohio. Copyright Notice. Maintained by Zoltan Nagy (nagy@anl.gov) The Center for Electrochemical Science and Engineering and Department of Chemical and Environmental Engineering, Illinois Institute of Technology, Chicago, Illinois.Committee Meeting Action: Accept in Principle in Part 1. Throughout the document except in Section 8.16, change the term “battery” or “power supply” to the term “power sources”.

1981-64

Report on Comments F2006 — Copyright, NFPA NFPA 1981 �. In Section 8.16, the term “variable power supply” remains. �. Reject using the term “portable power source”.Committee Statement: 1. The term is used beyond Section 8.16. Change to “power source” for consistency. �. The term is correct as it is referring to a type of electrical testing equipment. �. The term “power source” embraces all power sources without needing the extra word “portable”.

____________________________________________________________1981-�1� Log #48 FAE-RPE Final Action: Accept(8.16.7.2)____________________________________________________________Submitter: Robert Sell, Draeger Safety, Inc.Comment on Proposal No: 1981-�Recommendation: Revise to read: HUD battery power source voltage greater than or equal to the cease-proper-operation voltage shall constitute pass.Substantiation: This statement would be the same as what is currently identified in NFPA 1981, �00� edition.Committee Meeting Action: Accept

____________________________________________________________1981-�14 Log #1�9 FAE-RPE Final Action: Reject(8.23 and 8.23.1)____________________________________________________________Submitter: Stephen R. Sanders, Safety Equipment Institute (SEI)Comment on Proposal No: 1981-�Recommendation: Revise text to read: 8.23 Interchangeable Cylinder Valve Assembly Flow Rate Test. 8.23.1 Application. This test method shall apply to the SCBA manufacturer’s interchangeable cylinder valve assembly.Substantiation: Editorial “clean-up” corrections for Section 8.��.Committee Meeting Action: RejectCommittee Statement: Section 8.�� was deleted by Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-�15 Log #�04 FAE-RPE Final Action: Accept in Principle(8.23 through 8.25)____________________________________________________________Submitter: Salvatore Cassano, New York City Fire DepartmentComment on Proposal No: 1981-�Recommendation: Eliminate all references to the requirements for interchangeable SCBA breathing air cylinders as well as associated references and testing requirements.Substantiation: The changes recommended by this standard could decrease rather enhance firefighter safety. The requirement for interchangeable cylinders could have a negative effect on product innovation at a cost to firefighter safety. There has not been any evidence presented to document the need for interchangeability. Not all fire departments use the same pressure; therefore interchangeability will only be achieved via a single universal pressure. Forward/backward compatibility will not be assured placing departments in a position of lacking compatibility among existing vendors.Committee Meeting Action: Accept in Principle See Committee Comment 1981-76 (Log #CC1).Committee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-�16 Log #1�0 FAE-RPE Final Action: Reject(8.24)____________________________________________________________Submitter: Stephen R. Sanders, Safety Equipment Institute (SEI)Comment on Proposal No: 1981-�Recommendation: Revise text to read:

8.24.2.1 Samples shall be complete SCBA Each sample to be tested shall be as specified in 4.�.5.

8.24.4.2 Surrogate cylinders and valve assemblies shall meet the specifications of Table 8.�4.4.�.

8.24.3.1 One SCBA sample shall be tested with each surrogate cylinder and valve assembly as specified in Table 8.�4.x 8.�4.4.�.

8.24.5.1 The specimen, fitted with the surrogate cylinder and valve assembly, shall be fixed to the backplate and harness assembly in accordance with the manufacturer’s instruction in the user instructions provided with the SCBA for the end user.

8.24.5.3 The distances coordinates for each of the six directions specified in 8.�4.5.4, the original starting positions, shall be measured and recorded.

8.24.5.4 A force of �00 N (45 lbf) shall be applied to the intersection point specified in 8.�4.4.� 8.�4.4.4, in the six directions shown in Figure 8.�4.5.4. The force shall be applied for a period of 10 seconds, +5/-0 seconds allowing the measurements to be taken.

8.24.5.5 Following the application of force for each direction, the travel distances for each of the six directions shall be measured and recorded.

8.24.5.6 This procedure shall be repeated for each of the surrogate cylinders specified in Table 8.�4.4.�.Substantiation: Editorial “clean-up” corrections and clarifications for Section 8.�4.Committee Meeting Action: RejectCommittee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-�17 Log #65 FAE-RPE Final Action: Reject(8.24.4.1)____________________________________________________________Submitter: Karen Lehtonen, Lion ApparelComment on Proposal No: 1981-�Recommendation: Revise text to read: A test bench or similar text fixture that can firmly fix a fully assembled SCBA to the test bench or fixture that will not allow movement of the SCBA shall be used.Substantiation: There is currently no mandatory language in this paragraph.Committee Meeting Action: RejectCommittee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-�18 Log #10� FAE-RPE Final Action: Reject(Table 8.24.4.2)____________________________________________________________Submitter: Michael T. Rupert, MSAComment on Proposal No: 1981-�Recommendation: Replace the Table with the Figure shown on the following page.Substantiation: The figure accurately represents the worst case combination of features for a cylinder as allowed by Figure 6.5.1.Committee Meeting Action: RejectCommittee Statement: The test method in Section 8.�4 for interchangeable cylinders was deleted by Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-�19 Log #66 FAE-RPE Final Action: Reject(8.24.4.3)____________________________________________________________Submitter: Karen Lehtonen, Lion ApparelComment on Proposal No: 1981-�Recommendation: Revise text to read: Measurements will shall be taken with a calibrated measuring device having a resolution of better than ±0.�5 mm (±0.01 in.).Substantiation: Currently there is no mandatory language in this paragraph.Committee Meeting Action: RejectCommittee Statement: See Committee Comment 1981-76 (Log #CC1).

____________________________________________________________1981-��0 Log #1�1 FAE-RPE Final Action: Reject(8.25)____________________________________________________________Submitter: Stephen R. Sanders, Safety Equipment Institute (SEI)Comment on Proposal No: 1981-�Recommendation: Revise text to read:

8.25.3.1 One SCBA sample shall be tested with each surrogate cylinder and valve assembly as specified in Table 8.�4.4.�

8.25.3.12 The interoperable surrogate cylinder and valve assembly shall be fixed to the backplate harness assembly following the manufacturer’s instruction indicated in the user instructions.

8.25.4 Apparatus.8.25.4.1 Surrogate cylinder and valve assemblies shall meet the

specifications of Table 8.�4.4.�.8.25.4.2 The specimen, fitted with the surrogate cylinder and valve

assembly, shall be fixed to the backplate and harness assembly in accordance with the manufacturer’s instruction in the user instructions provided with the SCBA for the end user.

8.25.4 8.25.5 Procedure.Note: renumber all paragraphs in existing Section 8.�5.4 to 8.�5.5 and

renumber all of existing Sections 8.�5.5 and 8.�5.6, accordingly.8.25.5.7 This procedure shall be repeated for each of the surrogate

cylinders specified in Table 8.�4.4.�.8.25.56.2 The clearance distance for between the valve handwheel and

the SCBA shall be recorded and reported.Substantiation: Editorial “clean-up” corrections and clarifications for Section 8.�5.Committee Meeting Action: RejectCommittee Statement: The test method in Section 8.�5 for cylinder interchangeability was deleted by Committee Comment 1981-76 (Log #CC1).

1981-65

Report on Comments F2006 — Copyright, NFPA NFPA 1981

1981-218 (Log #103) Recommendation

FIGURE 8.24.4.2 Surrogate cylinder and valve specification.

1981-66

Report on Comments F2006 — Copyright, NFPA NFPA 1981____________________________________________________________1981-��1 Log #189 FAE-RPE Final Action: Reject(8.26)____________________________________________________________Submitter: Jeffrey L. Landis, Tyco/Scott Health and SafetyComment on Proposal No: 1981-�Recommendation: Revise as follows: 8.26 Immersion Leakage Tests. 8.26.1 Application. This test method shall apply to each electronic device of the SCBA required to meet Section 6 Design requirements. 8.26.2 Samples. 8.26.2.1 Each sample to be tested shall be as specified in 4.X.X.

8.26.2.2 Samples for conditioning shall be complete SCBA.8.26.3 Specimens. 8.26.3.1 One specimen shall be tested after conditioning within an oven

specified with 8.�6.4 at 177°C + 5°C/-0°C (�50°F + 10°F/-0°F)° for 5 minutes. 80°C ± �°C (176°F± 5°F) above the temperature of the test water for a minimum of 40 minutes ±5 minutes.

8.26.4 Apparatus. 8.26.4.1 The test oven shall have an air flow rate of �8 m/min to 76 m/min (1�5 ft/min to �50 ft/min) at the standard temperature and pressure of �1°C (70°F) at 1 atmosphere measured at the center point of the oven.

8.26.4.2 The test oven shall have minimum dimensions of 915 mm depth 915 mm width 1.�� m height (�6 in. depth �6 in. width 48 in. height) shall be provided.

8.26.4.3 A test thermocouple shall be positioned so that it is level with the horizontal centerline of a mounted sample specimen.

8.26.4.4 The test water container shall be capable of covering the uppermost point of the specimen SCBA with a depth of 1.5 m (4.9 ft.) 1 m (�.� ft) of water.

8.26.4.5 The water temperature shall be 18°C, ±10°C (64°F, ±18°F)8.26.5 Procedure.

8.26.5.1 The SCBA mounted on the test mannequin shall be placed in the test oven that has been preheated to 177°C, +5°/-0°C (�50°F, +10°/-0°F). The SCBA mounted on the test mannequin shall be placed in the test oven that has been preheated to 80°C ± �°C (176°F ± 5) above the temperature of the test water.

8.26.5.2 After the test oven door is closed and the oven temperature recovers to 80°C (176°F), the test exposure time of 15 minutes shall begin.

8.26.5.3 At the completion of the 15-minute exposure, the completion of the 40 minute exposure, the complete SCBA shall be removed from the heat and maintain mounted on the mannequin within an environment of ��°C, ±�°C (7�°F, ±5°F) at 50 percent, ±�5 percent relative humidity for a minimum of � hours. and within 1 minute, shall be removed from the mannequin, and immersed in the test water container for 15 minutes, +5/-0 minutes. After immersion, the specimen shall be removed from the test water container and shall be wiped dry.

8.26.5.4 Deleted8.26.5.5 Specimen shall be subjected to 8.�6.5.1 through 8.�6.5.4 for

six three complete cycles.8.26.5.6 Specimen shall be removed following the sixth third

conditioning cycle, and testing shall begin within �0 seconds of removal from conditioning.

8.26.5.7 The power supply compartment(s) of the specimen shall be opened, and each battery compartment shall be inspected for water leakage to determine pass/fail.

8.26.5.8 The specimen shall be re-immersed in the test water container for an additional 5 minutes. The power supply compartment(s) shall be open, and the battery shall not be installed.

8.26.5.9 After the 5-minute immersion, the specimen shall be removed from the test water container and shall be wiped dry.

8.26.5.10 The electronic compartment(s) of the specimen shall be opened and inspected for water leakage to determine pass/fail.

8.26.5.11 The electronic device shall be tested for proper function to determine pass or fail.Substantiation: Statement of Problem: ● There was no supporting data to substantiate the conditioning temperature in the proposed ROP test. ● The proposed ROP test poses a danger to the test technician because of the extreme high heat. In the event there is water leakage in the enclosure during a previous heat and immersion cycle, the enclosure could become filled with steam and rupture. Substantiation of Comment: ● The current immersion leakage test in NFPA 1982 PASS standard, have been in existence for over 15 years and have been shown to be an effective test method based on actual field use of products certified the standard.

● The proposed test changes increases the test exposure temperature, and the number of test cycles by a factor of �00% showing the intent of the TC to improve the testing requirements by the same factor, based on the current NFPA 198� test). ● The proposed test changes reduce the temperature exposure time by a factor of �00%, in proportion to the increase in exposure temperature (�00%). (based on the current NFPA 198� test).

● The proposed test eliminates the extra procedure of immersing the open battery compartment. This was proposed because all electronic devices need to meet the requirement in ANSI/UL 91�, 8.1.�, which requires the battery compartment be separated from the electronics to prevent battery electrolyte from getting to the components. Since this is being considered in the UL evaluation, the extra procedure step is redundant. Note: Supporting material is available for review at NFPA Headquarters.Committee Meeting Action: RejectCommittee Statement: See committee action on Comment 1981-��4 (Log #106) and 1981-��7 (Log #175).

____________________________________________________________1981-��� Log #166 FAE-RPE Final Action: Accept in Principle(8.26.1)____________________________________________________________Submitter: John Morris, International Safety Instruments, Inc.Comment on Proposal No: 1981-�Recommendation: Add Section 7 Performance Requirements to end of 8.�6.1. “8.�6.1 Application. This test method shall apply to each electronic device of the SCBA required to meet Section 6 Design requirements and Section 7 performance requirements.”Substantiation: Electronic devices required to meet standard should be included. Current wording omits voice amplification.Committee Meeting Action: Accept in Principle See Committee Comment 1981-8� (Log #CC�).Committee Statement: See Committee Comment 1981-8� (Log #CC�).

____________________________________________________________1981-��� Log #1�8 FAE-RPE Final Action: Accept(8.26.2.1)____________________________________________________________Submitter: Mark Miller, Ultra/AudiopackComment on Proposal No: 1981-�Recommendation: Revise text to read: 8.�6.�.1 Each sample to be tested shall be as specified in 4.x.x. (“4.x.x” should be replaced with “Table 4.�.9”).Substantiation: The table number has not been updated (Editorial error).Committee Meeting Action: AcceptCommittee Statement: See committee action on Comment 1981-1 (Log #69).

____________________________________________________________1981-��4 Log #106 FAE-RPE Final Action: Accept(8.26.5.1, 8.26.5.3, and 8.26.5.4)____________________________________________________________Submitter: Michael T. Rupert, MSAComment on Proposal No: 1981-�Recommendation: Revise text to read as follows: 8.�6.5.1 The SCBA mounted on the test mannequin, and tested for a water-tight seal per paragraph 8.1.5.�. It shall then be placed in the test oven that has been preheated to 177°C, +5°/-0°C (�50°F, +10°/-0°F). Delete 8.�6.5.�. 8.�6.5.4 Within � minutes, the specimen, mounted to the mannequin, shall be removed from the mannequin and immersed in the test water container for 15 minutes. After 15 minutes, the specimen shall be removed from the test water container and shall be wiped dry.Substantiation: Sealing the facepiece to a headform during the �50F oven and water immersion testing more accurately represents the field use of the SCBA, as it is worn by a user. The internal components of the facepiece would be protected from heat and water in the worn condition, therefore they should not be exposed when tested. This is the way the previous HUD water resistance test was conducted in Section 8.17.Committee Meeting Action: Accept

1981-67

Report on Comments F2006 — Copyright, NFPA NFPA 1981____________________________________________________________1981-��5 Log #1�9 FAE-RPE Final Action: Reject(8.26.5.2)____________________________________________________________TCC Action: The Technical Correlating Committee REJECTS this comment. The TCC made a TCC Note on the ROP NFPA 1982 to instruct the TC on Electronic Safety Equipment (TC on ESE) to coordinate the testing of electronic components with NFPA 1981 and the TC on Respiratory Protection Equipment (TC on RPE). The TC on ESE is considered the “lead” as their responsibility is for all electronics used in emergency services safety equipment. The TC on ESE did use the same immersion leakage test in NFPA 1982 as used in NFPA 1981 that, in part, challenged the equipment with a heat of 177°C (350°F) for a duration of 15 minutes prior to the immersion of the electronics. The challenge of 177°C (350°F) for 15 minutes was chosen based on the information submitted to the TCs from NIOSH NPPTL investigations into the deaths of fire fighters and failures of the electronics of Personal Alert Safety Systems (PASS) used by those fire fighters that caused the alarm signal of the PASS to either fail or to be reduced in sound dBA output that rendered the alarm signal being able to be heard above the normal background noise. In cooperation with NISOH NPPTL, NIST Building and Fire Research Laboratory conducted tests on PASS to determine if temperature exposure was a cause and NIST reported to NIOSH and to the NFPA TCs that at temperatures of about 150°C (about 300°F) the alarm signals were negatively affected. Following receipt of the report from NIOSH NPPTL along with the confirming test information from NIST, the following was published on NFPA website as well as NIOSH NPPTL’s website, and the websites of certification organizations: PASS alarm signals can fail at high temperatures Exposure to high temperature environments may cause the loudness of PASS alarm signals to be reduced. This reduction in loudness could cause the alarm signal to become indistinguishable from background noise at the incident scene. This problem was brought to the attention of the NFPA Technical Committee on Electronic Safety Equipment by the National Institute for Occupational Safety and Health’s (NIOSH) Fire Fighter Fatality Investigation and Prevention Program. NIOSH reported that during the investigation of four fire fighter fatalities that occurred from 2001 to 2004, the PASS alarms were not heard or were barely audible. The PASS had been certified as compliant to NFPA 1982, Standard on Personal Alert Safety Systems (PASS), 1998 Edition, and involved both stand-alone PASS and SCBA-integrated PASS. Initial laboratory testing of PASS by the National Institute for Standards and Technology’s (NIST) Fire Research Division has shown this sound reduction may begin to occur at temperatures as low as 300° F (150° C) and could affect all PASS. Additional work is required to better characterize the thermal conditions (temperatures and exposure durations) that contribute to alarm signal degradation. While the NFPA Technical Committee on Electronic Safety Equipment has been working to develop appropriate revisions to NFPA 1982 to address this issue, adequate solutions have not yet been presented. The Committee, in cooperation with NIOSH and NIST, will continue to study the issue and will incorporate revisions into NFPA 1982 as solutions are developed and consensus around addressing the issue is achieved. PASS has always been a “last resort call for help” for emergency services personnel who are unable to otherwise notify others that they are in distress. Fire fighters should continue to activate and wear PASS whenever in hazardous areas of any incident, but should also be aware that high temperatures could cause degradation of the alarm signal. Incident command should continue to apply all personnel accountability measures at all incidents to assure the safe entrance and exit of personnel from hazardous areas. Direct supervision of operating companies or teams should provide for the safe operating locations of personnel and ensure that members do not “freelance” on the incident scene. Emergency services organizations and emergency response personnel should report any PASS malfunctions and other problems with PASS functioning directly to both the certification organization whose certification mark appears on the PASS, and to NIOSH–NPPTL. Be sure to give your contact information so they can respond to you. · SEI, the Safety Equipment Institute (certification organization), can be reached by e-mail (info@seinet.org). · NIOSH-NPPTL, the National Institute for Occupational Safety and Health -- National Personal Protection Technical Laboratory, can be reached by e-mail (NPPTL_PASS@cdc.gov). The TCC, acting in accordance with 3.4.3(g) of the RGCPs, is taking the action it deems necessary in accordance with its authority as defined in 3.4.2, and in 4.4.7.1: “…The TCC shall be permitted to choose between alternatives presented by the TCs or develop text, as it deems necessary to achieve correlation, consistence, and the correction of errors and omissions...” and is taking these actions.

The TCC believes the correlation and consistency of performance criteria and testing methods is very important in “standardizing” electronics functioning. While the SCBA issues addressed in 1981-225 and 1981-227 apply to electronics in the SCBA and not to PASS, the issues of the performance in high heat environments of electronics and the power sources for these electronics that are part of the SCBA is common. The TCC believes that the heat exposure of 177°C (350°F) for 15 minutes presents the better challenge to the electronics and their power supplies to overcome the problems currently being experienced. The TCC notes that the reduced temperature and reduced exposure time for the electronics made in 1981-225 and 1981-227 was substantiated by what current technology and materials are capable of achieving now, rather than seeking better performance for increased durability of the electronics that will improve product performance and, in turn, the safety of the emergency responders’ electronics to properly function in hostile environments where they are used.Submitter: Mark Miller, Ultra/AudiopackComment on Proposal No: 1981-�Recommendation: Revise text to read as follows: 8.�6.5.� After the test oven door is closed and the oven temperature recovers to 177°C, the test exposure time of 10 minutes shall begin. The time for the oven to recover to 177°C after the door is closed shall not exceed 60 exceeds.Substantiation: There is no time or temperature tolerance specified. Without these constraints, the time to stabilize could take longer than the entire test rendering the test invalid.Committee Meeting Action: Accept

____________________________________________________________1981-��6 Log #140 FAE-RPE Final Action: Reject(8.26.5.2)____________________________________________________________Submitter: Mark Miller, Ultra/AudiopackComment on Proposal No: 1981-�Recommendation: Revise text to read as follows: 8.�6.5.� After the test oven door is closed and the oven temperature recovers to 177°C, the test exposure time of 15 minutes shall begin. (“177°C” should be replaced with “the temperature specified in Section 8.�6.�” and “of 15 minutes” should be replaced with: “specified in Section 8.�6.�”)Substantiation: The temperature in 8.�5.5 is specified � different times. 8.�6.5.� conflicts with 8.�6.�. Having 8.�6.5.� reference 8.�6.� will avoid this.Committee Meeting Action: RejectCommittee Statement: See committee action on Comment 1981-��5 (Log #1�9).

____________________________________________________________1981-��7 Log #175 FAE-RPE Final Action: Reject(8.26.5.2)____________________________________________________________TCC Action: The Technical Correlating Committee REJECTS this comment. The TCC made a TCC Note on the ROP NFPA 1982 to instruct the TC on Electronic Safety Equipment (TC on ESE) to coordinate the testing of electronic components with NFPA 1981 and the TC on Respiratory Protection Equipment (TC on RPE). The TC on ESE is considered the “lead” as their responsibility is for all electronics used in emergency services safety equipment. The TC on ESE did use the same immersion leakage test in NFPA 1982 as used in NFPA 1981 that, in part, challenged the equipment with a heat of 177°C (350°F) for a duration of 15 minutes prior to the immersion of the electronics. The challenge of 177°C (350°F) for 15 minutes was chosen based on the information submitted to the TCs from NIOSH NPPTL investigations into the deaths of fire fighters and failures of the electronics of Personal Alert Safety Systems (PASS) used by those fire fighters that caused the alarm signal of the PASS to either fail or to be reduced in sound dBA output that rendered the alarm signal being able to be heard above the normal background noise. In cooperation with NISOH NPPTL, NIST Building and Fire Research Laboratory conducted tests on PASS to determine if temperature exposure was a cause and NIST reported to NIOSH and to the NFPA TCs that at temperatures of about 150°C (about 300°F) the alarm signals were negatively affected. Following receipt of the report from NIOSH NPPTL along with the confirming test information from NIST, the following was published on NFPA website as well as NIOSH NPPTL’s website, and the websites of certification organizations: PASS alarm signals can fail at high temperatures Exposure to high temperature environments may cause the loudness of PASS alarm signals to be reduced. This reduction in loudness could cause the alarm signal to become indistinguishable from background noise at the incident scene. This problem was brought to the attention of the NFPA Technical Committee on Electronic Safety Equipment by the National Institute for Occupational Safety and Health’s (NIOSH)

1981-68

Report on Comments F2006 — Copyright, NFPA NFPA 1981Fire Fighter Fatality Investigation and Prevention Program. NIOSH reported that during the investigation of four fire fighter fatalities that occurred from 2001 to 2004, the PASS alarms were not heard or were barely audible. The PASS had been certified as compliant to NFPA 1982, Standard on Personal Alert Safety Systems (PASS), 1998 Edition, and involved both stand-alone PASS and SCBA-integrated PASS. Initial laboratory testing of PASS by the National Institute for Standards and Technology’s (NIST) Fire Research Division has shown this sound reduction may begin to occur at temperatures as low as 300° F (150° C) and could affect all PASS. Additional work is required to better characterize the thermal conditions (temperatures and exposure durations) that contribute to alarm signal degradation. While the NFPA Technical Committee on Electronic Safety Equipment has been working to develop appropriate revisions to NFPA 1982 to address this issue, adequate solutions have not yet been presented. The Committee, in cooperation with NIOSH and NIST, will continue to study the issue and will incorporate revisions into NFPA 1982 as solutions are developed and consensus around addressing the issue is achieved. PASS has always been a “last resort call for help” for emergency services personnel who are unable to otherwise notify others that they are in distress. Fire fighters should continue to activate and wear PASS whenever in hazardous areas of any incident, but should also be aware that high temperatures could cause degradation of the alarm signal. Incident command should continue to apply all personnel accountability measures at all incidents to assure the safe entrance and exit of personnel from hazardous areas. Direct supervision of operating companies or teams should provide for the safe operating locations of personnel and ensure that members do not “freelance” on the incident scene. Emergency services organizations and emergency response personnel should report any PASS malfunctions and other problems with PASS functioning directly to both the certification organization whose certification mark appears on the PASS, and to NIOSH–NPPTL. Be sure to give your contact information so they can respond to you. · SEI, the Safety Equipment Institute (certification organization), can be reached by e-mail (info@seinet.org). · NIOSH-NPPTL, the National Institute for Occupational Safety and Health -- National Personal Protection Technical Laboratory, can be reached by e-mail (NPPTL_PASS@cdc.gov). The TCC, acting in accordance with 3.4.3(g) of the RGCPs, is taking the action it deems necessary in accordance with its authority as defined in 3.4.2, and in 4.4.7.1: “…The TCC shall be permitted to choose between alternatives presented by the TCs or develop text, as it deems necessary to achieve correlation, consistence, and the correction of errors and omissions...” and is taking these actions. The TCC believes the correlation and consistency of performance criteria and testing methods is very important in “standardizing” electronics functioning. While the SCBA issues addressed in 1981-225 and 1981-227 apply to electronics in the SCBA and not to PASS, the issues of the performance in high heat environments of electronics and the power sources for these electronics that are part of the SCBA is common. The TCC believes that the heat exposure of 177°C (350°F) for 15 minutes presents the better challenge to the electronics and their power supplies to overcome the problems currently being experienced. The TCC notes that the reduced temperature and reduced exposure time for the electronics made in 1981-225 and 1981-227 was substantiated by what current technology and materials are capable of achieving now, rather than seeking better performance for increased durability of the electronics that will improve product performance and, in turn, the safety of the emergency responders’ electronics to properly function in hostile environments where they are used.Submitter: Bruce A. Hefner, International Safety InstrumentsComment on Proposal No: 1981-�Recommendation: Change time of oven test from “15 minutes” to “10 minutes” at �50°F.Substantiation: Electrical components with silicate have an upper limit of 150°C (�0�°F) and batteries are not manufactured to operate at continuous high temperatures. Duracell batteries are typically rated for use up to 1�0°F. Note: Supporting material is available for review at NFPA Headquarters.Committee Meeting Action: Accept

____________________________________________________________1981-��8 Log #49 FAE-RPE Final Action: Reject(8.26.5.10 and 8.26.5.11)____________________________________________________________Submitter: Robert Sell, Draeger Safety, Inc.Comment on Proposal No: 1981-�Recommendation: Revise to read as: 8.�6.5.10 The power supply and the power supply cover shall be reinstalled and the electronic device shall be tested for proper function to determine pass or fail.

8.�6.5.11 The electronic compartment(s) of the specimen shall be opened and inspected for water leakage to determine pass/fail.Substantiation: Rearranging the sections provides for a better test sequence and ensures that testing is performed before the electronic compartments are opened so that nothing interferes with the test results if the electronics are damaged by opening the compartment.Committee Meeting Action: RejectCommittee Statement: The test is to be conducted with the cover open to challenge the water tightness of the electronics.

____________________________________________________________1981-��9 Log #67 FAE-RPE Final Action: Accept in Principle(A.1.1.4 (New) )____________________________________________________________Submitter: Karen Lehtonen, Lion ApparelComment on Proposal No: 1981-�Recommendation: Add new text to read: Emergency response organizations are cautioned that accessories are not part of the certified product but could be attached to a certified product by means not engineered, manufactured, or authorized by the certified product manufacturer. Emergency response organizations are cautioned that if an accessory or its means of attachment causes the performance of the certified product to be compromised, the certified product might not be compliant with the standard with which it was originally certified as compliant. Additionally, if an accessory or the accessory’s means of attachment are not designed and manufactured from suitable materials for the hazardous environments of emergency incidents, the failure of the accessory, or means of attachment, could cause injury to the emergency responder. Because the aftermarket for accessories for certified products is so broad, emergency response organizations are advised to contact both the accessory manufacturer and the manufacturer of the certified product and verify that the accessory and its means of attachment are suitable for use in the intended emergency response environment. Emergency response organizations should seek and receive written documentation to validate the following information from the accessory manufacturer: (1) Accessories for a certified product, and the means of attachment, will not degrade the designed protection or performance of the certified product below the requirements of the standard to which it was designed, manufactured, tested and certified. (�) The accessory, when properly attached to the certified product, will not interfere with form, fit, or function of any of the certified product or with the form, fit, and function of any of the certified product’s component parts. Users are also cautioned that the means of attachment for accessories that fail to safely and securely attach the accessory to a certified product can allow the accessory to become inadvertently dislodged from the certified product, possibly posing a risk to emergency response personnel in the vicinity.Substantiation: There is no annex language for 1.1.4, which is identified as having annex text. This text is the boilerplate language for this annex item.Committee Meeting Action: Accept in Principle Revise text to read as follows: Both NIOSH 4� CFR 84 and NFPA 1981 require any accessory attached to an SCBA to be certified under both of these documents.Emergency response organizations are cautioned that accessories are not part of the certified product but could be attached to a certified product by means not engineered, manufactured, or authorized by the certified product manufacturer. Emergency response organizations are cautioned that if an accessory or its means of attachment causes the performance of the certified product to be compromised, the certified product might not be compliant with the standard with which it was originally certified as compliant. Additionally, if an accessory or the accessory’s means of attachment are not designed and manufactured from suitable materials for the hazardous environments of emergency incidents, the failure of the accessory, or means of attachment, could cause injury to the emergency responder. Where users desire an accessory that is not part of the certification of the SCBA, the user must contact the SCBA manufacturer to seek approval for the accessory. Attachment of any accessory that is not approved and part of the certification of the SCBA will void the certification.Committee Statement: The committee agrees with the submitter but modified the text to reflect that accessories are covered by the requirements of NFPA 1981.

1981-69

Report on Comments F2006 — Copyright, NFPA NFPA 1981____________________________________________________________1981-��0 Log #55 FAE-RPE Final Action: Accept in Principle(A.6.4 (New) )____________________________________________________________Submitter: David T. Bernzweig, Columbus, OHComment on Proposal No: 1981-�Recommendation: Add new annex information for this section: The RIC UAC fitting, should not be considered an alternative “fast fill” option for an SCBA cylinder. The RIC UAC is not designed or intended for routine fill operations. Use of the RIC UAC for routine filling would be a violation of safe filling procedures outlined in NFPA 1500. Use of the RIC UAC is considered a relatively dangerous practice that should not be done outside of a real emergency situation (i.e., down firefighter).Substantiation: Despite some manufacturer claims to the contrary RIC UAC is not suitable for routine or non-emergency cylinder filling operations.Committee Meeting Action: Accept in Principle Add new language to read: A.6.4 Use of the RIC UAC is intended for emergency situations. Recharging breathing air cylinders during routine operations and training should follow applicable safe filling practices outlined in, but not limited to, NFPA 1500, NFPA 185�, and manufacturing instructions.Committee Statement: The committee modified the proposed text to focus on the purpose of the RIC UAC and not to confuse other potential emergency uses.

____________________________________________________________1981-��1 Log #50 FAE-RPE Final Action: Accept(A.7.1)____________________________________________________________Submitter: Robert Sell, Draeger Safety, Inc.Comment on Proposal No: 1981-�Recommendation: In the last paragraph, include references to ANSI Z88.10:�001 Respirator Fit Test Methods and �9 CFR 1910.1�4 Respiratory Protection Standard.Substantiation: Update ANSI reference to the new Respirator Fit Test Methods: �001 that has been implemented and to include OSHA 1910.1�4 (Respiratory Protection Standard) since many fire departments are more familiar with this document.Committee Meeting Action: Accept

____________________________________________________________1981-��� Log #51 FAE-RPE Final Action: Accept(C.1.2.1)____________________________________________________________Submitter: Robert Sell, Draeger Safety, Inc.Comment on Proposal No: 1981-�Recommendation: Revise to include reference to: ANSI Z88.10 Respirator Fit Test Methods, �001.Substantiation: Document listed in A.7.1 is included in the appropriate section for Annex C Informational References.Committee Meeting Action: Accept

____________________________________________________________1981-��� Log #68 FAE-RPE Final Action: Accept(C.1.2.2)____________________________________________________________Submitter: Karen Lehtonen, Lion ApparelComment on Proposal No: 1981-�Recommendation: Revise text to read: ISO 9001, Quality management systems – requirements, 1999 �000.Substantiation: Correction to the most current edition of ISO 9001.Committee Meeting Action: Accept

____________________________________________________________1981-��4 Log #5� FAE-RPE Final Action: Accept(C.1.2.3)____________________________________________________________Submitter: Robert Sell, Draeger Safety, Inc.Comment on Proposal No: 1981-�Recommendation: Revise to include reference to: (�9 CFR 1910.1�4 Title �9 Code of Federal Regulations, Part 1910.1�4 Respiratory Protection Standard) 8 January 1998.Substantiation: Document listed in A.7.1 is included in the appropriate section for Annex C Informational References.Committee Meeting Action: Accept

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Company or Affiliation __________________________________________________Email Address

Street Address_________________________________City________________________State______Zip _________________ 1. (a) NFPA Document (include Number and Title)_______________________________________________________________ (b) Proposal or Comment Number____________________ (c) Section/Paragraph _____________________________________

2. Motion to be made. Please check one: (See also 4-6 of the Regulations Governing Committee Projects) (a) Proposal _(1) Accept. (2) Accept an Identifiable Part.* __ (3) Accept as modified by the TC. (4) Accept an Identifiable Part as modified by TC.* (b) Comment (1) Accept. (2) Accept an Identifiable Part.* (3) Accept as modified by the TC. (4) Accept an Identifiable Part as modified by TC.* __ (5) Reject (6) Reject an Identifiable Part.* (c) Return Technical Committee Report for Further Study _____ (1) Return entire Report. (2) Return a portion of a Report in the form of a proposal and related comment(s). _____ (3) Return a portion of a Report in the form of identifiable part(s) of a proposal and related comments (s). (Identify the specific portion of the proposal and the related comments below)* * Clearly identify the Identifiable Part(s) indicated above (use separate sheet if required). ______________________________________________________________________________________________________________________________________________________________________________________________________________________

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3. I am entitled to make this motion in accordance with 4.6.8 of the Regulations Governing Committee Projects, as follows: (check (a), (b), or (c). (a)____ This motion may be made by the original submitter or their designated representative, and I am the (if you check (a) indicate

one of the following):

___I am the Original submitter, or

___I am the submitter’s designated representative (attach written authorization signed by the original submitter), or

___ I am an Organizational Member delegate permitted to represent the submitter on behalf of the Organization Member in accordance with 4-6.5 (c). (b)____This motion may be made by a Technical Committee Member and I am a Member of the responsible Technical Committee.

(c)____This motion may be made by anyone.

(Form continued on next page)

NITMAM form (continued) 4. Comments or Clarification (optional): This NITMAM will be reviewed by a Motions Committee. In addition to determining whether your Amending Motion is proper, the Committee may take other actions as described in 2.3 of the Technical Meeting Convention Rules as follows:

Restating and Grouping of Motions. Upon request or on its own initiative, and in consultation with the mover(s), the Motions Committee may: (a) restate an Amending Motion to facilitate the making of a proper motion or to clarify the intent of the mover; and (b) group Amending Motions that are dependent on one another into a single Amending Motion. Dependent motions are motions that the mover(s) wish to be considered by the assembly and voted on as single up or down package. In addition to the foregoing, the Motions Committee may take such other actions or make such other recommendations as will facilitate the fair and efficient consideration of amending.

The NFPA Staff may contact you to clarify your motion or to consult on the permitted actions in 2.3. If you have any comments, suggestions, or requests of the Motions Committee as it reviews your NITMAM and considers actions permitted in 2.3, please provide them below. (Use additional sheet if necessary): __________________________________________________________________________________________________________________________

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Name (please print):_____________________________________________________________________

Signature (Required)_____________________________________________________________________ (Note: This NITMAM will be reviewed, and if proper, your Amending Motion will be certified in accordance with the Technical Meeting Convention Rules and posted on the NFPA website by November 17, 2006. Documents that have Certified Amending Motions will be considered at the June 2007 Annual Meeting Technical Committee Report. In order to have your Certified Amending Motion considered at that meeting, you must appear, sign in, and make the motion as prescribed in the Convention Rules).

PLEASE USE A SEPARATE NITMAM FORM FOR EACH AMENDING MOTION YOU WISH TO MAKE,

Mail to: Secretary, Standards Council, National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169-7471 NFPA Fax: (617) 770-3500

Sequence of Events Leading to Issuance of an NFPA Committee Document

Step 1 Call for Proposals

▼ Proposed new Document or new edition of an existing Document is entered into one of two yearly revision cycles, and a Call for Proposals is published.

Step 2 Report on Proposals (ROP)

▼ Committee meets to act on Proposals, to develop its own Proposals, and to prepare its Report.

▼ Committee votes by written ballot on Proposals. If two-thirds approve, Report goes forward. Lacking two-thirds approval, Report returns to Committee.

▼ Report on Proposals (ROP) is published for public review and comment.

Step 3 Report on Comments (ROC)

▼ Committee meets to act on Public Comments to develop its own Comments, and to prepare its report.

▼ Committee votes by written ballot on Comments. If two-thirds approve, Reports goes forward. Lacking two-thirds approval, Report returns to Committee.

▼ Report on Comments (ROC) is published for public review.

Step 4 Technical Report Session

▼ “Notices of intent to make a motion” are filed, are reviewed, and valid motions are certified for presentation at the Technical Report Session. (“Consent Documents” that have no certified motions bypass the Technical Report Session and proceed to the Standards Council for issuance.)

▼ NFPA membership meets each June at the Annual Meeting Technical Report Session and acts on Technical Committee Reports (ROP and ROC) for Documents with “certified amending motions.”

▼ Committee(s) vote on any amendments to Report approved at NFPA Annual Membership Meeting.

Step 5 Standards Council Issuance

▼ Notification of intent to file an appeal to the Standards Council on Association action must be filed within 20 days of the NFPA Annual Membership Meeting.

▼ Standards Council decides, based on all evidence, whether or not to issue Document or to take other action, including hearing any appeals.

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The Technical Report Session of the NFPA Annual Meeting

The process of public input and review does not end with the publication of the ROP and ROC. Following the completion of the Proposal and Comment periods, there is yet a further opportunity for debate and discussion through the Technical Report Sessions that take place at the NFPA Annual Meeting.

The Technical Report Session provides an opportunity for the final Technical Committee Report (i.e., the ROP and ROC) on each proposed new or revised code or standard to be presented to the NFPA membership for the debate and consideration of motions to amend the Report. The specific rules for the types of motions that can be made and who can make them are set forth in NFPA’s rules which should always be consulted by those wishing to bring an issue before the membership at a Technical Report Session. The following presents some of the main features of how a Report is handled.

What Amending Motions are Allowed. The Technical Committee Reports contain many Proposals and Comments that the Technical Committee has rejected or revised in whole or in part. Actions of the Technical Committee published in the ROP may also eventually be rejected or revised by the Technical Committee during the development of its ROC. The motions allowed by NFPA rules provide the opportunity to propose amendments to the text of a proposed code or standard based on these published Proposals, Comments and Committee actions. Thus, the list of allowable motions include motions to accept Proposals and Comments in whole or in part as submitted or as modified by a Technical Committee action. Motions are also available to reject an accepted Comment in whole or part. In addition, Motions can be made to return an entire Technical Committee Report or a portion of the Report to the Technical Committee for further study.

The NFPA Annual Meeting, also known as the World SafetyConference and Exposition®, takes place in June of each year. A second Fall membership meeting was discontinued in 2004, so the NFPA Technical Report Session now runs once each yearat the Annual Meeting in June.

Who Can Make Amending Motions. Those authorized to make these motions is also regulated by NFPA rules. In many cases, the maker of the motion is limited by NFPA rules to the original submitter of the Proposal or Comment or his or her duly authorized representative. In other cases, such as a Motion to Reject an accepted Comment, or to Return a Technical Committee Report or a portion of a Technical Committee Report for Further Study, anyone can make these motions. For a complete explanation, NFPA rules should be consulted.

The filing of a Notice of Intent to Make a Motion. Before making an allowable motion at a Technical Report Session, the intended maker of the motion must file, in advance of the session, and within the published deadline, a Notice of Intent to Make a Motion. A Motions Committee appointed by the Standards Council then reviews all notices and certifies all amending motions that are proper. The Motions Committee can also, in consultation with the makers of the motions, clarify the intent of the motions and, in certain circumstances, combine motions that are dependent on each other together so that they can be made in one single motion. A Motions Committee report is then made available in advance of the meeting listing all certified motions. Only these Certified Amending Motions, together with certain allowable Follow-Up Motions (that is, motions that have become necessary as a result of previous successful amending motions) will be allowed at the Technical Report Session.

Consent Documents. Often there are codes and standards up for consideration by the membership that will be non-controversial and no proper Notices of Intent to Make a Motion will be filed. These “Consent Documents” will bypass the Technical Report Session and head straight to the Standards Council for issuance. The remaining Documents are then forwarded to the Technical Report Session for consideration of the NFPA membership.

Important Note: The filing of a Notice of Intent to Make a Motion is a new requirement that takes effect beginning with those Documents scheduled for the Fall 2005 revision cycle that reports to the June 2006 Annual Meeting Technical Report Session. The filing of a Notice of Intent to Make a Motion will not, therefore, be required in order to make a motion at the June 2005 Annual Meeting Technical Report Session. For updates on the transition to the new Notice requirement and related new rules effective for the Fall 2005 revision cycle and the June 2006 Annual Meeting, check the NFPA website.

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Action on Motions at the Technical Report Session. In order to actually make a Certified Amending Motion at the Technical Report Session, the maker of the motion must sign in at least an hour before the session begins. In this way a final list of motions can be set in advance of the session. At the session, each proposed Document up for consideration is presented by a motion to adopt the Technical Committee Report on the Document. Following each such motion, the presiding officer in charge of the session opens the floor to motions on the Document from the final list of Certified Amending Motions followed by any permissible Follow-Up Motions. Debate and voting on each motion proceeds in accordance with NFPA rules. NFPA membership is not required in order to make or speak to a motion, but voting is limited to NFPA members who have joined at least 180 days prior to the session and have registered for the meeting. At the close of debate on each motion, voting takes place, and the motion requires a majority vote to carry. In order to amend a Technical Committee Report, successful amending motions must be confirmed by the responsible Technical Committee, which conducts a written ballot on all successful amending motions following the meeting and prior to the Document being forwarded to the Standards Council for issuance.

Standards Council Issuance

One of the primary responsibilities of the NFPA Standards Council, as the overseer of the NFPA codes and standards development process, is to act as the official issuer of all NFPA codes and standards. When it convenes to issue NFPA documents it also hears any appeals related to the Document. Appeals are an important part of assuring that all NFPA rules have been followed and that due process and fairness have been upheld throughout the codes and standards development process. The Council considers appeals both in writing and through the conduct of hearings at which all interested parties can participate. It decides appeals based on the entire record of the process as well as all submissions on the appeal. After deciding all appeals related to a Document before it, the Council, if appropriate, proceeds to issue the Document as an official NFPA code or standard. Subject only to limited review by the NFPA Board of Directors, the Decision of the Standards Council is final, and the new NFPA code or standard becomes effective twenty days after Standards Council issuance. The illustration on page 9 provides an overview of the entire process, which takes approximately two full years to complete.

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