NFPA NOTIFICATION TO 179 AUTHORS of COMMENTS IN SUPPORT OF TIA 1594 SUBMITTED BY IAFF GENERAL PRESIDENT EDWARD KELLY.
8.13.2021 — FAILED BALLOT
8.24.2021 NFPA HEARING NFPA 1971 STANDARDS COUNCIL TO VOTE ON TIA 1594 AFTER REVIEWING COMMENTS.
BACKGROUND… 2006 NFPA Revision. The ‘xenon light test’ was put into place after the reported failures of the Breathtex Moisture Barriers as was reported by the IAFF in 1999 under then General President Alfred K. Whitehead:
During the revision of the NFPA 1971 Standards the discussion for the xenon light test would take place and is entered here in the 2006 Report of Proposal (ROP)
https://www.nfpa.org/assets/files/AboutTheCodes/1971/1971-A2006-ROP.pdf
PAGE 3: Jeffrey Stull — NFPA expert and chemist reports on record, stating:
Proposal 1971–39 Log #103: I would like to go on record as finding the “Light Degradation Test” as fallacious. While the intent of the test is worthy, the task group and the committee have failed in demonstrating that the mode of moisture barrier failure on which the test is based is truly the cause of the Breathetex degradation problem. No evidence has been ever been provided that UV degradation alone (even along with the laundering and heat conditioning) adequately explains the phenomena observed in the field. The fact that the chosen conditions would render most outer shell materials to a completely unusable state, remembering that it would be the outer shell that is attenuating the vast majority of UV light exposure, is proof positive that the selected test conditions fail to appropriately mimic the conditions of Breathetex failure. I understand that the task group expended a great effort in developing the proposed requirements, but the commitment of these resources in of itself does not constitute a valid reason for adding this requirement. Consider that if Breathetex degradation had been instead the result of a product defect, either in the film or manufacturing process or both, that was limited to only a portion of the material placed in the marketplace, then the proposed test would have no value whatsoever. I believe the committee should reconsider the test on the basis of its merits only as compared the original direction of the task group to prevent “Breathetex-like failures.”
page 4, Chemist Jeffrey Stull on record:
Proposal 1971–124 Log #118: The conditioning requirement does not make sense. No where in the conditioning procedure is the amount of moisture specified. Rather, the amount of water that is absorbed by the respective thermal barrier material is dependent on the material itself and the conditions of the blotting paper and laboratory wringer. No substantiation has been provided for the basis of the 30% weight by mass requirement for Aralite as a justifiable moisture condition. I note that this requirement was apparently written within the meeting without full committee review (at the meeting
and again here page 4:
Proposal 1971–8 Log #106, Proposal 1971–9 Log #109, and Proposal 1971–10 Log #108: While I understand the committee’s position to move the decision on definitions to the TCC, I firmly believe that the current definitions for the moisture barrier (Log #106), outer shell (Log #109), and thermal barrier (Log #108) are clearly out of date and are inaccurate. These definitions have remained unchanged since earlier editions and have failed to capture the increased multifunctional performance aspects of these layers as addressed in the addition of new requirements implemented in the past couple of revisions. I further feel that the committee is negligent is specifically addressing facings, which often can be an entirely different material than the moisture barrier and that should be evaluated for the same properties as the moisture barrier
page 8:
1971–8 Log #106 FAE-SPF Final Action: Reject
Submitter: Jeffrey O. Stull, International Personnel Protection, Inc. Recommendation: Revise text as follows: 1–3.77 Moisture Barrier. The portion of the protective ensemble element composite, including facings in those areas of garments where employed, designed to prevent the transfer of liquids that may include but not be limited to, water, hot water, certain hazardous materials, and blood borne pathogens. The moisture barrier also attenuates the passage of steam and contributes to the thermal insulation provided by the composite. 1–3.XX Facing. A material used in the construction of garments that is intended to provide the functionality of a moisture barrier in the areas of the garment where used. Substantiation: Facing materials are used in firefighter protective clothing to provided continuous moisture protection to the wearer (see current paragraph 4–1.5). Even though used as part of the overall moisture protection of the wearer, facings are not tested to the same requirements of the moisture barrier in the current edition of NFPA 1971
. Committee Meeting Action: Reject Committee Statement: The Technical Correlating Committee has directed the Technical Committees to use TCC project definitions and to avoid including any information beyond the basic definition of the specific term. In addition, the TC did not feel that the proposed new definition for “facing” was appropriate. The term “facing” can be used in many different ways in garment construction. Further, the TC believes the requirements related to moisture barriers the submitter was attempting to address in the definition of facing are already covered by the standard in existing paragraph 4–1.4. Should additional performance requirements be desired, they should be placed in the performance chapter and not in a definition.
1971–9 Log #109 FAE-SPF Final Action: Reject (1.3.79) Submitter: Jeffrey O. Stull, International Personnel Protection, Inc. Recommendation: Revise to read: 1–3.79 Outer Shell. The outermost layer of the composite with the exception of trim, hardware, reinforced material, and wristlet material, that is intended to provided the principal physical protection for the composite and contribute the composite’s resistance to flame resistance, heat resistance, and thermal insulation. Substantiation: The current definition does not recognize the functional performance of outer shell and its role in overall clothing composite. Committee Meeting Action: Reject Committee Statement: The Technical Correlating Committee has directed the Technical Committees to use TCC project definitions and to avoid including any information beyond the basic definition of the specific term in the definition. ______________________________________________________
1971–10 Log #108 FAE-SPF Final Action: Reject (1.3.124) Submitter: Jeffrey O. Stull, International Personnel Protection, Inc. Recommendation: Revise to read: 1–3.124 Thermal barrier. The portion of protective ensemble element composites that is designed to provide the principal portion of thermal protection. Substantiation: The current definition does not recognize that other layers of the composite also provide thermal protection, namely, the outer shell and moisture barrier layers. Committee Meeting Action: Reject Committee Statement: Technical Correlating Committee has directed the Technical Committees to use TCC project definitions and to avoid including any information beyond the basic definition of the specific term in the definition. In addition, this definition has been revised and may address the submitter’s concern.
FROM PAGE 18 :
1971–39 Log #103 FAE-SPF Final Action: Accept in Principle (Chapter 5 and 6) Submitter: Elizabeth P. Easter, Textile Testing Lab Recommendation: Specimens of the Moisture Barrier layer of turnout gear shall be tested for resistance to degradation light by exposure to a Xenon light source for 60 hours using a modification of ASTM G155 Standard Practice for Operating Xenon Arc Light Apparatus. The conditions of the test should include an inner and outer filter of Borosilicate ”S”, irradiance of 340 nm wavelength at 50% RH and 63 o C/43 o C black panel temperature. The light exposure should be a continuous exposure of light for a maximum of 60 hours. After exposure the moisture barrier specimen shall be tested for resistance to liquid penetration as specified in Section ___, Liquid Penetration Resistance Test. Substantiation: The recommendation of 60 hours exposure is based on extensive research on the degradation of moisture barriers to light exposure. Our findings showed that Breathetex moisture barriers failed after exposure to 40–60 hours of Xenon light exposure. In my opinion, anything less that 60 hours of exposure would enable materials to enter the market that may deteriorate before the 3–5 year estimated service life of turnout gear. I recommend that testing be limited to only the moisture barrier layer because the materials used in this layer have demonstrated failure due to light exposure. Committee Meeting Action: Accept in Principle
PAGE 20
method.1971–48 Log #48 FAE-SPF Final Action: Reject (5.1.14 and 6.27) Submitter: Jeffrey O. Stull, International Personnel Protection, Inc. Recommendation: Delete performance requirement and test Substantiation: The water penetration test is more of a coating or laminate strength test than it is a determination of barrier performance. Both the liquid penetration resistance test (6–28) and the viral penetration resistance test (6–29) serve to adequately address the barrier performance and durability of the moisture barrier. Committee Meeting Action: Reject Committee Statement: The Committee believes that if properly applied this test can discriminate between materials and should remain in the standard.
2006 voting members and alternates:
August 4, 2021 — 179 COMMENTS SUBMITTED IN SUPPORT OF TIA 1594:
August 13, 2021 — TIA 1594 and FINAL BALLOT OF Vote of NFPA 1971 Committee Members :
This would NOT be the first rejection by the NFPA for a TIA calling for the removal of PFAS in PPE.
FROM June? 2018. Submitted by Diane Cotter with support from IAFF, Attorney Robert Bilott , renowned members of the science community and advocates. This TIA was not accepted. I would receive a call in 2018 from two firefighters on behalf of NFPA telling me it did not meet the NFPA criteria:
Diane Cotter 8.14.2021
#GreatestDeceptionEver