MEMORANDUM TO:

NFPA Technical Committee on Respiratory Protection Equipment

FROM:

Stacey Van Zandt

DATE:

April 14, 2010

SUBJECT:

NFPA 1984 F2010 ROC Letter Ballot

The ROC letter ballot for NFPA 1984 is attached. The ballot is for formally voting on whether or not you concur with the committee’s actions on the comments. Reasons must accompany all negative and abstention ballots. Please do not vote negatively because of editorial errors. However, please bring such errors to my attention for action. Please complete and return your ballot as soon as possible but no later than Tuesday, May 4, 2010. As noted on the ballot form, please return the ballot to Stacey Van Zandt either via e-mail to [email protected] or via fax to 617.984.7056. You may also mail your ballot to the attention of Stacey Van Zandt at NFPA, 1 Batterymarch Park, Quincy, MA 02169. The return of ballots is required by the Regulations Governing Committee Projects. Attachment

Report on Comments – November 2010

NFPA 1984

_______________________________________________________________________________________________ 1984-1 Log #1 FAE-RPE _______________________________________________________________________________________________ Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment, 1984-1a Pertaining to 7.1.5 and the associated test method, the TCC directs the TC to examine the performance requirements and communications test as it relates to PAPR “blower-on” vs. PAPR “blower-off” conditions. This is a direction from the Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment in accordance with 3.4.2 and 3.4.3 of the Regulations Governing Committee Projects. See Committee Actions taken on Comments 1984-46 (Log #23) and 1984-49 (Log #24). _______________________________________________________________________________________________ 1984-2 Log #49 FAE-RPE _______________________________________________________________________________________________ Peter D. Finch, Xcaper Industries, LLC 1984-1a Add new text as follows: Nothing in this standard shall prevent the use of systems, methods, or devices that are equivalent in quality, performance, effectiveness and durability to those prescribed by the standard, provided technical documentation is made available to the authority having jurisdiction that demonstrates equivalency and the system, method, or device is appropriate for the intended purpose. Nothing in this standard is intended to limit fair competition for new technology under the guidelines of the Federal Trade Commission. Similar language is included in NFPA 13. This language should be included to preclude the elimination of any new technology that was not considered during the promulgation of this standard. The proposed text in the submitter's Comment is adequately embraced by the text provided in Chapter 1, Section 1.1; and does not prevent innovation that meets or exceeds the minimum requirements of NFPA 1984. This standard does not provide the criteria necessary for validating what is "equivalent." The portion of the submitter's Comment that addresses "...documentation is made available to the authority having jurisdiction that demonstrates equivalency..." does not provide for independent, third-party evaluation and testing of the product to assure the product will provide the respiratory protection needed for the wildland fire fighters. The "authority having jurisdiction" can receive the pass/fail determination from the certification organization following the evaluation of the product and whether or not it meets the requirements of NFPA 1984. Chapter 4 of NFPA 1984 provides the process for independent, third-party certification organizations to inspect, evaluate, and test the proposed products to determine if the manufacturers' product meets all of the requirements specified in NFPA 1984. Where a product is confirmed as meeting all requirements of the standard, the product will be marked by the certification organization that it meets the requirements of NFPA 1984. All NFPA PPE product standards produced by the Project on Fire and Emergency Services Protective Clothing and Equipment require that independent, third-party certification organizations inspect, evaluate, and test the proposed products to determine if the manufacturers' product meets all of the requirements specified in the standard. All certification requirements are found in Chapter 4 of each PPE standard. NFPA 1984 was developed to set minimum criteria for wildland fire fighting respirators to better provide better breathing air quality, and to assure adequate respiratory protection for personnel operating at wildland fires. Nothing in the document prohibits innovation that meets or exceeds the minimum requirements of the standard.

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NFPA 1984

_______________________________________________________________________________________________ 1984-3 Log #50 FAE-RPE _______________________________________________________________________________________________ Peter D. Finch, Xcaper Industries, LLC 1984-1a Add new text as follows: Nothing in this standard shall be intended to restrict new technology or alternate arrangements, provided that the level of safety prescribed by this standard is not lowered. NONE Provided. The proposed text in the submitter's Comment is adequately embraced by the text provided in Chapter 1, Section 1.1; and does not prevent innovation that meets or exceeds the minimum requirements of NFPA 1984. NFPA 1984 was developed to set minimum criteria for wildland fire fighting respirators to better provide better breathing air quality, and to assure adequate respiratory protection for personnel operating at wildland fires. Nothing in the document prohibits innovation that meets or exceeds the minimum requirements of the standard. _______________________________________________________________________________________________ 1984-4 Log #11 FAE-RPE _______________________________________________________________________________________________ David V. Haston, USDA Forest Service 1984-1a Delete 2.3.1 in its entirety ANSI B46.1 ANSI Y1.1 ANSI Y14.5 ASTM B 16 ASTM D 6413

, 1978. , 1982.

, 1972.

, 1999

References are not used in the document.

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, 2000.

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NFPA 1984

_______________________________________________________________________________________________ 1984-5 Log #51 FAE-RPE _______________________________________________________________________________________________ Marcelo M. Hirschler, GBH International 1984-1a Revise text as follows: ASTM International, 100 Barr Harbor Drive, West Conshohocken, PA 19428-2959. ASTM B 16/B16M, 2000 2005 . ASTM B 117, , 2003. ASTM D 1003, ASTM D 6413,

, 1999 2008 .

Update of ASTM standards

,

2000 2007 e1.

The TC Accepts the submitter's recommendations regarding ASTM B16M, ASTM B 117, and ASTM D 1003. The TC Rejects the submitter's recommendation regarding ASTM D 6413. ASTM D 6413 is not referenced in NFPA 1984. See Committee Action taken on Comment 1984-4 (Log #11). _______________________________________________________________________________________________ 1984-6 Log #10 FAE-RPE _______________________________________________________________________________________________ David V. Haston, USDA Forest Service 1984-1a New text to read as follows: 29 CFR 1910.134 (Title 29, Code of Federal Regulations, Part 1910.134) . Regulation is referenced in 6.1.3.

_______________________________________________________________________________________________ 1984-7 Log #12 FAE-RPE _______________________________________________________________________________________________ David V. Haston, USDA Forest Service 1984-1a A chemical process of oxidation that occurs at a rate fast enough to produce heat and usually light in the form of either a glow or a flame. Combustion evidenced by heat and usually light in the form of either a glow or a flame. A material response evidenced by splitting or delaminating. Undefined words in Chapter 7. “Ignite” and “separate” are used in 7.1.1, “combustion” is used in 7.1.2. The definition for “separate” is from NFPA 1977, 2005 edition. Accept the term and definition of "Separate." Reject the terms and definitions of "Combustion" and "Ignite." Websters dictionary adequately defines the terms "combustion" and "ignite."

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Report on Comments – November 2010

NFPA 1984

_______________________________________________________________________________________________ 1984-8 Log #27 FAE-RPE _______________________________________________________________________________________________ Geoffrey Betsinger, 3M 1984-1a Revise text to read as follows: The A tight-fitting-respiratory inlet covering component of a respirator; e.g. a half facepiece covers the wearer's nose and mouth; a full facepiece covers the wearer's nose, mouth, and eyes. A tight fitting component, such as a filter with thread, could meet this definition. 'Respiratory inlet covering' is used elsewhere in this standard.

Revise 3.3.9 to read: Facepiece. A tight-fitting respiratory inlet covering: component of the respirator: e.g. a half facepiece covers the wearer’s nose and mouth; a full facepiece covers the wearer’s nose, mouth, and eyes. The TC made minor text modifications for clarity. _______________________________________________________________________________________________ 1984-9 Log #13 FAE-RPE _______________________________________________________________________________________________ David V. Haston, USDA Forest Service 1984-1a Delete text as follows: A carbon based chemical substance existing in the vapor form in ambient air. Consistency - the other gases and vapors listed in A.4.1.2 are not defined.

_______________________________________________________________________________________________ 1984-10 Log #28 FAE-RPE _______________________________________________________________________________________________ Geoffrey Betsinger, 3M 1984-1a Revise text to read as follows: NIOSH does not certify respirators for applications. They are certified to the hazards. This wording may need to change depending on what NIOSH decides to call the approvals designed for this respirator but this is an example of what it may need to look like. A NIOSH approved R95, OV, CO, formaldehyde, acrolein, sulfur dioxide, nitrogen dioxide respirator that has been certified for providing respiratory protection during wildland fire fighting operations by NIOSH under 42 CFR 84, and is certified as compliant with NFPA 1984, Standard Application Procedure for the Certification of Respirators Under 42 CFR 84 Rev. 1 July 2005 states in section C.23, 4th paragraph, "Manufacturers may not imply 'Use" for approved products. For example, packaging may not say 'NIOSH-approved Paint Spray Respirator." It may say "NIOSH approved OV/P1 00 respiratory; manufacturer recommended for lacquer paints." Additionally, section c.14 states "A product trade name may indicate a protection but it may not imply use,"

A NIOSH approval for an R95, OV, CO, formaldehyde, acrolein, sulfur dioxide, nitrogen dioxide respirator that is certified as compliant with NFPA 1984 will imply use. The TC feels the text as printed should stand.

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NFPA 1984

_______________________________________________________________________________________________ 1984-11 Log #29 FAE-RPE _______________________________________________________________________________________________ Geoffrey Betsinger, 3M 1984-1a Revise text to read as follows: NIOSH does not certify respirators for applications. They are certified to the hazards. This wording may need to change depending on what NIOSH decides to call the approvals designed for this respirator but this is an example of what it may need to look like. Prior to certification of wildland fire fighting respirators to this standard, respirators shall be certified by NIOSH as a "wildland fire fighting air-purifying respirator," or as a wildland fire fighting powered air-purifying respirator approved to R95, OV, CO, formaldehyde, acrolein, sulfur dioxide, nitrogen dioxide requirements. Standard Application Procedure for the Certification of Respirators Under 42 CFR 84 Rev. 1 July 2005 states in section C.23, 4th paragraph, "Manufacturers may not imply 'Use" for approved products. For example, packaging may not say 'NIOSH-approved Paint Spray Respirator." It may say "NIOSH approved OV/P100 respiratory; manufacturer recommended for lacquer paints." Additionally, section c.14 states " A product trade name may indicate a protection but it may not imply use."

The term “wildland fire fighting air purifying respirator” is the term selected by NIOSH. _______________________________________________________________________________________________ 1984-12 Log #2 FAE-RPE _______________________________________________________________________________________________ Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment, 1984-13 The TCC noted that in Log CP3 there is missing text, incomplete text, or misplaced text in 4.3.9, 4.3.9.2, 4.3.15, 4.3.15.2, 4.3.15 (repeated), and 4.3.15.2 (repeated). The TCC directs the TC to review the text of Log CP3 and the text of 4.3.9, 4.3.9.2, 4.3.15, and 4.3.15.2 in the ROP draft, and clarify the text. This is a direction from the Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment in accordance with 3.4.2 and 3.4.3 of the Regulations Governing Committee Projects. Log #CP3 and the ROP draft are correct as-written. For some reason paragraphs 4.3.15 and 4.3.15.2 were inadvertently repeated during the compilation of proposals. Other than this repeated text, the TC noted no missing, incomplete, or misplaced text in ROP Log #CP3. See Committee Action taken on ROC 1984-18 (Log #16). _______________________________________________________________________________________________ 1984-13 Log #14 FAE-RPE _______________________________________________________________________________________________ David V. Haston, USDA Forest Service 1984-1a Revise text to read as follows: 4.2.7 The certification organization shall require the manufacturer to establish and maintain a quality assurance program that meets the requirements of Section 4.5 Manufacturers’ Quality Assurance Program ISO Registration for Manufacturers. Incorrect title of Section 4.5 referenced.

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NFPA 1984

_______________________________________________________________________________________________ 1984-14 Log #15 FAE-RPE _______________________________________________________________________________________________ David V. Haston, USDA Forest Service 1984-1a Table 4.3.9 test Series Category A Test 2: Respirator Heat Resistance (Section 8.1) Category B Test 3: Respirator Flammability (Section 8.2) Category C Test 1: Accelerated Corrosion Resistance (Section 8.7) Consistency of references between chapters 4, 7 and 8. See related comments on Chapters 7 and 8.

_______________________________________________________________________________________________ 1984-15 Log #30 FAE-RPE _______________________________________________________________________________________________ Geoffrey Betsinger, 3M 1984-1a Revise text to read as follows: All tests within Categories A, and B and C shall be conducted in the order specified and are designed as cumulative damage tests. All tests within Categories A, and B and C shall be conducted in the order specified and are designed as cumulative damage tests. There is only one test in Category C.

_______________________________________________________________________________________________ 1984-16 Log #31 FAE-RPE _______________________________________________________________________________________________ Geoffrey Betsinger, 3M 1984-1a Delete text as follows: NIOSH does not certify individual components or accessories. Where wildland fire fighting respirators are provided with any accessories or enhancements, those accessories or enhancements shall be certified by NIOSH in accordance with 42 CFR 84 for that specific respirator, and the respirator with accessories or enhancements installed shall be tested to and shall pass all of the performance requirements specified in Chapter 7. NIOSH will follow its procedures with regard to individual components or accessories. 4.3.11.1 addresses this issue with regard to this standard. Delete the current 4.3.11 and move 4.3.11.1 into that position.

It is necessary for accessories to be certified by NIOSH as respirator components.

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NFPA 1984

_______________________________________________________________________________________________ 1984-17 Log #32 FAE-RPE _______________________________________________________________________________________________ Geoffrey Betsinger, 3M 1984-1a Revise text to read as follows: Any modifications made to a certified wildland fire fighting respirator that is certified by NIOSH in accordance with 42 CFR 84, and also certified as compliant with this standard; or any modifications to any NIOSH certified accessories or enhancements by the respirator manufacturer after certification, shall require evaluation by NIOSH. Recommend re-wording to eliminate redundancy.

It is very important that both NIOSH certification and independent third-party certification is specified in Chapter 4 of the NFPA 1984. The emphasis of both certifications is there for clarity to the requirement. _______________________________________________________________________________________________ 1984-18 Log #16 FAE-RPE _______________________________________________________________________________________________ David V. Haston, USDA Forest Service 1984-1a, 1984-13 Paragraphs 4.3.15 and 4.3.15.2 are repeated in Log CP#3 as presented in the ROP. Delete repeated text as shown in ROP Log #CP3. Note: the 1984-F10-ROP draft standard (dated 21 August 2009) is correct as-written. The TCC advised the TC of repeated text in Log #CP3.

_______________________________________________________________________________________________ 1984-19 Log #33 FAE-RPE _______________________________________________________________________________________________ Geoffrey Betsinger, 3M 1984-1a Revise text to read as follows: The manufacturer shall maintain all design and performance inspection and test data from the certification organization used in the certification of the manufacturer's compliant product. The manufacturer shall provide a statement of compliance such data, upon request, to the purchaser or authority having jurisdiction. Manufacturer's test data is considered proprietary. Generally a statement of what test the product was tested to and if it met the requirement is all that is provided.

This text is standard boilerplate for all PPE "product standards" produced by Project on Fire and Emergency Services Protective Clothing and Equipment.

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Report on Comments – November 2010

NFPA 1984

_______________________________________________________________________________________________ 1984-20 Log #34 FAE-RPE _______________________________________________________________________________________________ Geoffrey Betsinger, 3M 1984-1a Delete text as follows: We feel that a five year re-certification requirement is adequate. An annual re-certification requirement is not necessary if the manufacturer complies with the Quality Control requirements outlined in Section 4.5 of this standard and the Quality requirements mandated by NIOSH. 4.4 Annual Verification of Product Compliance 4.4.1 All wildland fire fighting respirator models that are certified and labeled as being compliant with this standard shall undergo recertification on an annual basis. 4.4.2 Recertification shall include inspection and evaluation to all design requirements as required by this standard on all manufacturer models and components. 4.4.3 Recertification shall include testing to all performance requirements as required by this standard on all manufacturer models and components. 4.4.3.1 Where a test method incorporates testing both before and after a preconditioning and the test generates quantitative results, recertification testing shall be limited to the conditioning that yielded the worst case test result during the initial certification for the model or component. 4.4.3.2 Where a test method incorporates testing both before and after a preconditioning and the test generates non-quantitative results, recertification testing shall be limited to a single conditioning procedure in any given year. Subsequent annual re-certifications shall cycle through the remaining the conditioning procedures to ensure that all required conditionings are included over time. 4.4.3.3 Where a test method requires testing on three specimens, a minimum of one specimen shall be tested for annual certification. 4.4.3.4 Where a test method requires testing of five or more specimens, a minimum of two specimens shall be tested for annual certification. 4.4.4 Samples of manufacturer models and components for recertification acquired from the manufacturer or component supplier during random and unannounced visits as part of the follow-up inspection program in accordance with 4.2.9 shall be permitted to be used toward annual recertification. 4.4.5 The manufacturer shall maintain all design and performance inspection, evaluations, and test data from the certification organization used in the recertification of the manufacturer's models and components. The manufacturer shall provide such data, upon request, to the purchaser or authority having jurisdiction. 4.4.6 Every fifth year from the date of the initial certification, the requirements specified in Section 4.4 shall be waived when the testing required by 4.3.15 is conducted. In addition to the requirements of Section 4.5, products can be 'audited' at any time and NIOSH Quality Requirements include manufacturing site audits. This text is standard boilerplate for all PPE "product standards" produced by Project on Fire and Emergency Services Protective Clothing and Equipment. The NIOSH quality requirements do not address NFPA performance requirements outside the scope of 42 CFR Part 84. Annual recertification insures that any changes in product performance that could affect certification will be detected.

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NFPA 1984

_______________________________________________________________________________________________ 1984-21 Log #35 FAE-RPE _______________________________________________________________________________________________ Geoffrey Betsinger, 3M 1984-1a Revise text to read as follows: The wildland fire fighting respirator protective package product label shall bear the following compliance 1 statement, legibly printed, and all letters and numbers shall be at least 6.5 mm /4 in.) in height: "THIS RESPIRATOR MEETS THE REQUIREMENTS OF NFPA 1984, STANDARD ON RESPIRATORS FOR WILDLAND FIRE FIGHTING OPERATIONS, 2011 EDITION. DO NOT REMOVE THIS LABEL!" How do you open the protective package without removing the label?

requirement.

Opening the protective package does not remove the label and would not be in violation of this

_______________________________________________________________________________________________ 1984-22 Log #3 FAE-RPE _______________________________________________________________________________________________ Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment, 1984-18 The TCC directs the TC to review the actions taken on 1984-18 ( Log #49) and 1984-19 (Log #50) and verify that the actions taken are as intended and correct. This is a direction from the Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment in accordance with 3.4.2 and 3.4.3 of the Regulations Governing Committee Projects. The TC has reviewed the actions taken on ROP 1984-18 (Log #49) and ROP 1984-19 (Log #50) and has verified that the actions taken were as intended and correct. _______________________________________________________________________________________________ 1984-23 Log #36 FAE-RPE _______________________________________________________________________________________________ Geoffrey Betsinger, 3M 1984-1a Revise text to read as follows: Where applicable the expiration date of air purification component(s) shall be printed on the outside surface of the air purifying component, and shall also be printed on the air purification component protective package. The expiration date shall be in the YYYY/MM form. The expiration date shall be visible when the air purifying component is attached to the respirator inlet covering for normal use. Some components may not require an expiration date.

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_______________________________________________________________________________________________ 1984-24 Log #4 FAE-RPE _______________________________________________________________________________________________ Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment, 1984-19 The TCC directs the TC to review the actions taken on 1984-18 ( Log #49) and 1984-19 (Log #50) and verify that the actions taken are as intended and correct. This is a direction from the Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment in accordance with 3.4.2 and 3.4.3 of the Regulations Governing Committee Projects. The TC has reviewed the actions taken on ROP 1984-18 (Log #49) and ROP 1984-19 (Log #50) and has verified that the actions taken were as intended and correct. _______________________________________________________________________________________________ 1984-25 Log #37 FAE-RPE _______________________________________________________________________________________________ Geoffrey Betsinger, 3M 1984-1a Revise text to read as follows: This requirement will not benefit the end user. 5.1.10 Where wildland fire fighting respirators utilize a rechargeable power source as a component of the certified respirator, the manufacturer is required to provide information on service life, shall be printed on the outside surface of the power source. The expiration date shall be in the YYYY/MM format. Battery chemistry service life is generally more dependent on charge/discharge cycles rather than time. So a requirement for an expiration date could cause end users to dispose of batteries that are still functional or keep batteries longer than they should. The real issue is decreased run time as the capacity of the battery chemistry decreases. Operationally an 8 hour battery that now has 4 hours of capacity may be OK and could be managed by switching batteries on breaks etc.

The TC revised the text as follows: 5.1.10 Where wildland fire fighting respirators utilize, as a component of the respirator, a rechargeable power source with an expiration date, the power source expiration date shall be printed on the outside surface of the power source. The expiration date shall be in the YYYY/MM format. Some rechargeable batteries might not have expiration dates.

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_______________________________________________________________________________________________ 1984-26 Log #38 FAE-RPE _______________________________________________________________________________________________ Geoffrey Betsinger, 3M 1984-1a Revise text to read as follows: This requirement will not benefit the end user. 5.1.11 Where wildland fire fighting respirators utilize a power source as a component of the certified respirator, the estimated power source service life, in the fully charged condition shall be printed on the respirator. The printing shall be visible when the respirator is assembled in the as certified configuration. Battery life can vary depending on a variety of factors such as temperature; filter loading, age and chemistry type. A battery that functions for 8 hours in a test lab may function significantly less in cold weather or under heavy filter loading. Simply listing an estimate service life on the battery may be misleading to the end user.

Estimated power source service life provides a reference point for the user. _______________________________________________________________________________________________ 1984-27 Log #39 FAE-RPE _______________________________________________________________________________________________ Geoffrey Betsinger, 3M 1984-1a Revise text to read as follows: Information or training materials regarding use shall be provided at least on the following areas: (1) Pre-use checks (2) For fire departments or fire department based emergency services, proper use consistent with NFPA 1500, Standard on Fire Department Occupational Safety and Health Program. (2) Replacement of air purification components, if applicable (3) Emergency procedures to be followed in the event of damage, malfunction, or failure of the respirator Item '2' is a requirement for the end user not the manufacturer. Perhaps a warning would be sufficient?

This is a requirement for the manufacturer. _______________________________________________________________________________________________ 1984-28 Log #40 FAE-RPE _______________________________________________________________________________________________ Geoffrey Betsinger, 3M 1984-1a Revise text to read as follows: The respirator manufacturer shall provide the manufacturer's specified component service life, where applicable, for the product. This information shall be included at least in the maintenance information provided to the users. Re-word to make more clear.

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_______________________________________________________________________________________________ 1984-29 Log #41 FAE-RPE _______________________________________________________________________________________________ Geoffrey Betsinger, 3M 1984-1a Revise text to read as follows: Where the respiratory inlet covering is configured as a full facepiece, the full facepiece shall accomodate NIOSH certified corrective eyewear. NIOSH does not certify corrective eyewear.

See Committee Action taken on 1984-30 (Log #42). _______________________________________________________________________________________________ 1984-30 Log #42 FAE-RPE _______________________________________________________________________________________________ Geoffrey Betsinger, 3M 1984-1a Revise text to read as follows: Protective eyewear shall not interfere with the sealing surface of the wildland fire fighting respirator to the wearer's face, shall not pass between any sealing surfaces of the respirator to the wearer's face, shall not reduce the respiratory protective qualtities of the respirator, shall not restrict the movement of the wearer, and shall not restrict the vision of the wearer. This requirement is too vague and subjective. OSHA requires that fit testing be performed with all required PPE in place. Identification of these types of issues on an individual basis is more valuable than what is stated in this requirement. Delete 6.1.3.3 Add new 6.1.4 as follows: 6.1.4 Wildland fire fighting respirators shall be designed to accommodate protective eyewear. 6.1.4.1 Where the respiratory inlet covering is configured as a full facepiece, the full facepiece shall accommodate corrective eyewear that is certified by NIOSH as a respirator accessory. 6.1.4.2 Where the respiratory inlet covering is not configured as a full facepiece, the respirator shall be designed to accommodate protective eyewear including, but not limited to, corrective eyewear, safety glasses, and gas-tight goggles. The TC agrees that paragraph 6.1.3.3 is a user requirement and not a manufacturer’s requirement. The text in 6.1.4 was revised by the TC.

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_______________________________________________________________________________________________ 1984-31 Log #43 FAE-RPE _______________________________________________________________________________________________ Geoffrey Betsinger, 3M 1984-1a Revise as follows: This section is not needed. All requirement will be met by NIOSH approval. 6.1.5 All wildland fire fighting respirators shall be equipped with an air purification component or components. 6.1.5.1 Each air purification component shall contain the necessary media for all target substances and particulate matter. 6.1.5.2 More than one air purifying component shall be permitted to be used to meet the minimum NIOSH service life requirements. 6.1.5.3 Particulate matter filters shall be located on the inlet side of the air purifying component. A secondary upstream filter shall be permitted. 6.1.5.4 All wildland fire fighting respirator air purification components shall be color coded in accordance with ANSI/AIHA Z88.7, Color Coding of Air Purifying Respirator Canisters, Cartridges, and Filters. These are design specifications and NIOSH approval will address all of them. 42 CFR 84 dictates the colors of cartridges. The most recent version of Z88.7 is in conflict with the NIOSH color code. Therefore, if a manufacturer followed the current Z88.7 the cartridge would not be able to be NIOSH approved (e.g. brown OV (Z88) versus Black (NIOSH)).

_______________________________________________________________________________________________ 1984-32 Log #44 FAE-RPE _______________________________________________________________________________________________ Geoffrey Betsinger, 3M 1984-1a Delete text as follows: 6.1.7 All wildland fire fighting respirators shall be designed to be carried on a belt, in a pocket, and on wildland fire fighting load carrying equipment. As worded, this requires a PAPR to fit in a pocket. This is a design specification and should be deleted. The TC revised 6.1.7 as follows: 6.1.7 All wildland fire fighting respirators shall be designed to be carried on a belt, in a pocket, or on wildland fire fighting load carrying equipment. The TC rejects the deletion of the entire 6.1.7 as appropriate respirator carries are necessary. The new wording does not require a PAPR to fit in a pocket.

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_______________________________________________________________________________________________ 1984-33 Log #5 FAE-RPE _______________________________________________________________________________________________ Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment, 1984-28 The TCC directs the TC to review the action taken 1984- 28 (Log #32) and verify that the action taken is as intended and correct. This is a direction from the Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment in accordance with 3.4.2 and 3.4.3 of the Regulations Governing Committee Projects. The TC has reviewed the action taken on ROP 1984-28 (Log #32) and has verified that the action taken was as intended and correct. The TC agreed with the submitter; however, the PAPR-specific design requirements were removed with the deletion of Section 6.2. The TC determined that minimum design requirements shall be the same for all wildland respirators. _______________________________________________________________________________________________ 1984-34 Log #6 FAE-RPE _______________________________________________________________________________________________ Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment, 1984-29 The TCC directs the TC to review the action taken 1984- 29 (Log #33) and verify that the action taken is as intended and correct. This is a direction from the Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment in accordance with 3.4.2 and 3.4.3 of the Regulations Governing Committee Projects. The TC has reviewed the action taken on ROP 1984-29 (Log #33) and has verified that the action taken was as intended and correct. The TC agreed with the submitter; however, the PAPR-specific design requirements were removed with the deletion of Section 6.2. Chapter 6 had separate design requirements for APR and PAPR. The TC determined that minimum design requirements shall be the same for all wildland respirators. _______________________________________________________________________________________________ 1984-35 Log #17 FAE-RPE _______________________________________________________________________________________________ David V. Haston, USDA Forest Service 1984-1a 7.1.1 All wildland firefighting respirators shall be tested for resistance to heat as specified in Section 8.1 Respirator Heat Resistance Test, and no part of the respirator shall ignite, melt, drip, or separate. 7.1.2 All wildland firefighting respirators that are externally exposed when the respirator is worn, in accordance with the respirator manufacturer’s instructions, shall be tested as specified in Section 8.2 Respirator Flammability Test, and shall not sustain combustion after removal of the heat source. 7.1.7 All wildland firefighting respirators shall be tested for corrosion resistance as specified in Section 8.7, Accelerated Corrosion Test, and shall have the metals that are inherently resistant to corrosion show no more than light surface-type corrosion or oxidation, shall have ferrous metals show no corrosion at the base metal, and shall have the use and function of controls and operating features of the respirator remain functional. Consistency of references between chapters 4, 7 and 8. See related comments on Table 4.3.9 and Chapter 8.

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_______________________________________________________________________________________________ 1984-36 Log #CC1 FAE-RPE _______________________________________________________________________________________________ Technical Committee on Respiratory Protection Equipment, 1984-1a Revise 7.1.2 to read: 7.1.2 All wildland fire fighting respirator materials that are externally exposed when the respirator is worn in accordance with the manufacturer's instructions shall be tested as specified in Section 8.2, Respirator Flammability Test, and shall not sustain flame after removal of the heat source. The TC revised 7.1.2 for consistency of terminology. See Committee Action taken on 1984-39 (Log #20).

_______________________________________________________________________________________________ 1984-37 Log #CC2 FAE-RPE _______________________________________________________________________________________________ Technical Committee on Respiratory Protection Equipment, 1984-1a Revise 7.1.3 to read: 7.1.3 All wildland fire fighting respirators shall be tested for storage integrity as specified in Section 8.3, Storage Integrity Test, and all test subjects shall pass a quantitative fit test with all three test samples. Qualitative fit testing was removed by action taken on 1984-41 (Log #45).

_______________________________________________________________________________________________ 1984-38 Log #18 FAE-RPE _______________________________________________________________________________________________ David V. Haston, USDA Forest Service 1984-1a Revise text to read as follows: 8.1 Respirator Heat Resistance Test 8.2 Respirator Flammability Test. 8.3 Respirator Storage Integrity Test. 8.4 Respirator Lens Abrasion Test. 8.5 Respirator Donning Performance Test. 8.7 Accelerated Corrosion Resistance Test Consistency of references between chapters 4, 7 and 8. See related comments on Table 4.3.9 and Chapter 7. Note: Supporting material is available for review at NFPA Headquarters.

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_______________________________________________________________________________________________ 1984-39 Log #20 FAE-RPE _______________________________________________________________________________________________ David V. Haston, USDA Forest Service 1984-1a Revise text to read as follows: Observations of flame combustion after removal of the heat source shall be recorded and reported for each specimen. 8.2.6.1 Any evidence of flame combustion after removal of the heat source of any specimen shall constitute failure of the specimen. Consistency of terms used in the document. Flame is one indication of combustion. The term "flame" is the appropriate term for this requirement. It is the flame that is being evaluated, not other types of combustion such as smoke, glow, or oxidation. _______________________________________________________________________________________________ 1984-40 Log #19 FAE-RPE _______________________________________________________________________________________________ David V. Haston, USDA Forest Service 1984-1a Substitute the following for Figure 8.2.4.1 (the electronic version of this figure is available from the author):

***Insert 1984_L19_Figure_F2010_R here*** Figure shown in ROP draft was a preliminary figure, a more legible figure was produced and should be used in the standard. The content of the figure is unchanged.

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_______________________________________________________________________________________________ 1984-41 Log #45 FAE-RPE _______________________________________________________________________________________________ Geoffrey Betsinger, 3M 1984-1a Revise text to read as follows: Prior to testing, the test subject shall undergo and pass a qualitative or quantitative fit test procedure with the test specimen. The fit test procedures shall be as specified in 29 CFR 1910.134(1), and 29 CFR 134(m)(2) appendix A. Loose-Fitting PAPRs can be fit tested using either qualitative or quantitative fit test methods, where quantitative fit test methods are used a fit factor of 100 or greater is considered passing. Text added to address testing of loose fitting PAPRs. Paragraph (m) (2) covers training. Appendix A has the approved fit test methods.

The TC revised 8.3.4 as follows: The TC revised the text of 8.3.1 as follows: 8.3.1 Application. This test method shall apply to all non-powered wildland fire fighting respirators. The TC revised the text of 8.3.4.1 as follows: 8.3.4.1* Prior to testing, the test subject shall undergo and pass a quantitative fit test procedure with the test specimen. The fit test procedures shall be as specified in Appendix A of 29 CFR 1910.134. The TC revised 8.3.1 to specify only non-powered respirators. PAPRs have a high flow rate from the power blower and tend to maintain positive pressure in the facepiece for much of the breathing cycle. The TC modified the text of 8.3.4.1 to reference the requirements for fit testing procedures in accordance with 29 CFR 1910.134 to assure consistency in testing. _______________________________________________________________________________________________ 1984-42 Log #46 FAE-RPE _______________________________________________________________________________________________ Geoffrey Betsinger, 3M 1984-1a Revise text to read as follows: The requirements in Section 8.4 need to be re-organized. Move sentence 8.4.3.4 (1) to 8.4.3.1 . (1) Specimens shall be a square piece of respirator lens 50 mm x 50 mm (2 in. x 2 in.). Seven specimens shall be chosen from the four respirator lenses. Renumber remaining text accordingly. Clarification of section.

The sections on "Samples" and "Specimens" are formatted to be the same in all of the PPE product standards. This provides the certification organization and testing organizations with consistent formats. The specimen size is contained in paragraph 8.4.3.5.

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_______________________________________________________________________________________________ 1984-43 Log #47 FAE-RPE _______________________________________________________________________________________________ Geoffrey Betsinger, 3M 1984-1a Delete text as follows: Changes to 8.4.3.1 require the following change: The right test specimens shall conform to all the following criteria: (1) Specimens shall be a square measuring 50 mm × 50 mm (2 in. × 2 in.). (2) Two edges of the square section shall be parallel within ±2 degrees of the axis of the cylinder or cone in the center of the specimen. 1 (3) At least 38 mm (1 /2 in.) of the 50 mm × 50 mm (2 in. × 2 in.) square shall be taken from the right side of the center line of the lens. (4) The 50 mm x 50 mm (2 in. x 2 in.) square shall be cut at approximately eye level. Renumber remaining text accordingly. Clarification of section.

the testing process.

The specimen size in 8.4.3.5(1) is correct and will remain in the test method to clearly specify

_______________________________________________________________________________________________ 1984-44 Log #21 FAE-RPE _______________________________________________________________________________________________ David V. Haston, USDA Forest Service 1984-1a Revise text to read as follows: 8.4.5.1(2) The specimen shall be repositioned to achieve the maximum haze value within the area defined in 8.9.5.1(1) 8.4.5.1(1). Incorrect reference.

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_______________________________________________________________________________________________ 1984-45 Log #22 FAE-RPE _______________________________________________________________________________________________ David V. Haston, USDA Forest Service 1984-1a Revise text to read as follows: The total time required to remove the respirator from the protective storage device, if applicable; don the respirator; and perform a fit check, if applicable; shall be recorded and reported. The total time required to remove the respirator from the protective storage device if applicable, don the respirator, and perform a fit check if applicable, shall be used to determine pass or fail performance. The TCC directed the TC to more clearly state that the required to remove the respirator from the protective storage device be included in the overall donning time. The TC revised the text as follows: 8.5.5 The total time required to remove the respirator from the protective storage device, if applicable; assemble any respirator components, if applicable; don the respirator; and perform a user seal check, if applicable; shall be recorded and reported. 8.5.6.1 The total time required to remove the respirator from the protective storage device if applicable; assemble any respirator components, if applicable; don the respirator; and perform a user seal check, if applicable; shall be used to determine pass or fail performance. The TCC’s recommendation was adopted and additional language was added for clarity. _______________________________________________________________________________________________ 1984-46 Log #23 FAE-RPE _______________________________________________________________________________________________ David V. Haston, USDA Forest Service 1984-1a, 1984-40, Log #37 Revise text to read as follows: Prior to testing, the test subject shall be trained to don the respirator in accordance with the respirator manufacturer’s instructions. For respirators with a protective storage device, the test subject shall remove the respirator from the protective storage device before donning the respirator. PAPRs shall be tested with the blower turned off. New 8.5.4.2: Proposal was accepted during the ROP but not incorporated. New 8.5.4.3: The TCC directed the TC to clarify PAPR “blower on” versus “blower off” condition for this test. The TC revised the text as follows: 8.5.4.1 Prior to testing, the test subject shall be trained to remove the respirator from the protective storage device, if applicable; assemble any respirator components, if applicable; don the respirator; and perform a user seal check, if applicable; in accordance with the respirator manufacturer’s instructions. 8.5.4.2 PAPRs shall be tested with the blower turned off. 8.5.4.3 For respirators with a protective storage device, the test subject shall remove the respirator from the protective storage device before donning the respirator. 8.5.4.4 The test subject shall don the respirator in accordance with the manufacturer’s instructions. 8.5.4.5 For respirators with a tight-fitting respirator inlet covering, the test subject shall perform a user seal check to confirm that the respirator is adequately sealed to the test subject’s face. The TCC’s recommendation was adopted, additional language was added for clarity, and the paragraphs were restructured.

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_______________________________________________________________________________________________ 1984-47 Log #48 FAE-RPE _______________________________________________________________________________________________ Geoffrey Betsinger, 3M 1984-1a Revise text to read as follows: User seal check is the correct term for this procedure. The time required to remove the respirator from the protective storage device, if applicable; don the respirator; and perform a user seal fit check, if applicable; shall be recorded and reported. The time required to remove the respirator from the protective storage device if applicable, don the respirator, and perform a user seal fit check if applicable, shall be used to determine pass or fail performance User seal check is the OSHA accepted term.

_______________________________________________________________________________________________ 1984-48 Log #7 FAE-RPE _______________________________________________________________________________________________ Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment, 1984-40 The TCC directs the TC to modify the text of 1984-40 (Log #37) to more clearly state that the time required to remove the respirator from its protective storage device be included in the overall donning time calculation. The TCC advises that the reference should refer to 8.5.1.4 and 8.5.6.1 respectively. This is a direction from the Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment in accordance with 3.4.2 and 3.4.3 of the Regulations Governing Committee Projects. See Committee Actions taken on 1984-45 (Log #22) and 1984-46 (Log#23). _______________________________________________________________________________________________ 1984-49 Log #24 FAE-RPE _______________________________________________________________________________________________ David V. Haston, USDA Forest Service 1984-1a PAPRs shall be tested with the blower turned on. Clarify PAPR "blower on" versus "blower off" condition for this test.

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_______________________________________________________________________________________________ 1984-50 Log #25 FAE-RPE _______________________________________________________________________________________________ David V. Haston, USDA Forest Service 1984-1a Revise text to read as follows: 8.6.5.6.3 Where the calculated sample standard deviation of the test score is ≥ 10.0. the test shall be invalidated and the procedures of 8.6.5.2 through 8.6.5.6.6 8.6.5.6.2 shall be used. Incorrect reference. Revise 8.6.5.6.3 to read: Where the calculated sample standard deviation of the test score is ≥ 10.0. the test shall be invalidated and the procedures of 8.6.5.2 through 8.6.5.6.6 8.6.5.6.2 shall be used repeated. Text was revised for clarity. _______________________________________________________________________________________________ 1984-51 Log #8 FAE-RPE _______________________________________________________________________________________________ Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment, 1984-41 The TCC advises that the reference should refer to 8.5.1.4 and 8.5.6.1 respectively. This is a direction from the Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment in accordance with 3.4.2 and 3.4.3 of the Regulations Governing Committee Projects. The referenced paragraphs and content were deleted. Paragraph 8.5.1.4 does not exist in the ROP document, and paragraph 8.5.6.1 is not related to the proposal. _______________________________________________________________________________________________ 1984-52 Log #9 FAE-RPE _______________________________________________________________________________________________ Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment, 1984-64 The TCC directs the TC to review its action taken on Log 23 and verify that the action taken is as intended and correct. This is a direction from the Technical Correlating Committee on Fire and Emergency Services Protective Clothing and Equipment in accordance with 3.4.2 and 3.4.3 of the Regulations Governing Committee Projects. This NIOSH test method was removed by ROP Log #CP8.

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_______________________________________________________________________________________________ 1984-53 Log #26 FAE-RPE _______________________________________________________________________________________________ David V. Haston, USDA Forest Service 1984-1a Revise text to read as follows: Gas and vapor testing: Protection against the following gases and vapors: Carbon monoxide, Oorganic vapors, Fformaldehyde, Aacrolein, Ssulfur Ddioxide, and Nnitrogen Ddioxide. Capitalization should be consistent.

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