Diane Cotter
10 min readFeb 3



PUBLIC COMMENT SUBMISSION by Diane Cotter for: First draft of NFPA 1970 — Re: Proposed Changes to Firefighter PPE Standard Open for Review and Public Comment through January 4, 2023.

Update 11.21.2023. Prompted by the trolling of Jim Reidy on my LinkedIn profile this week and last week, I discovered the 2005 unanimous decision against him by the San Antonio Ethics Review Board regarding gifts from vendors.

“Tell me somethings not wrong here…” Earl Tennant.

January 3, 2023 ~ Diane Cotter’s comments will be italics.

One of the proposed changes within the draft includes the elimination of the light degradation resistance test on the moisture barrier layer of jackets. It will be replaced by a multi-environmental conditioning procedure (9.1.22) that will be applied to composite test samples before certain tests.


NFPA does not create or dictate the provisions within our codes and standards. NFPA is the neutral facilitator of the standards development process; each standard is developed by balanced voluntary technical committees. It is an open and transparent process in which anyone (except NFPA staff) can review and provide input and comment. I strongly encourage everyone who has opinions, perspectives, and insights on these proposed changes to make sure their voices are heard by the committee. Comments will be accepted through January 4, 2023.

Anyone who believes the first draft of the standard should be changed to address these and other topics is strongly encouraged to submit proposed changes (public comment) to the next edition of the standard. You do not have to be an NFPA member or on an NFPA Technical Committee to provide comment and propose additional changes. Anyone (except NFPA staff) can propose a change to the standard by suggesting specific wording and providing a technical rationale through our online submission system, which is accessible at nfpa.org/1970next.

The deadline for Public Comment is January 4, 2023.

I wish to publicly comment on the NFPA INSTITUTIONAL STRUCTURE as follows and have added my input to ‘NEW ADDITION’ in the GENERAL structure for NFPA 1970. Below is a portion of the public comment I have submitted.

Since 2017 my involvement in the workings of the NFPA has been of observer, activist, and member of a particular task group for Structural PPE and restricted chemicals. I have seen the absolute enormous amount of work and effort from volunteers who have made it their passion to watch over the safety of firefighters for righteous reasons — who serve as volunteers for NFPA PPE and AFFF committees. Now having been immersed in thousands of pages of NFPA documents, serving on Task Groups, and providing input, I’m in great admiration of the ability of leaders like Jeff Stull and Marni Schmidt to organize and teach novices like myself how to navigate the NFPA.

I have also witnessed contemptuous deeds committed by leaders in industry ~ beginning nine days after the publication of “The Real Cancer in Your Gear’

Nine days after the Station Pride article this email would be circulated:

It would be the beginning of a seven-year-saga led by a firewife, and joined by firefighters, scientists, medical professionals, industry, fire institutions, attorneys, activists, fire service leaders, media, and the President of the United States.

Why did it take so long?

In 2017, after the Station Pride article, I was in contact with Chris Dubay who I spoke with at length. Chris provided the outline of the NFPA and the parameters it worked within. As the wife of a firefighter with cancer I was new to the behemoth NFPA organization and appreciated the one-on-one with Chris. After my initial conversation with Chris regarding my article with Jon Marr, a shocking article by Kyle Bagenstose would appear and publish a shocking note written by a member of the NFPA AFFF Committee on Foam. It would be published in The Intelligencer.

Chris would tell me there is no ‘mechanism in place and that if there is a subject of concern it could be addressed in a task group’. Chris would go on to advise there is a ‘honesty system’ whereby manufactures, not the NFPA, would advise if their products were harmful or not. Chris would stress the NFPA is a ‘neutral organization. I believed it. At first.

My opinion is far from that now. I believe the NFPA is NOT a neutral organization. I believe the NFPA uses the term ‘we are a neutral organization’ as a shield, in the belief that because they ‘declare’ themselves neutral, the public will believe it. In my years of research in both PPE and AFFF I see the NFPA has failed miserably at its own mission as it relates to public safety in the aspect of ‘forever chemicals’.

My public comment is now directed at the structure of the NFPA directly, and to advise those in power in Congress, the IAFF, every citizen with PFAS in their blood, and every environmentally contaminated community to demand Congressional Hearings into this organization specifically relative to the voting members in this institution who have intentionally acted to withhold data, science, act with malice, lie by omission, hide in plain sight as not only voting members of firefighting equipment standards for PPE and AFFF, but to act as chairperson of these same committees.

The NFPA structure works on a failed ‘honesty system’. The NFPA structure works without declaration of ‘conflicts of interest’, accepts non-peer reviewed science, has set no controls to disqualify, remove or penalize bad actors. The NFPA acts by not acting to remove corporate interests and literally places the giants of ‘forever chemicals’ directly in the drivers seat of a ‘highly selective’ NFPA board on research.

NFPA: 125 Years of Protecting People and Property (2021)

The National Fire Protection Association® (NFPA®) is a global self-funded nonprofit organization devoted to eliminating death, injury, property, and economic loss due to fire, electrical, and related hazards. The association began its work to solve the fire problem in a young, industrialized nation in 1896 and has since become a global force known for advancing safety worldwide. NFPA delivers information and knowledge through more than 325 consensus codes and standards, research, training, education, outreach, and advocacy; and by partnering with others who share an interest in furthering the NFPA mission.

My comments are relative to the firefighting community although the NFPA covers standards for a multitude of labors

1970 — Chemical Concentrates Corporation — letter to NFPA on ‘3M Light Water’. The effects were highly derogatory to marine life. It is not clear what — if any- actions NFPA took. They did not act to protect the environment or the fire service members. The only place environmental information was kept for years is the ‘annex’ which is not required reading for NFPA material.

My comment is directed at the NFPA 1970 pubic comment so I will focus on industry voting members within Firefighter Structural PPE going forward.

Lion Gear has orchestrated an effort filled with indignation to a stunned fire service and worked in earnest to downplay the health effects of PFAS to firefighters and to direct harm to this activist and firewife. Here, in 2019 we learned of the ‘volleyballs and tennis balls’ concept of nothing-to-worry about regarding PFAS, and in particular short chain PFAS being too large to pass through the skin of a firefighter.

In 2017, when Attorney Robert Bilott first called for studies for firefighters regarding their turnout gear, Lion Gear would call the claims fear mongering:

“A battle of studies and statistics is being waged between a manufacturer of turnout gear for firefighters and a lawyer calling for such gear to be tested for potentially cancer-causing elements.”

Stephen A. Schwartz, president of Dayton-based Lion Group Inc., said “false statements” about the coats, pants and other protective gear “have the potential to put at risk the health and safety of firefighters … by creating fear and mistrust” in the equipment.

However, that was nothing compared to the stand. SCHAITBERGER ‘s IAFF would take in 2017, 2018, 2019, 2020, and only change with the leadership of newly elected President Ed Kelly, who took this issue on as job one. Who, in his first months as President would come out with actions that would show us the IAFF has a new sheriff and that the IAFF would no longer be a doormat for industry as was the norm for the Schaitberger administration.

While DuPont was sponsoring our firefighter cancer summits and telling us there was nothing wrong with PFOA, they had in their possession the studies that clearly showed PFOA would permeate all glove material eventually (see page 174 of Robert Bilott’s book; EXPOSURE ) DuPont was also sitting as a voting member of NFPA’s Structural PPE committees and remained silent on all fronts of this issue, even while being advised that they were asked by the European Chemical Agency to remove PFOA and precursors from turnout gear. The response from industry was to petition ECHA to ‘derogate’ PPE from all ECHA regulations. Thankfully that did not happen.

In 2013 a University of Kentucky thesis was conducted on the weathered effects of turnout gear, and, of what in particular was found for chemicals gathered from the gear. The study was based off of the two previous studies from Univ of Ky students under the tuteldge of Dr. Easter. In this thesis weathered gear is sent to Haskell Labs, as in DuPont Haskell Labs. There was no test for PFAS. There would never be a test for PFAS in the gear until a most unusual group would organize.

This memo is also to serve notice to the NFPA that during his duties as Vice President of Corporate Responsibility of Lion Gear, and while he served on Senator Lisa Murkowski’s Federal Firefighter Caucus, John Granby did seek the collaboration of a well known fire service leader to attend a June 2020 meeting with him in the headquarters of the IAFF in Washington, DC. The intent of the meeting was malicious — “to mess with Diane Cotter”. The fire service leader declined. While I did advise Senator Murkowski, twice, nothing has come of it.

The fire service leader was Chief Bobby Halton. He spoke to me of this twice and asked me to watch my back, he was very concerned for me. During his July 2022 podcast with Frank Ricci and Pj Norwood while speaking to ‘BURNED’ documentary filmmaker Elijah Yetter-Bowman and Dr. Graham Peaslee, Chief Halton did allude to his concerns:

The voting members of NFPA mentioned above did not adhere to the NFPA Guide for Conduct, and there appears to be no consequence. Not in the aspect of ‘scientifically sound ’ or malicious acts.

© To promote the development of codes and standards that are scientifically and technically sound, that promote creativity and innovation in the development of new methods and technologies, and that set reasonable standards intended to minimize the possibility and effects of fire and related hazards


The NFPA disclaims liability for any personal injury, property or other damages of any nature whatsoever, whether special, indirect, consequential or compensatory, directly or indirectly resulting from the publication, use of, or reliance on NFPA Standards. The NFPA also makes no guaranty or warranty as to the accuracy or completeness of any information published herein.

It is my hope this comment brings forth an immediate Congressional and Department of Justice investigation into lack of mechanisms allowing decades of conflicts-of-interest impacting the health of firefighters and the environment within the NFPA itself.

Diane Cotter

37 Delton Drive

Rindge, NH 03461

I’m always happy to share my research and resources during my deep dives. Yet because I possess no credentials my research has been appropriated by some claiming to ‘lead a national effort to remove PFAS from turnout gear’ - also from a trusted journalist.

Don’t be that person. Research of this type doesn’t come up with a google search.



Diane Cotter

A very private individual who fell into a very public rabbit hole of epic proportions. I call it the #greatestdeceptionever - really, EVER.