NFPA Compliance Requires Certified Third-Party Testing
Keeping It Safe
By Robert Tutterow
Fire Apparatus & Emergency Equipment Magazine
The only true indication that personal protective equipment (PPE) is compliant is a third-party certifying mark with the appropriate language on the product label.
Some statements — such as National Fire Protection Association (NFPA) approved or meets the performance requirements of NFPA or built in accordance with NFPA standards or meets the relevant portions of NFPA standards or laboratory tested — do not necessarily mean the PPE product is compliant.
It's important to keep in mind that NFPA does not approve anything, as it has no testing laboratories. Through NFPA, standards are written for PPE that include design, performance and testing requirements. It is the third-party certifying agency that tests the products to ensure they are compliant with the NFPA standard.
NFPA compliance is a re-emerging issue as the fire service is beginning to see more PPE products enter the market that are not NFPA compliant. Not since the late 1980s has the topic been so much at the forefront. It was then that third-party certification became a requirement. Before that time, any manufacturer could claim compliance without verification.
Today, the issue has again arisen as more products come to the United States from other countries. With abundant cheap labor outside the U.S. and the very high cost of PPE in the U.S., the market for less expensive products naturally leads to foreign competition. The products most likely to have suspicious NFPA compliance are gloves and hoods. However, turnout gear and other PPE products have recently arrived in small numbers.
An incident occurred in my area earlier this year when a firefighter received burns while participating on a live-burn training exercise. The officers on the scene did not think he was in an environment where burns should have occurred. The element of the PPE ensemble was isolated and sent to third-party experts for evaluation. The evaluation determined that the product did not have the proper labeling. Other occurrences of the product element causing burns have also been reported. Examinations of the product indicated the thermal protective components of the element had actually melted. This is a product that is being sold and marketed as being NFPA compliant. It is cheaper than competitive products and feels great when being worn in a non-hostile environment. Remember, what feels good on the trade show floor may not perform when "the wet stuff meets the red stuff."
NFPA PPE standards have lengthy requirements for third-party certification. In fact, the third-party certification requirements are a significant cost of PPE. Who pays for a product to be third-party certified? The manufacturer pays the cost. Who pays the manufacturer? You guessed it.
Strict Guidelines
Not only must the products be third-party certified, but the third-party certifiers must follow strict guidelines. For example, the certifying party must be "accredited for personal protective equipment in accordance with ISO Guide 65, General requirements for bodies operating product certification systems. The accreditation shall be issued by an accreditation body operating in accordance with ISO 17011, General requirements for accreditation bodies accrediting conformity assessment bodies."
Currently, there are two agencies certifying products that meet this requirement. They are Underwriters' Laboratories (UL) and Safety Equipment Institute (SEI).
Buyers should know that not all testing agencies and laboratories are qualified to be third-party certifying agencies. If the agency is not one of the two listed above, fire departments should take time to investigate and validate claims of compliance.
Laboratory Facilities
To learn about the requirements of a third-party testing agency, use NFPA 1971 — the Standard on Protective Ensembles for Structural Firefighting and Proximity Firefighting for an illustration. The certification organization must have laboratory facilities and equipment available for conducting proper tests to determine product compliance. It must have the capability to calibrate all its instrumentation in accordance with the requirements of ISO 17025, General requirements for the competence of testing and calibration laboratories.
There are strict controls on documentation and training and qualifications of staff members. The certification organization is responsible to assure the manufacturer has a quality assurance program and must continually audit the program. The certification organization shall require the manufacturer to have a product recall system specified as part of the manufacturer's quality assurance program.
Follow-Up Inspections
The organization must work with the manufacturer to make sure that any changes to the PPE do not affect the form, fit or function of the certified product. The certifier must perform a follow-up inspection program of the manufacturer. This includes at least two unannounced random visits within a 12-month period to verify compliance. During these visits, the certifying organization must select sample compliant products from the manufacturer's production line, in-house stock, or from the open market to verify compliance is still being maintained.
If for some reason the organization's findings indicate there may be problems with the compliance, then more frequent testing is required. The certifier must have procedures to address reports of compliant products creating a hazard. And, the certifying organization must be in a position to use legal means to protect the integrity of its name and its label.
The Label
The label of the PPE product is very important. All compliant products must be labeled and listed. The certification organization's label, symbol, or identifying mark must be part of the product label or attached to the product label or be immediately adjacent to the product label.
If a fire department has concerns about product certifications, it should:
• Check for the third-party organization's mark.
• Check the third-party organization's Web site or give it a call.
• Contact NFPA if there are difficulties identifying the mark or questions about the way the compliance is being presented.
• Notify state attorney general offices if problems are discovered as product misrepresentation is prosecutable.
If you have questions and safety concerns about PPE products that are definitely NFPA compliant, they should be immediately reported to the manufacturer and the third-party certification organization. Simply contacting your local dealer or distributor is not enough.