Apparatus

Reviewing The Need For Product Certification

Issue 3 and Volume 12.

Product certification has quietly emerged as a major component of fire service products, especially personal protective equipment (PPE). With its far-reaching implications, it is amazing how quietly this has occurred. Nothing has driven the rising cost of products more than certification. That is not a statement for or against certification, just a fact.

Product certification has enormous implications for just about everything we do in the fire service. Let’s look at what certification means. The dictionary defines certification as: “to attest as being true or as represented or as meeting a standard.”

This is where the rubber meets the road, as our PPE products are (or should be) certified to a National Fire Protection Association (NFPA) standard. I feel compelled to say that you should NEVER purchase or use PPE that is not certified to NFPA standards. There are PPE products on the market today that are not certified, such as firefighter gloves.

The NFPA PPE project defines certification/certifying its standards as: “a system whereby a certification organization determines that a manufacturer has demonstrated the ability to produce a product that complies with the requirements of this standard, authorizes the manufacturer to use a label on listed products that comply with the requirements of this standard, and establishes a follow-up program conducted by the certification organization as a check on the methods the manufacturer uses to determine continued compliance of labeled and listed products with the requirements of this standard.”

For self-contained breathing apparatus (SCBA), National Institute for Occupational Safety and Health (NIOSH) certification is also required.

Here is an excellent case study of the implications. First, a disclaimer: This study is not a condemnation of the manufacturers mentioned. It is simply a real life demonstration of the certification process as it applies to fire departments.

My department was recently approached about purchasing SCBA cylinders at a considerable cost-saving from Structural Composites Industries (SCI). Our SCBA technician was savvy enough to investigate further before recommending the purchase.

He contacted our manufacturer, Scott Health & Safety, about the certification of our SCBA if we used SCI cylinders. Our units were supplied and certified with Luxfer brand cylinders.

Our SCBA tech was given a letter that Scott had sent to its distributors saying, among other things, that: “…if a fire department purchases a cylinder directly from SCI and deploys it on our self-contained breathing apparatus, it will void all product approvals including NISOH, NFPA and chemical, biological, radioactive and nuclear (CBRN) certifications. In turn, by avoiding the certification of the respirator, it will then additionally void Scott’s warranty on the complete SCBA. This is not solely a position of Scott Health & Safety, but rather meets requirements set forth by the approval agencies that mandate that the SCBA is approved as a complete system as supplied by the respiratory manufacturer. In fact, the use of unapproved parts violates NIOSH and NFPA certifications on any manufacturer’s equipment.”

Scott also submitted a “Respirator User’s Notice,”  dated March 17, 2006, that addresses the issue. The NIOSH notice states: “A NIOSH approval applies only to the specific respirator that is made up of the components included on the NIOSH approval label.”

NIOSH Requirements

When our SCBA technician advised me he had heard a rumor that NIOSH was going to reconsider the cylinder issue, I contacted NIOSH. Their email response stated: “NIOSH requires that any approved respirator be maintained in the approved configuration. Any modification to the configuration will result in a non-approved device. Scott conducts additional test on the assembly containing DOT approved cylinder that becomes a Scott numbered part. The use of the basic cylinder that forms the initial part of the Scott configuration without the Scott approval process is not an acceptable practice.”

That’s enough of the quotes. However, I think it is important the exact wording be furnished rather than paraphrase on a topic of this nature.

The same principle applies to other PPE items. You would not want to replace your helmet goggles with something from the hardware store. If you are even thinking about doing something like that, don’t.

Don’t Modify Turnout Gear

Resist the urge to sew a U.S. flag on your turnout coat, and as tempting as it may be, resist the urge to add kneepads to your turnout pants after you have made your purchase.

If you do any of these, or similar activities, there are ramifications. First, you have modified a product that may cause firefighter injury or death.

Second, you have just provided fodder for a sharp attorney to make money, and that is a whole other story in itself. Why would you want to put yourself, your department and your community in such a position?

The NFPA has taken aggressive steps to make sure PPE products are certified. Each PPE standard has an entire chapter devoted to “Certification.” The association is very concerned about manufacturers using “Slick Sam’s Bail Bond and Certification Agency.”

Agency Accredited

A certification agency must be accredited to International Organization for Standardization Guide 65 which specifies general requirements that a third-party operating a product or service certification system shall meet if it is to be recognized as competent and reliable. Even the accrediting agency must meet ISO requirements.

The certification requirements also include the manufacturer’s quality assurance program, hazards involving compliant products, manufacturers’ investigation of complaints and returns, and manufacturers’ safety alert and product recall systems.

Certification applies to manufacturers of new products. However, the next revision of NFPA 1851-Standard on Selection, Care and Maintenance of Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting, places similar requirements on agencies, including fire departments, that repair turnout gear.

A “verified” Independent Service Provider (ISP) must do repairs. A fire department can be verified, but the verification must come from-you guessed it-a certification organization. This will be a whole new arena for fire departments if they choose to do their own repairs.

So far, only PPE has been discussed. What about fire apparatus? Interestingly, only fire pumps and aerial devices require independent third-party certification. The NFPA apparatus committee is pursuing proposals that will require the manufacturer to advise the purchaser if there is anything non-compliant about the apparatus.

End-User Responsibilities

With all these certification requirements, it is incumbent upon us as end-users to make sure we purchase, use, maintain, and replace our equipment in a manner consistent to which it is designed. Mess around with a product and the manufacturer will wash its hands of any responsibility if an injury or fatality occurs. The burden then becomes solely yours.

As boring and unsexy as product certification is, it has a major impact on our industry and the equipment we use. It is incredibly important to know something about the topic, and you made it through this column with, it is hoped, a little more knowledge.

Editor’s Note: Robert Tutterow, who has nearly 30 years in the fire service, is Charlotte (N.C.) Fire Department’s health and safety officer. He is a member of the NFPA’s technical committees on fire apparatus, serving as the chairperson of the group’s safety task force. He is also a member of the NFPA’s structural firefighting protective clothing and equipment correlating committee.

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