NFPA Encourages Public Participation

The National Fire Protection Association, an international nonprofit safety advocacy organization, was established in 1896 after representatives of sprinkler and fire insurance companies gathered in Boston. They were worried about the possibility of sprinkler system failures because of variations in piping sizes and sprinkler spacing that could be found within 100 miles of the city. That small group developed what came to be known as the NFPA 13 Standard for the Installation of Sprinkler Systems.

Today NFPA, based in Quincy, Mass., has responsibility for 300 codes and standards and has more than 75,000 members in 100 countries. While it is a highly structured organization with very formal procedures, NFPA encourages public participation by non-members. Anyone can become involved in the process of making and revising standards.

NFPA, according to its mission statement, strives to reduce the worldwide burden of fire and other hazards on the quality of life by providing and advocating consensus codes and standards, research, training and education.
The organization has more than 200 technical code and standard development committees with over 6,000 volunteer members. The NFPA’s fire service volunteers have expertise in a wide range of areas, from fire apparatus and ambulances to personal protective equipment and thermal imagers. They vote on proposals and revisions to standards in a formal process that is accredited by the American National Standards Institute (ANSI).
Voluntary Standards

Often the question is asked whether NFPA standards are mandatory requirements for fire departments to follow. The answer is no, unless the standards have been officially adopted by local or county officials or a state legislature.
NFPA standards are voluntary compliance standards and are not legally enforceable. However, NFPA standards are consensus based and recognized as national standards of care. They have been cited in courts as minimum levels of care that would be exercised by reasonably prudent professionals or manufacturers.

Another question frequently asked is how equipment gets certified by NFPA. The short answer is nothing is certified by NFPA. The official answer is, “The NFPA does not approve, inspect, or certify any installations, procedures, equipment, or materials; nor does it approve or evaluate testing laboratories.” 

Products and equipment that meet NFPA standards are certified by independent testing laboratories, and those testing organizations provide the “certification.”

There seems to be some confusion about new requirements that become part of a revised standard and whether they are applicable to existing equipment. NFPA standards are revised regularly, but are not retroactive. A revised standard is applicable only to new equipment manufactured after the standard’s effective date. In-service equipment, manufactured to previous editions of an NFPA standard, need only meet the requirements of the standard that was in effect at the time the equipment was made.

In the NFPA codes and standards development process, NFPA technical committees with their volunteer members serve as the principal consensus bodies responsible for developing and regularly updating all codes and standards.

Technical Committees

Committees are appointed by the Standards Council, the overseer of the NFPA codes and standards development process. Technical committees typically consist of no more than thirty voting members representing a balance of interests. NFPA membership is not required to participate on technical committees, and appointments are based on such factors as technical expertise, professional standing, commitment to public safety and the ability to bring to the table the point of view of a category of interested people or groups.

Each technical committee must reach a consensus in order to take action on an item. The committees represent a balance of affected interests, with no more than one-third of the committee from any single interest category. The interest categories are:

1. Manufacturer (M): A representative of a maker or marketer of a product, assembly or system that is affected by the standard.
2. User (U): A representative of an entity that is subject to the provisions of the standard or that voluntarily uses the standard.
3. Installer/Maintainer (IM): A representative of an entity that is in the business of installing or maintaining a product, assembly or system affected by the standard.
4. Labor (L): A labor representative or employee concerned with safety in the workplace.
5. Applied Research/Testing Laboratory (RT): A representative of an independent testing laboratory or independent applied research organization that promulgates and/or enforces standards.
6. Enforcing Authority (E): A representative of an agency or an organization that promulgates and/or enforces standards.
7. Insurance (I): A representative of an insurance company, broker, agent, bureau or inspection agency.
8. Consumer (C): A person who is or represents the ultimate purchaser of a product, system or service affected by the standard, but who is not included in (2).
9. Special Expert (SE): A person not representing (1) through (8) who has special expertise in the scope of the standard.

All NFPA codes and standards are revised and updated every three to five years in revision cycles that normally take approximately two years to complete. The process contains five basic steps leading to issuance of an NFPA committee standard, also called a document.

Call For Proposals

The revision cycle begins with a Call for Proposals, a public notice asking for any interested party to submit specific written proposals on an existing standard or a committee-approved new draft document. A proposal form is available on NFPA’s Web site and in every published code and standard.

Public participation is encouraged. Anyone who has an interest in an NFPA code or standard can submit proposals for change.

Report On Proposals

Following the call for proposals period, the responsible technical committee holds a meeting to consider and act on submitted proposals. The committee may develop its own proposals. A Report on Proposals (ROP) is prepared containing all the proposals and the committee’s action on each one.

The ROP is submitted for committee approval by a formal written ballot. If the ROP is not approved, it is returned to the committee for further consideration. If it is approved, the ROP is published in a compilation of Reports on Proposals issued by NFPA twice yearly for public review and comment.

Reports on Proposals are sent free of charge to all who submitted proposals and to each respective committee member, as well as anyone who requests a copy. All ROPs are available for free downloading.

Report On Comments

Once the ROP becomes available, there is a 60-day public comment period. The committee reconvenes at the end of the comment period and acts on all public comments. The committee may develop its own comments.

As before, written ballot approval is required on all committee actions.  All of this information is compiled into a second report, called the Report on Comments (ROC), which is published and made available for public review for a seven-week period.

The ROCs are also sent free of charge to anyone who wants a copy and are available for free downloading.

Association Meeting 

The process of public input and review does not end with the publication of the ROP and ROC. There is a further opportunity for debate and discussion through the Association Technical Meeting that takes place at the NFPA Conference & Expo each June. 

The Association Technical Meeting provides an opportunity for NFPA members to amend the technical committee reports (the ROPs and ROCs) on each proposed new or revised document.

If no amendments are offered, the document is not placed on the agenda for the Association Technical Meeting. Instead, it is sent directly to the Standards Council for issuance as a consent document.

Standards Council

One of the primary responsibilities of the NFPA Standards Council is to act as the official issuer of all NFPA codes and standards. When it convenes to issue NFPA documents, it also hears any appeals related to the document.
Appeals are an important part of assuring that all NFPA rules have been followed and that due process and fairness have been upheld throughout the codes and standards development process. The council considers appeals both in writing and through the conduct of hearings at which all interested parties can participate.

After deciding appeals, the council, if appropriate, issues a document as an official NFPA code or standard, which takes effect 20 days later. The Standards Council’s decision is subject only to limited review by the NFPA Board of Directors.
NFPA’s most recent project is developing a national standard for ambulances because there is no national standard that addresses ambulance safety.

There is a federal specification document KKK-1822, often referred to as the “Triple K Spec.” The Triple K document was never intended to be a safety standard or a national standard for ambulances. It was developed for the single purpose of providing purchasing criteria for federal government agencies. Because no other document existed, the Triple K specification became a so-called “standard” by default.

NFPA got involved in developing an ambulance standard after the Standards Council received a letter of request to start a new project. The Council considered the request, asked for public input and received overwhelming support.

Today a new committee is at work, representing various interests of the emergency medical services and ambulance industry. Committee members are using the KKK-1822 specification and the NFPA 1901 Standard for Automotive Fire Apparatus as starting material in the development of a new ambulance standard.

NFPA has always been thought of as an organization that provided standards related to fire, but NFPA has evolved to include broader areas for all emergency services.

Editor’s Note: Larry Stewart, who has a bachelor’s degree in mechanical engineering, was a firefighter for 11 years before joining the NFPA, where he has worked for 15 years. He is in the organization’s Public Fire Protection Division and serves as staff liaison to the Fire Department Apparatus Technical Committee, as well as committees for fire hose, fire department ground ladders, public emergency communications and the new ambulance standard.

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