NIOSH NPPTL has issued two letters to all interested parties regarding the incorporation of NFPA 1986 Standards into policy statements.

Incorporation of National Fire Protection Association (NFPA) 1986, Standard on Respiratory Protection Equipment for Tactical and Technical Operations, 2017 edition into NIOSH policy statement on “Evaluation and Acceptance of Emergency Breathing Support Systems (EBSS) incorporated into SCBA Approvals”

Copy of Official Letter

Letter to All Interested Parties

May 9, 2017

The National Institute for Occupational Safety and Health (NIOSH) is updating its policy statement on “Evaluation and Acceptance of Emergency Breathing Support Systems (EBSS) incorporated into SCBA Approvals.”

This policy change is being made coincident with the addition of requirements related to the use and operation of these devices in the National Fire Protection Association (NFPA) 1986, 2017 edition, Standard for SCBA used in Tactical and Technical Operations. This letter serves as the policy change modifying the above-referenced NIOSH policy statement to incorporate Self-Contained Breathing Apparatus (SCBAs) meeting the requirements of NFPA 1986:2017, or subsequent editions, as part of the current policy statement.

Consistent with the National Technology Transfer and Advancement Act of 1995 and OMB Circular A-119, NIOSH participated in the NFPA consensus standards development process for NFPA 1986. Adoption of NFPA 1986 into the above-referenced policy statements meets the intent of this act.

This policy change is applicable only to SCBAs meeting the requirements of NFPA 1981:2013, or subsequent editions, along with those meeting the newly established requirements of NFPA 1986:2017, or subsequent editions. NIOSH will recognize NFPA 1981:2013 compliant EBSS systems and NFPA 1986:2017 compliant EBSS systems as a part of the NIOSH SCBA approval for users who have received the appropriate level of training. Users will be able to identify approvals for SCBAs which incorporate the required hardware by the explicit listing of an additional EBSS statement to the standard cautions and limitations on the NIOSH approval label. The statement will signify the EBSS components have been evaluated by NIOSH and accepted as meeting the requirements for EBSS under the requirements of either NFPA 1981:2013, or NFPA 1986:2017, or subsequent editions.

Background

Based upon a review of submissions made to the NIOSH Docket (Docket # 147), as well as the applicable Occupational Safety and Health (OSHA) standards, NIOSH has modified the existing “Buddy Breather” policy to further support and encourage best practices in the fire service for the deployment of EBSS. Accessories available on some manufacturers’ products enable users to have the option to provide buddy breathing.

Recognition of these practices and use of EBSS conforming to the newly developed NFPA 1986:2017 standard provides a framework for use in tactical or technical applications. NIOSH recommends that these users also follow guidance developed for firefighters and to formally incorporate best practices used in fire departments for the maintenance and use of EBSS and development of “Buddy Breathing” training programs conforming to NFPA Standards 1404, Fire Service Respiratory Protection Training and 1500, Fire Department Occupational Safety and Health Program, which will further address cautions and limitations associated with the use of EBSS in future editions. Until such time that the personnel training requirements of NFPA 1404 and the Occupational Safety and Health Program requirements of NFPA 1500 are revised to address EBSS maintenance and use, NIOSH will require the manufacturer User Instructions to provide training information.

Those making application for NIOSH approval are advised of the following minimum requirements:

Additional standards:

In order to be evaluated for incorporation into SCBA approval, EBSS systems must be incorporated into SCBA configurations found to be conforming to NFPA 1986:2017, by a certification organization accredited for personal protective equipment in accordance with ISO/IEC 17065:2012, Requirements for bodies certifying products, processes and services, currently Safety Equipment Institute (SEI).

Additional testing:

All components of the EBSS must be able to operate at the specified low temperature limit without adversely affecting the operation of the SCBA, as determined by testing conducted in accordance with NIOSH Standard Testing Procedure Number TEB-CBRN-ASR-STP-0219.

At the minimum activation pressure with the EBSS receiver line held open to atmosphere, the donor unit must be able to meet pressure-demand performance requirements through the remainder of the air supply as determined by testing in accordance with NIOSH Standard Testing Procedure Number TEB-CBRN-ASR-STP-0220.

Starting from a full cylinder and prior to the minimum End-of-Service-Time-Indicator (EOSTI) activation pressure, the EBSS donor/receiver line will be opened to atmosphere and held open. The duration for which the host unit performance meets pressure-demand performance requirements, as determined by testing in accordance with NIOSH Standard Testing Procedure Number TEB-CBRN-ASR-STP-0220, will be measured and recorded.

Additional cautions and limitations:

The approval label must include this additional caution and limitation statement (statement EBSS):

EBSS Activation or engagement of EBSS in either the donor or receiver mode changes the SCBA use to Escape-Only. Approved service time as listed on the NIOSH approval label for either the donor, or the receiver is no longer applicable. Additional critical cautions and limitations apply. Refer to section EBSS in the SCBA User Instructions.

At a minimum, these additional caution and limitation statements must appear in section EBSS of the SCBA User Instructions, (similar to the statements appearing in the User Instructions with caution and limitation statement S).
•EBSS may not be engaged or activated in donor mode after the donor EOSTI has activated. a
•Users must be fully trained in the operation of EBSS in accordance with a training program conforming to the requirements of NFPA Standards 1404 Fire Service Respiratory Protection Training and 1500 Fire Department Occupational Safety and Health Program.
•Simultaneous connection of more than two users, (one donor, and one receiver), is not permitted.

General application information:

All approval application(s) shall: 1) be submitted concurrently to NIOSH (Records Room) and
SEI and 2) include a completed application package for each SCBA respirator model for which approval is requested. NIOSH submittals must conform to the requirements outlined in the Standard Application Procedure. Standard SCBA approval fees are applicable to each new approval sought. Consultations with NIOSH are available and encouraged prior to submitting an application to enable an accurate determination of required test hardware to be made. Your effort in following these procedures will assist NIOSH and SEI in ensuring an orderly approval process.

We hope this information is helpful to you. Please feel free to contact Robert Stein at, 412-386-6889 or by email at rstein@cdc.gov if you have any questions.

Sincerely yours,

David Chirdon
Chief, Conformity Verification and Standards Development Branch
National Personal Protective Technology Laboratory

Incorporation of National Fire Protection Association (NFPA) 1986, Standard on Respiratory Protection Equipment for Tactical and Technical Operations, 2017 edition into NIOSH Self-Contained Breathing Apparatus (SCBA) policy statement on “Acceptance of Applications for the Testing and Evaluation of Self-Contained Breathing Apparatus for Use against Chemical, Biological, Radiological and Nuclear Agents”

Copy of Official Letter

Letter to All Interested Parties

May 9, 2017

The National Institute for Occupational Safety and Health (NIOSH) is updating its policy statement on “Acceptance of Applications for the Testing and Evaluation of Self-Contained Breathing Apparatus for Use Against Chemical, Biological, Radiological and Nuclear Agents.”

This policy change is being made coincident with the addition of requirements related to the use and operation of these devices in the National Fire Protection Association (NFPA) 1986, 2017 edition, Standard for SCBA used in Tactical and Technical Operations. This letter serves as the policy change modifying the above referenced NIOSH policy statement to incorporate SCBAs meeting the requirements of NFPA 1986:2017, or subsequent editions as part of the current policy statement.

Consistent with the National Technology Transfer and Advancement Act of 1995 and OMB Circular A-119, NIOSH participated in the NFPA consensus standards development process for NFPA 1986. Adoption of this standard into the above referenced policy statement meets the intent of this act.

This letter informs applicants of additional requirements that a SCBA will be evaluated against prior to receiving NIOSH approval and provides the procedures for submitting applications. When first announced in 2001, the need to meet requirements for the CBRN protection level was voluntary in both the NFPA and the NIOSH approval processes, as specified in Attachment A to the 2001 CBRN policy statement. However, in the 2007 revision to NFPA 1981, the requirement for SCBA to obtain CBRN-level approval was made a mandatory part of NFPA 1981. This requirement also holds true for NFPA 1986:2017. As a result, all NFPA 1981 or 1986 approvals will require compliance with the additional CBRN requirements.

Background

In April 2000, NIOSH entered into a Memorandum of Understanding with the National Institute for Standards and Technology (NIST), the Occupational Safety and Health Administration (OSHA), and the National Fire Protection Association (NFPA) to jointly work on developing standards for all types of counterterrorism equipment. NIOSH and NIST initiated Interagency Agreements with the U.S. Army Edgewood Chemical Biological Center (ECBC) (which at that time was the U.S. Army Soldier and Biological Chemical Command (SBCCOM)) for development of respiratory protection standards, test procedures, and laboratory support. The new procedures for SCBA certification were consistent with the guidance of the Federal Emergency Management Agency (FEMA) and NFPA, which called for the use of SCBAs when hazards are unknown (i.e., within the first hours of an event).

NIOSH initiated its voluntary approval program pursuant to 42 CFR Parts 84.60(b) and 84.63(c). These sections provide NIOSH with the authority to issue approvals for respirators not specifically addressed in Part 84 and to develop additional requirements that the agency determines are “necessary to establish the quality, effectiveness, and safety of any respirator used as protection against hazardous atmospheres.” NIOSH has continued to conduct that program issuing special approvals and approval labels identifying the SCBA as appropriate for use against CBRN agents.

Summary of the CBRN Requirements for Approval

The minimum requirements for CBRN-level protection determinations made by NIOSH are as follows:

  • Requirements for approval of an SCBA under 42 CFR Part 84. Approval under 42 CFR Part 84, Subpart H, demonstrates that the SCBA is approved for industrial usage and requires the applicant to maintain a quality control program and documentation for the SCBA in accordance with Part 84.
  • Requirements for compliance of an SCBA with the National Fire Protection Association (NFPA) 1981 or NFPA 1986. In the 2001 announcement notifying all interested parties of NIOSH’s intent to accept applications for the testing and evaluation of SCBA for use against CBRN agents, it was stated that certification by the NFPA demonstrates that the SCBA can meet the flame, heat, and other requirements of NFPA 1981 that are important for protection against hazards that may be present for first responders to a terrorist incident. In the time that has passed since the first CBRN certification program for SCBA was announced, the NFPA 1981 Standard on Open-Circuit Self-Contained Breathing Apparatus for Fire and Emergency Services was modified to require CBRN protection to be present in all NFPA 1981 compliant SCBA. As a result, what started as a three-stage process of approval has, through the cooperation of NIOSH and the Safety Equipment Institute (SEI), become a two-stage process. The two-stage process developed for NFPA 1981 will be used to issue NFPA 1986 approvals. While the technical requirements of NFPA 1986 do not demand the same level of fire “hardening” that NFPA 1981 requires, NFPA 1986 still addresses and assures other critical SCBA performance aspects. NIOSH expects that terrorist incident first responders who will rely upon NFPA 1986 approved apparatus will be acting within the same capacities that they normally do and will therefore benefit from the differences in protective capability that have been called for and developed as the basis for NFPA 1986. The more modest fire hardening required in NFPA 1986 has been incorporated to assure protection against the kind of brief, but possibly intense, flame and heat hazards that could occur in a chaotic, uncontrolled environment of a terrorist incident. It is not intended to protect users engaged in active fire suppression; that requirement is achieved through the thermal protection offered by SCBA approved to NFPA 1981. In spite of the fact that the protection from thermal hazards is different, both NFPA 1981 and NFPA 1986 approved SCBA will provide the same high levels of respiratory protection from all threats, including the same level of protection against CBRN respiratory threats.
  • Additional standards for special tests associated with resistance of chemical penetration and permeation and quantitative laboratory protection levels. Additional standards for special tests associated with resistance of chemical penetration and permeation and quantitative laboratory protection levels are required. NIOSH has determined that the vulnerabilities of SCBAs to CBRN agents necessitate two additional special tests. Test criteria have been developed to assess the extent to which the components and materials of the SCBA can be penetrated and permeated if the wearer is in a hazardous chemical environment for an extended period. The penetration/permeation test procedures and protocol are provided on the NPPTL web site, Procedure Number RCT-CBRN-STP-0200, 0201. The laboratory respirator protection level test assesses the respirator’s ability to fit a wide range of facial dimensions. The test procedure is provided on the NPPTL web site, Procedure Number TEB-CBRN-APR-STP-0352.

General Application Information

Application procedures for CBRN respirators are included in the “Standard Application Procedure for the Approval of Respirators Under 42 CFR 84.”

All approval application(s) shall: 1) be submitted concurrently to NIOSH (Records Room) and the Safety Equipment Institute (SEI) and 2) include a completed application package for each SCBA respirator model for which approval is requested. NIOSH submittals must conform to the requirements outlined in the Standard Application Procedures. Standard SCBA approval fees are applicable to each new approval sought. Consultations with NIOSH are available and encouraged prior to submitting an application to enable an accurate determination of required test hardware to be made. Your effort in following these procedures will assist NIOSH and SEI in ensuring an orderly approval process. Applications will be processed in the order in which they are received by NIOSH. NIOSH will process CBRN SCBA applications as a priority.

Reference Notification to Users and Regulatory Agencies

NIOSH will continue to maintain and disseminate an approval list for the SCBAs approved under this program. This list will be a prominent part of the Certified Equipment List (CEL), and will contain the name of the approval holder, model, component parts, accessories, and rated durations.

Respirator Identification/Labeling

NIOSH will authorize the use of an additional approval label on apparatus that demonstrate compliance to the CBRN criteria. This label is to be placed in a visible location on the SCBA backplate, e.g., on the upper corner or in the area of the cylinder neck. The addition of this label will provide visible and easy identification of equipment for its appropriate use. 

We hope this information is helpful to you. Please feel free to contact Robert Stein at 412-386-6889 or by email at rstein@cdc.gov if you have any questions.

Sincerely yours,

David Chirdon
Chief, Conformity Verification and Standards Development Branch
National Personal Protective Technology Laboratory

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