New and Improved Ensembles

Clearer NFPA standards will make it easier for first responders to select their ensembles. Grant money increasingly acknowledges the same standards.

Editor's note: End users' confusion about multiple classes of protective apparel will ease as they become familiar with new editions of NFPA standards for responders' protective apparel, says Jeffrey O. Stull, president of International Personnel Protection Inc. of Austin, Texas. He discussed the new standards, linkage between respirator and clothing testing, what's driving responders' and industrial workers' apparel purchases, and other issues in a Feb. 16, 2006, conversation with Occupational Health & Safety's editor. Excerpts from the conversation follow:

Three important NFPA standards--1991, Standard on Vapor-Protective Ensembles for Hazardous Materials Emergencies; 1992, Standard on Liquid Splash-Protective Ensembles and Clothing for Hazardous Materials Emergencies; and 1994, Standard on Protective Ensembles for Chemical/Biological Terrorism Incidents--were updated recently. What do hazmat team leaders and emergency response personnel need to know about the new editions?

Jeffrey Stull: Actually, the new editions of NFPA 1991 and 1992 did go into effect early last year, in February 2005. The most substantial difference in NFPA 1991 addressed encapsulating suits, or what are called vapor-protective ensembles. This change was to include a requirement for mandatorily protecting against chemical warfare agents.

Encapsulating suits covered by this standard now have to protect against both conventional industrial chemicals plus chemical warfare agents. In the past 2000 edition, the chemical warfare agent part of the requirements had been an option. This change was actually part of an overall strategy by the NFPA Technical Committee on Hazardous Materials Protective Clothing and Equipment. This is because in NFPA 1994, which is a standard that's broader-based--for first responders in general, not just hazmat teams--there used to be something called a Class 1, as there is in the current 2001 edition. Class 1 was an encapsulating suit with a very high-end performance. However, the committee felt that for the general population of first responders, which would include not just hazmat people, but firefighters and law enforcement and emergency medical technicians, the high end for first responder personal protective equipment didn't need to be Class 1; that Class 1 was really a specialized product that would be relegated to specialized groups like hazardous materials response teams.

So that was the rationale for taking it out of 1994?

Yes. And also, as you well know, these encapsulating suits are the most encumbering, the most stressful, the most difficult to put on and use, compared to all the other kinds of clothing. The intent of the NFPA technical committee was to set an upper-end requirement for first responders that would provide sufficient protection while permit the types of functions expected of first responders during a WMD incident.

Tell me about 1994's timetable. Is the new edition still being worked on?

Work on the standard has been completed, but there has been a delay. The NFPA has a process where if someone wants to appeal a standard, they can put in that appeal . . . that's what happened. One industry representative was not satisfied with the way that their comments were handled and has asked for the NFPA to reconsider those comments. The consequence has been to delay until sometime this summer. The new edition of 1994 is now expected to come out in late summer 2006.

There will be some big changes in 1994 as part of the new edition. First of all, there will still be three classes, but the committee removed Class 1 when it became part of NFPA 1991. There are Class 2 and Class 3, but what the committee did was to make the distinctions between the classes simpler, since it was difficult to understand when to apply each class. The committee decided that Class 2 is the kind of ensemble a first responder would wear when an SCBA was required. Class 3 is the type of clothing that would be worn when an air-purifying respirator or a powered air-purifying respirator was permitted.

Okay. That's a lot clearer and simpler, I agree.

The new system is a lot clearer. Essentially, when you have an IDLH condition requiring self-contained breathing apparatus, you wear Class 2. When you have less than an IDLH that permits an air-purifying respirator or a PAPR, then you can wear Class 3. This represents a much, much cleaner distinction between Class 2 and 3 than existed before.

What's Class 4?

Class 4 is for biological and radiological particulates only. That really ensued, I think, because the committee realized after the anthrax issue that a whole range of clothing was being worn, from nothing to encapsulating suits. . . . Whether it be anthrax or even if it was the residue of a dirty bomb and was just a particulate issue, we thought there should be a particulates-only classification.

For Class 3 and Class 4 ensembles, the committee established a breathability requirement. The garments are more comfortable to wear for longer wearing periods. This approach was consistent with the recognition that if a first responder is wearing an APR, then typically the responder will have a longer service mission. So there's a breathability requirement in Class 3 and an even higher breathability requirement for Class 4, because holding out particulates is a lot easier than holding out vapors.

With all of that said, there's now a hierarchy of protection that makes a whole lot more sense for the first responder. And the idea of NFPA 1994 is truly to apply across any of the areas of first responders, whether it be hazmat, fire, police, [or] medical.

And 1991 and 1992 really aren't that way, correct?

No, NFPA 1991 and 1992 really are hazmat team standards, although NFPA 1992 sets criteria that are useful in a lot of different situations that might be appropriate for the fringes of a WMD event.

On NFPA's Web site, you can read comments and see how they were dealt with. There was a lot of discussion in 1994's comments about Total Heat Loss performance requirements.

As you know, a lot of the products in the marketplace currently are relatively inexpensive plastic films. While these products involve a high degree of technology and are very good barriers in holding out chemical vapors and liquids, the materials totally limit body cooling and will lead to heat stress during long wearing periods and high work loads. The fact of the matter is, people are being put in plastic bags. And that type of encapsulation creates probably as much of a hazard as anything else in terms of strain to the individual wearers.

From heat buildup.

Right. The microenvironment inside the clothing traps any heat from conduction and quickly becomes saturated with humidity. As humidity builds up, the wearer's sweat production shuts down, eliminating another principal method of body cooling. The net result is a rise in core temperature and the effects of heat stress.

The Total Heat Loss measures both conductive heat loss and evaporative heat loss (from sweating) that is possible with a material system. Prior studies have shown that this test can correlate with physiological studies and in essence predict the strain imposed by the garment and the materials system used in its construction.

Were those requirements retained? There was discussion about making them optional.

They requirements for total heat loss were retained. And the good news is that there are technologies out there, and have been for some time, that are what they call semi-permeable or -breathable, which are able to retard the highly toxic chemicals but still allow water vapor to pass through because of the smaller size of the water molecules and chemistry used in the material system. These properties allow some degree of comfort to the wearer.

If I understood correctly, these total heat loss requirements are applied only to Class 3 and 4.

Right. The total heat loss requirement was not established for Class 2 ensembles. While it has been shown that Class 2 barrier performance can be achieved with available materials, the committee felt that a good first step would be to introduce the breathability requirement primarily for the mission areas where longer service times were expected.

I hadn't realized this standard addresses total ensembles--including footwear and gloves.

Yes. NFPA 1994 is an ensemble standard. The only equipment not directly addressed is the respirator. But within NFPA 1994, the proposed standard does reference the CBRN approvals that NIOSH offers for both SCBA and APR.

I thought so. It says the ensemble maker would specify NIOSH-certified respirators to be included in the ensemble.

Right. The other thing that's nice is, whereas the industry always has had different ways of testing respirators and clothing, the NFPA committee actually harmonized the ways that protection is established for both respirators and clothing. The challenge levels used for NFPA 1994 Class 2 ensembles are consistent with what NIOSH has established for CBRN SCBA. Likewise, the same approach is used for NFPA 1994 Class 3 ensembles, where the testing of clothing is consistent with the NIOSH criteria for CBRN APRs.

That is important, I agree.

We finally made it logical. . . . It really did bring everything together. Now, the NFPA 1994 standard and the NFPA 1991 standard have been adopted or recognized by the Department of Homeland Security. This is of significance to your readers because grant monies are now being more and more scrutinized in the purchase of PPE that complies with standards. In terms of the non-industrial [purchases], that's clearly the biggest push. . . .

DHS [and] what was formerly the DOJ Office of Domestic Preparedness, all those organizations are placing more emphasis on equipment compliance with standards. There's something called the Authorized Equipment List that makes reference to standards. There's a lot of debate because, obviously, people whose products don't meet those standards are critical of that approach. But, for all the junk that's been sold in the marketplace, it's a good thing to set some minimum criteria for the equipment that first responders must depend on for their safety.

Has it brought many more manufacturers to the standards-writing tables?

It certainly has. There is a substantially greater interest in how the standards are written and scrutiny over the process by which they are adopted.

There was input in the 1994 debate from many different players. They get their voices heard, and the standards ought to be improved as a result. Has NFPA 70E also been a key driver for this sector?

It is. That standard has helped tremendously. What's neat about 70E is it's not a manufacturing standard, it's really a use standard. I always like the fact that they go through in detail within 70E and specify specific kinds of electrical utility worker tasks. They identify a hazard category with each of those tasks. Then there's a table that relates the hazard category to types of clothing, and then there are specifications that go with that clothing that actually come from ASTM, primarily.

Of course, OSHA 1910.269 helps. It doesn't specifically reference NFPA 70E, but the industry recognized the link between NFPA 70E and the OSHA regulations.

OSHA's about to link them more directly. On the industrial side, are 70E and 1910.269 too influential on developments in apparel? Are people who don't need electrical safety protection being left out?

I believe NFPA 70E has the desired effect on the electrical protective industry by defining specifically where workers need specific levels [of] protection. The standard supports the OSHA regulations with much-needed detail that is difficult for OSHA to establish.

In the hazmat industry, the same parallel exists where Levels of Protection are established by OSHA that are relatively ambiguous. The NFPA 1991, 1992, and 1994 standards set specific performance criteria to provide needed definition. There has been some discussion that OSHA might initiate a rulemaking process to reexamine PPE requirements across the board, and specifically in the area of emergency response--that some further work would be done to create a new appendix to OSHA 1910.120.

How long ago was this talked about?

The issue has been under consideration for a couple of years now. . . . As far as I know, there is still an intent to make a proposal specifically addressing emergency responders for WMD events. What has been the issue is defining the EPA levels of protection, primarily level A, B, and C ensembles. A number of groups would like to provide more specific definitions of ensemble requirements in terms of existing consensus standards, for emergency applications that are not at a fixed site. This issue has created some controversy, but that seems to be a logical approach.

Would you be in favor?

I'd be in favor of any clarification on the types of protection needed by first responders. I don't think the EPA Levels of Protection provide responder organizations the type of information needed to make good clothing and equipment choices. The EPA levels really just describe what the clothing looks like; the levels don't define minimum performance. An encapsulating suit could be made out of a fairly poor barrier material and still qualify as a Level A suit; the term "chemical resistant" used in the OSHA regulations is not defined and left to the imagination of the response organization. Likewise, the regulations address about other aspects of the clothing in terms of its integrity, but this performance is not defined well enough for there to be consistency with the protection offered to end users.

Was the manufacturing community pushing OSHA to do this? How did it come about?

Oh, no, I think it was the opposite. Where I think a lot of the support for improving regulations has come from is end user organizations. For example, the InterAgency Board for Equipment Standardization and InterOperability, or IAB--an organization that consists primarily of federal, state, and local government representatives involved in emergency response--is seeking to improve the consistency of protection offered by safety equipment for first responders. Their whole mission is to promote standardization of equipment--not just PPE, but things like communications, and medical equipment, and detectors, and decontamination, and the training for the use of those items--for first responders. While the scope of this activity is primarily for WMD events, I think it may broaden to general disaster events.

The IAB helps shape what's called the Standardized Equipment List. It's very similar to the Authorized Equipment List. In fact, based on their efforts, the Authorized Equipment List now looks a lot like the Standardized Equipment List, and vice versa. Whereas those lists were fairly general in the past, they're now quite detailed and informative. A good reference for both lists is a database called the Responder Knowledge Base, sponsored by the Memorial Institute for the Prevention of Terrorism, located in Oklahoma City [online at http://www1.rkb.mipt.org/ ]. An incredible amount of valuable information is available online through the Responder Knowledge Base.

Do you know of any formal timetable for OSHA's action in this area?

I would have thought something was going to happen by the end of last year or this year. I haven't heard any specific announcement from OSHA on this activity, so I don't know what their current timetable is. I know there are groups reminding OSHA to look at this issue, but, again, I don't know what constraints have been encountered.

Switching gears, I noticed a recent article in which you discussed "Katrina Cough." How does it fit in with PPE worn by first responders?

Some of the same issues came up post-9/11. One of the issues is the report of chronic respiratory ailments [among] workers in these disaster areas. . . . To relate it back to 9/11, one of the occupational groups, the firefighters, in particular had well-documented medical baselines, so the documentation for effects on firefighters could be established. There were obviously a lot of firefighters [who subsequently] were found medically unfit for duty.

There's that same concern with Katrina after-effects. While the flooding is gone, particulates from the remediation efforts cause individuals' respiratory systems to become irritated. That effect, in combination with exposure to molds and other biological hazards, has contributed to the pneumonia-like cases that have been reported by some to be widespread through that area. I haven't seen statistics to well define the number of individual complaints, other than it was considered significant as recently as November.

Is there a lesson here for PPE manufacturers? Anything they can learn from these two situations to prevent such exposures?

Obviously, the conditions for disaster operations such as Hurricane Katrina, where workers have to wear respiratory protection for very long periods of time, point out that we [need] to consider how federal grant monies are used. A Katrina-like disaster shows that some priority must be given to non-WMD preparedness, as well as the terrorism events that we could face. Both types of disasters can produce long-term, chronic effects.

When we were discussing the CBRN elements of NFPA 1994, I had a similar thought: If you stockpile gear against WMD threats, it may not be used for a long, long time. The hazards after a natural disaster are not the same.

Fortunately, there is some crossover, but you're right, the events may not be the same. For example, the kind of remediation work that will be done in a post-disaster cleanup probably doesn't warrant the same level of barrier protection. There is still a need for protection from physical hazards, perhaps, but what you're really trying to do is keep contamination off your body or underclothing. In this case, the threat is not likely to be vapors or prolonged liquid contact; instead, it may be particulates and incidental liquid contact, which would be different than during the early stage of the emergency or in a WMD event.

It makes me wonder whether some of the standards are being tuned so highly that they're being overdone.

I believe that standards that have been set by the NFPA are appropriate for the intended applications. Unfortunately, we simply do not have all of the standards that we need to cover the range of clothing and equipment that are needed for protection against a range of hazards. For example, we don't have a general chemical protective apparel standard in this country--a standard that is sorely needed. The International Safety Equipment Association (ISEA) has been working on such a standard for some time.

What OSHA had in mind with an appendix to the HAZWOPER standard--that wouldn't do it, either. Do you know of anything on the horizon that would?

No. I think the bigger driving force will continue to be government grant funds. And if those get broadened or extended, that's going to help. The U.S. is somewhat standards-averse; it's not easy to update OSHA standards. There's nothing really on the horizon, short of these efforts we've just described. That's going to remain the way of things, I think, for some time yet.

We assume DHS funding will continue to be high. I don't know, though.

I don't know that, either. I've heard some observers indicate the grant monies have already crested, that it takes another disaster because we have short memories on such things. And, of course, these programs are expensive and don't always achieve the desired effects.

Is nanotechnology a possible driver?

I think it will be. One group I definitely want to be able to mention is the [NIOSH] National Personal Protective Technology Laboratory in Pittsburgh. . . . They have an initiative in this area; they have been moving toward the anticipation of future nanotechnology hazards, at least from the respiratory protection standpoint.

I wasn't aware of that. They have a role in respirator certification.

The National Personal Protective Technology Laboratory actually has a larger role. The organization has broadened its scope to deal with all forms of personal protective equipment. In fact, they've just signed memoranda of understanding with both ASTM and the National Fire Protection Association. A big part of NPPTL's mission now, under NIOSH, is to support standards work . . . to work through industry and consensus groups to create these new standards. They were very much a contributor to the NFPA 1994 process.

This Q&A appeared in the September 2006 issue of Occupational Health & Safety.

This article originally appeared in the September 2006 issue of Occupational Health & Safety.

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