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August 28, 1997

MEMORANDUM FOR:         BILL KILLEN, Director
                       Navy Fire and Emergency Services

FROM:                   JOHN E. PLUMMER, Director
                       Office of Federal Agency Programs

SUBJECT:                Fire Fighter Personal Protective Clothing 
                       Issues

This is in response to your memo of August 7 on fire fighter Personal Protective Equipment (PPE). First, let me re-emphasize OSHA's position on proximity fire fighting clothing. NFPA standard 1500 "Fire Department Occupational Safety and Health Program", 1992 edition, paragraph 5-1.1 specifies that "The fire department shall provide each member with the appropriate protective clothing and protective equipment to provide protection from the hazards to which the member is or is likely to be exposed. Such protective clothing and protective equipment shall be suitable for the tasks that the member is expected to perform." Therefore, if the primary job of the fire fighter is proximity fire fighting, then proximity protective clothing and equipment needs to be used. Further, NFPA 1971 and NFPA 1976 both specify that when radiant heat is a hazard, proximity protective equipment is to be used (see paragraph 1-3 in each standard.

I'll answer each of your scenarios in the order that you presented them:

a. Airfield rescue fire fighting personnel respond and participate in structural fire fighting operations. They are wearing proximity protective clothing meeting NFPA 1976 standard on protective clothing for proximity fire fighting.

• This is acceptable as protective clothing meeting NFPA 1976 standard requirements exceeds that required for NFPA 1971 standard requirements.

b. Fire Fighter Jones is assigned to work overtime at the airfield fire station on his day off. He wears structural fire fighting protective clothing meeting NFPA 1971 standard on protective clothing for structural fire fighting.

• This would be citable as Jones is expected to perform aircraft rescue and fire fighting.

c. Structural fire fighting personnel respond and participate in bulk petroleum fire fighting operations. They are wearing PBI kevlar protecting clothing meeting NFPA 1971 standard on protective clothing for structural fire fighting.

• This would also be citable as it does not meet the requirements of NFPA 1976 where the hazard is radiant heat. See NFPA 1976, paragraph 1-3 under approach fire fighting and NFPA 1971, paragraph 1-3, under approach clothing. Both standards state that the protective clothing must be designed to provide protection from radiant heat.

d. Structural fire fighting personnel respond to a helicopter crash wearing NFPA 1971 standard protective clothing for structural fire fighting.

• In an emergency situation where a crash occurs and the closest responders are structural, no citations would be issued. The same would be true for a city fire company that responded to a crash in the local community. The key is that proximity fire fighting is not their primary duty.

e. Crew Chief Smith works a significant amount of overtime each month, rotating between airfield and structural fire apparatus. His protective coat complies with NFPA 1976 standard on protective clothing for proximity fire fighting and his protective trousers comply with NFPA 1971 standard for structural fire fighting.

• This practice violates both NFPA 1971 and NFPA 1976 standards. However, because NFPA 1976 standard requirements exceed those of NFPA 1971, this would not be cited for structural (fire) fighting.

f. Fire Chief Tradition rotates firefighter personnel once each year between the structural and airfield fire apparatus. All personnel are issued protective clothing that complies with NFPA 1976 standard on protective clothing for proximity fire fighting.

• Again, this meets or exceeds the requirements of NFPA 1971, so no problem.

g. Fire Chief Non-Tradition rotates firefighter personnel every 90 days between structural and airfield fire stations. All personnel are issued protective clothing that complies with NFPA 1971 standard on protective clothing for structural firefighting.

• The key to this whole issue is the primary job. If the primary job is proximity fire fighting, then PPE must comply with NFPA 1976. So those that rotate to airfield duty every 90 days must be provided with proximity gear that complies with NFPA 1976.

h. Emergency medical technicians respond to all emergencies, including fires in buildings and aircraft and are often involved in fire fighting operations. All EMT personnel are issued protective clothing that complies with NFPA 1976 standard on protective clothing for proximity fire fighting.

• No problem, by meeting the NFPA requirement for proximity fire fighting they meet or exceed the requirements of NFPA 1971 for structural PPE. You must be careful here not to violate the requirements for protective clothing for medical personnel as stated in NFPA 1999, Standard on Protective Clothing for Emergency Medical Operations.