m e m o r a n d u m - nfpa.org 0 abstain 0 eligible to vote: 31 not returned : 11 donald b....

National Fire Protection Association

1 Batterymarch Park, Quincy, MA 02169-7471

Phone: 617-770-3000 • Fax: 617-770-0700 • www.nfpa.org

M E M O R A N D U M

TO: NFPA Technical Committee on Hazardous Materials Protective Clothing

and Equipment

FROM: Yvonne Smith, Project Administrator

DATE: May 27, 2014

SUBJECT: NFPA 1991 FD TC Ballot Circulation (F2015)

The May 21, 2014 date for receipt of the NFPA 1991 First Draft ballot has passed.

The preliminary First Draft ballot results are shown on the attached report.

31 Members Eligible to Vote

11 Ballots Not Returned (Thompson, Greene, Shelton, Buck, Pever, Ott, Kelly, Starrett,

Baxter, North, West)

In accordance with the NFPA Regulations Governing the Development of NFPA Standards,

attached are reasons for negative votes for review so you may change your ballot if you wish.

Abstentions and affirmative comments are also included. Ballots received from alternate members

are not included unless the ballot from the principal member was not received.

If you wish to change your vote, the change must be received at NFPA on or Wednesday, June

4, 2014. Members who have not returned a ballot may do so now. Such changes should be

submitted through the VoteNet Ballot online.

The return of ballots is required by the Regulations Governing the Development of NFPA

Standards.

Eligible to Vote: 31

Not Returned : 11

Donald B. Thompson,Russell R. Greene,Robert E.

Shelton,Ted S. Buck,Kenneth A. Pever,Louis V.

Ott,Bruce S. Kelly,William M. Starrett,Christina M.

Baxter,John W. North,Robert West

Vote Selection Votes Comments

Affirmative 19

Affirmative with Comment 1

Susan L. Lovasic Approve as is.

Negative 0

Abstain 0


Not Returned : 11






Affirmative 19



FR-74, Global Input, See FR-74

Election:1991_FAE-HAZ_FD_Ballot_F2015

Results by Revision


http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/Content/1991-2005.ditamap/2/C1393001848033.xml&viewmode=nfpa/xslt/nfpaviewmode.xsl


Negative 0

Abstain 0


Not Returned : 11






Affirmative 18


Susan L. Lovasic Unclear what exact changes are to be made to the document.

Negative 1



William A. Fithian Deleting all Section/Chapter titles following all cross references is

a highly undesirable action. If accepted, the proposed change will

require the user of the document to waste an incredible amount

of time and effort to refer from one chapter (for instance Chapter

7) to another chapter (for instance Chapter 8) to obtain relevant

information. Including the section/chapter titles also provides a

double check when revisions to the standard are necessary, to

ensure the revised section numbers match the appropriate

performance or testing criteria. This proposed change will impose

an incredible amount of undue burden and add a substantial

amount of time for end users to review and evaluate the

standard. It will also result in losing the ability to maintain each

section or chapter as a stand-alone system.

Abstain 0


Not Returned : 11






Affirmative 19



FR-1, Section No. 1.1.1, See FR-1


Negative 0

Abstain 0


Not Returned : 11






Affirmative 19



Negative 0

Abstain 0


Not Returned : 11






Affirmative 17






Jeffrey O. Stull Additional language is needed in the appendix to indicate how the

standard is currently predicated on the use of NFPA 1981-

compliant SCBA.

Negative 2

James P. Zeigler If it is the intent to the committee to allow non-encapsulating

garment designs in NFPA 1991, then the non-encapsulating

ensembles will have to be tested with each model of respirator

specified by the manufacturer as appropriate with the garment As

such, the standard is restricting and hence specifying aspects of

the respirator as is done in NFPA 1994. IN addition, proposed

6.1.11 restricts the choice of respirators.

Susan L. Lovasic (1) Respiratory protection is not "provided" by the authority

having jurisdiction. That text needs to be removed. (2) Do not

support removing Annex A.1.1.7 as that text is relevant to the

intent of the standard.

Abstain 0


Not Returned : 11






Affirmative 19

FR-4, Section No. 1.2.1 [Excluding any Sub-Sections], See FR-4




Negative 0

Abstain 0


Not Returned : 11






Affirmative 19



Negative 0

Abstain 0


Not Returned : 11






FR-6, Section No. 2.2, See FR-6

FR-5, New Section after 1.3.5, See FR-5



Affirmative 19



Negative 0

Abstain 0


Not Returned : 11






Affirmative 19



Negative 0

Abstain 0


Not Returned : 11














Affirmative 19



Negative 0

Abstain 0


Not Returned : 11






Affirmative 19



Negative 0

Abstain 0



FR-29, Sections 3.3.2, 3.3.3, See FR-29



Not Returned : 11






Affirmative 19



Negative 0

Abstain 0






Affirmative 19



Negative 0

Abstain 0






Not Returned : 11






Affirmative 16


Steven D. Corrado Recommend deleting the term "gas-tight". Gas tight protection is

not specified in the Scope (1.1.1), Purpose (1.2.1), or Application

(1.3.1) of this document.

Jeffrey O. Stull This definition should be updated to indicate that encapsulating

suits provide both vapor and liquid protection.

Negative 1

Susan L. Lovasic No objection to the defintion listed, however I do not support

allowing non-encapsulating suit designs to be permitted in NFPA

1991. See supporting rationale in file "Negative - non-

encapsulating".

Abstain 1

Ulf Nystrom Whereas there may be a point in making the standard less design

restrictive I choose to abstain because I am not convinced that

allowing non-encapsulating ensembles for the top level

protection only means improvements for the users. There may be

disadvantages for example concerning decontamination of the

respiratory protective devices.


Not Returned : 11






Affirmative 19


Negative 1

Susan L. Lovasic I do not support allowing non-encapsulating suit designs to be

permitted in NFPA 1991. See supporting rationale in file

"Negative - non-encapsulating".

Abstain 0


Not Returned : 11






Affirmative 19







Negative 0

Abstain 0


Not Returned : 11






Affirmative 19



Negative 0

Abstain 0


Not Returned : 11






Affirmative 19






Negative 1

Susan L. Lovasic (1) As revised with the use of "or", there could be up to 4

different entities that could qualify as the "manufacturer". (2)

Keep the current definition

Abstain 0


Not Returned : 11






Affirmative 15


Jeffrey O. Stull This definition, taken from NFPA 1992 and NFPA 1994, requires

modification to indicate the basis for providing vapor and liquid

protection.

Negative 3

Philip C. Mann The definition is contradictory, in that it says the ensemble

provides liquid splash protection but not liquid tight protection.



James P. Zeigler There is a clear conflict between this definition of

nonencapsulaitng and the purpose of this standard. This

definition indicates on This defines nonencapsulating as providing

liquid splash protection, but does not provide vapor- or gastight

protection but the purpose of the standard ?(1.2.1) states that

the purpose of the standard is to provide vapor and particle

protection.

Susan L. Lovasic No objection to the defintion listed, however I do not support

allowing non-encapsulating suit designs to be permitted in NFPA

1991. See supporting rationale in file "Negative - non-

encapsulating".

Abstain 1








Not Returned : 11








Affirmative 18


Negative 2

Ulf Nystrom It has not been shown that replacing permeation breakthrough

time with cumulative permeation means any advantages to the

users in terms of a concept that is easier to understand or to

apply e.g. in hazmat response. Further, the suggested use of

cumulative data does not solve the potential problem of

permeation spikes being missed. Some problems could perhaps

be overcome by reporting both cumulative and breakthrough

time and/or increasing sampling frequency but the current

revision does not do this.

Susan L. Lovasic Keep original text. Do not support changing from current

normalized breakthrough time as the permeation test procedure.

See supporting rationale in file "Negative - cumulative

permeation".

Abstain 0


Not Returned : 11








Affirmative 19



Negative 0

Abstain 0


Not Returned : 11






Affirmative 19



Negative 0

Abstain 0




Not Returned : 11






Affirmative 19



Negative 0

Abstain 0


Not Returned : 11








Total Voted : 20



Affirmative 18


Jeffrey O. Stull The referenced section number is wrong. In addition, an appendix

section is needed to explain the type of respiratory equipment

considered acceptable for use with vapor-protective ensembles.

Negative 1

Susan L. Lovasic I believe that the current text should be retained as it is relevant

to this standard.

Abstain 0


Not Returned : 11






Affirmative 19



Total Voted : 20



Negative 0

Abstain 0


Not Returned : 11






Affirmative 17


Negative 2

Steven D. Corrado This new Annex item is contradictory to FI77 where the definition

of non-encapsulating specifically excludes vapor protection.




Abstain 1

Total Voted : 20










Not Returned : 11






Affirmative 19


Negative 1




Abstain 0

Total Voted : 20




Not Returned : 11






Affirmative 18


William A. Fithian As noted in FR-90 above, Section/chapter titles need to be

included. Specifically, "Certification Program" after Section 4.2

should not be deleted.


Negative 0

Abstain 0


Total Voted : 20

Total Voted : 20



Not Returned : 11






Affirmative 19



Negative 0

Abstain 0


Not Returned : 11







Total Voted : 20




Affirmative 19



Negative 0

Abstain 0


Not Returned : 11






Affirmative 19



Negative 0

Abstain 0

Total Voted : 20


Total Voted : 20



Not Returned : 11






Affirmative 19



Negative 0

Abstain 0


Not Returned : 11


Total Voted : 20









Affirmative 19



Negative 0

Abstain 0


Not Returned : 11






Affirmative 19



Negative 0

Total Voted : 20



Abstain 0


Not Returned : 11






Affirmative 17


William A. Fithian As noted in FR-90, Section titles should not be deleted.

Jeffrey O. Stull A test by test review is needed to ascertain if the proposed

testing reduction captures all essential requirements and is

satisfactory to addressing continued certification of the product.


Negative 0

Abstain 0

Total Voted : 20

FR-20, Section No. 4.4.3.2, See FR-20

Total Voted : 20



Not Returned : 11






Affirmative 17


Jeffrey O. Stull According to item (4) permeation tests would be conducted with

two replicates. Given the reduction in the number of chemicals,

three replicates of these tests be carried out.


Negative 1



William A. Fithian The Section numbers are not correct and there are additional

issues that require action by the committee. [Proposed language:

Chemical permeation testing as specified in 7.6.1 shall not be

required.] The new Section 7.6.1 defines optional Liquefied Gas

Testing and needs to remain. The existing Section 7.6.1 defines

CBRN chemical performance requirements, which have been

inadvertently removed from the proposed language in new

edition. The committee needs to reevaluate this issue and fix the

appropriate sections. [Proposed language: Chemical permeation

resistance testing specified in 7.7.2 shall be limited to ammonia.]

This should reference Section 7.8.2 in the new edition, unless the

comments above change the new edition section numbers.

Abstain 0


Not Returned : 11





Total Voted : 20

FR-21, Sections 4.5.2, 4.5.3, See FR-21



Affirmative 19



Negative 0

Abstain 0


Not Returned : 11






Affirmative 19



Negative 0

Abstain 0

Total Voted : 20


Total Voted : 20



Not Returned : 11






Affirmative 19



Negative 0

Abstain 0


Not Returned : 11



Total Voted : 20








Affirmative 18


Jeffrey O. Stull New items (8) and (9) should be retititled "Procedures for". Item

(8) should be moved under item (4), while item (9) belongs with

item (6).


Negative 0

Abstain 0


Not Returned : 11






Total Voted : 20



Affirmative 18


Jeffrey O. Stull The word "worn" should be changed to "used".

Susan L. Lovasic I do not believe adding this information to the technical data

package is relevant or adds any value to the specifier or user of

the suit.

Negative 0

Abstain 0


Not Returned : 11






Affirmative 19



Negative 0

Abstain 0

Total Voted : 20




Not Returned : 11






Affirmative 16


Philip C. Mann The specific chemical barrier performance requirements to

support use of respirator face pieces as primary chemical barrier

need to be addressed in Chapter 7.

Negative 2

Total Voted : 20

FR-39, New Section after 6.1, See FR-39


James P. Zeigler With nonencapsulating ensembles, there are no assurances and

significant reason to be concerned that open-circuit, SCBA cannot

provide chemical barrier comparable to the requirements that

are otherwise mandated for the rest of the ensemble in NFPA

1991. Since its inception, NFPA 1991, Standard on Vapor-

Protective Ensembles for Hazardous Materials Emergencies, has

required that all ensemble components provide protection

against a battery of chemicals. Originally, this battery consisted of

21 chemicals. This battery was selected for its wide range in

chemical solubility and polymer diffusion characteristics, critical

factors in the chemical permeation through protective materials.

The chemicals were not chosen because their represent a specific

threat, although the list includes some high volume, frequently

encountered, toxic chemicals. The requirements that the

ensembles protect against all of these chemicals provides a high

probability that the NFPA 1991 compliant ensembles would

protect against a high concentration of an unknown chemical, an

unknown mixture mixture or a peculiar environmental condition.

In contrast, military chemical protective equipment is tested

against specific chemicals and specific concentrations, based on

the assumption that both the identity and concentration of the

chemical hazards can be determined beforehand. Along these

lines, additional chemicals barrier requirements were added to

NFPA 1991, first as options, and then mandated in the 2005

edition, in response the threat of chemical terrorism. These

additional chemicals consisted of chemical warfare agents and

industrial chemicals recognized as potential terrorism weapons.

The latter are sometime described as “dual-use” chemical agents.

Susan L. Lovasic (1) Respiratory protection is not "provided" by the authority

having jurisdiction. That text needs to be removed. (2) I do not

support allowing non-encapsulating suit designs to be permitted

in NFPA 1991. See supporting rationale in file "Negative - non-

encapsulating".

Abstain 1








Not Returned : 11






Total Voted : 20



Affirmative 17


Negative 2
































Abstain 1








Not Returned : 11






Affirmative 18


Negative 2

Total Voted : 20






























The latter are sometime described as “dual-use” chemical agents. Susan L. Lovasic I do not support allowing non-encapsulating suit designs to be



Abstain 0


Not Returned : 11






Affirmative 17


Negative 2

Total Voted : 20



Susan L. Lovasic Keep original text. I do not support allowing non-encapsulating

suit designs to be permitted in NFPA 1991. See supporting

rationale in file "Negative - non-encapsulating". 1991 suit must

have integrated visor design.

Abstain 1








Not Returned : 11






Affirmative 18

Total Voted : 20




Steven D. Corrado The associated Annex item contains a Performance Requirement

and therefor should be in Ch. 7 as a mandatory item.

Negative 1

Susan L. Lovasic Use of multiple layers should continue to be permitted. If there is

concern about possible mis-use of these ensembles, that can be

handled with additional instructions/wording in the TDP or labels

inside the suit itself.

Abstain 0


Not Returned : 11






Affirmative 17



Total Voted : 20


William A. Fithian Current proposed language is awkward. Suggest changing to the

following: For encapsulating designs, vapor-protective ensembles

shall be equipped with an exhaust valve(s)

Negative 1




Abstain 1








Not Returned : 11

Total Voted : 20








Affirmative 19


Susan L. Lovasic For clarity, should add the words "suit sleeve" to the sentence as

noted below. "...extend to at least the suit sleeve interface

connection."

Negative 0

Abstain 0


Not Returned : 11






Affirmative 19

Total Voted : 20





Negative 0

Abstain 0


Not Returned : 11






Affirmative 19



Negative 0

Abstain 0

Total Voted : 20


Total Voted : 20



Not Returned : 11






Affirmative 13


Steven D. Corrado Sections 7.7 and 7.9 are redundant to each other. References

should be updated as follows: In paragraph 7.3.3; the 8.10

reference should be 8.28. In paragraph 7.3.4; the 8.11 reference

should be 8.29. In paragraph 7.3.5; the 8.14 reference should be

8.30.

Jeffrey O. Stull Specific criteria are needed to provide minimum field of vision

requirements for ensemble in 7.1.2 and added based on changes

made in Section 8.4 and addressed in FR-51.

Negative 5

William A. Fithian Section Titles need to be included as noted in FR-90 above.

Liquefied Gas & Flash Fire sections - eliminate the term “primary

suit material” and replace it with garment, visor, glove and

footwear materials

FR-46, Chapter 7, See FR-46







permeation spikes being missed. We are concerned the MIST test

may not be the most appropriate method to evaluate level A suits

and we are are concerned about the reduction of the protection

factor requirement to 1080.

Philip C. Mann 7.2.2 This section only addresses the afterflame time and not the

char length as specified in 8.7.7.2. A char length needs to be

added. 7.7 and 7.9 are redundant 7.7.4 the afterflame time

should be zero, not 2.0 seconds 7.7.5 references testing as

specified in 8.18, this should be 8.26 Specific performance

requirements for non-encapsulating ensembles that utilize

respirator face pieces as the chemical barrier need to be included

in Chapter 7.

James P. Zeigler I have three major concerns regarding the proposed move to

cumulative permeation: 1.) It significantly lowers the barrier

performance requirement of NFPA 1991 ensemble materials. 2.)

It is based solely on long-term systemic toxicity. The proposal

ignores short term exposure to high concentration (ceiling limits)

and the potential for skin irritation, dermatitis, sensitization and

allergic skin reactions. 3.) It provides less information about the

barrier performance of the material during the testing interval

that the current method. Two additional documents – ‘Proposed

Changes to NFPA 1991 Barrier Requirements” and “Cumulative

Permeation Performance from Breakthrough Data” have been

provided to NFPA or inclusion with this ballot response.

Susan L. Lovasic Specific sections for which I am voting negative in this ballot item

are: - 7.1.2 -- Time limit should be 5 minutes rather than 2

minutes proposed. - 7.1.8 / 7.6.4 -- Should stay with SF6 test. See

file "Negative-Inward leakage-SF6 to MIST". - 7.2.1 / 7.2.1.2 /

7.2.6 / 7.2.6.1 / 7.3.6.1 / 7.4.1 / 7.4.3 / 7.5.1 / 7.5.1.3 / 7.6.2 /

7.7.2 -- Should stay with NBTT - see file "Negative - Cumulative

Permeation". - 7.3.1 / 7.3.1.1 / 7.3.1.2 / 7.3.1.3-- Should stay with

NBTT - see file "Negative - Cumulative Permeation". AND if non-

encapsulating suit designs are permitted, then all "visor"

requirements must be applied to all exposed components of the

external SCBA system. - 7.3.2 / 7.3.3 / 7.3.4 / 7.3.5 / 7.3.6 / 7.7.3 /

7.8.2 -- If non-encapsulating suit designs are permitted, then ALL

"visor" requirements for flammability, burst strength, etc must be

applied to all exposed components of the external SCBA system. -

7.5.5 - Soles of boots should also be tested (not just heels). - 7.7.5

- The addition of the new requirement for ASTM F1930 testing is

not additive to this standard. See FR52 comments due to limited

space under this FR comments. - 7.9.2, 7.9.3 and 7.9.4 are

redundant to 7.7.2, 7.7.3, and 7.7.4.

Abstain 0

Total Voted : 20




Not Returned : 11






Affirmative 18



Negative 1

Steven D. Corrado The minimum 24 hour option for conditioning should be

maintained in order to correlate with the other documents is this

project (as stated in the Committee Statement).

Abstain 0


Not Returned : 11

Total Voted : 20








Affirmative 18


Negative 2

Ulf Nystrom There should not be any changes or added procedures for the suit

material abrasion procedure. The reason is that the committee

did agree that outer covers and similar may only be used to

achieve compliance with the optional additional requirements for

chemical flash-over and liquefied gas protection. Consequently

the garment material of all ensembles submitted for testing shall

be subjected to the same base requirement testing without any

outer layers being involved in any way.

Susan L. Lovasic Under section (4), it is irrelevant whether the "inner layer is the

chemical barrier layer" or not. If a two layer garment system is

used in the 1991 ensemble then the abrasion tests should always

abrade the outside of the inner suit with the inside of the outer

suit.

Abstain 0

Total Voted : 20


Not Returned : 11






Affirmative 19


Susan L. Lovasic Approved as is.

Negative 0

Abstain 0


Not Returned : 11







Total Voted : 20




Affirmative 19


Susan L. Lovasic Approved as is.

Negative 0

Abstain 0


Not Returned : 11






Affirmative 18


Jeffrey O. Stull Additional work is needed to specify and validate the proposed

test procedures for the measurement of ensemble field of vision.

Further enhancement is needed for how ensemble glove

dexterity and hand function is addressed in functional testing of

the ensemble.

Negative 1

Total Voted : 20



Susan L. Lovasic Specific sections for which I am voting negative in this multi-part

ballot item are: - 8.4.5.2.1 - This references 20/20 vision

correction with "contact lenses" only. Is it intended that the

wearer's vision cannot be corrected to 20/20 with glasses? -

8.4.5.3 - Not enough detail is provided to run this new test. How

is "angular degree" determined? Are the large block letters placed

90 degrees from the center vision point to begin the test and

then move slowly until they come into view to the wearer? Is the

wearer permitted to turn their head to try to see the letters or is

this measuring the wearer's peripheral vision? Seems to be a

meaningful test to include, but as written it is not a proper test

method. - 8.4.7.1 -- Need to add specifics for what test is to be

used (ASTM F1052?) - 8.4.7.4 - I did not note any pass/fail limits

for this new test added in Section 7.

Abstain 0


Not Returned : 11

Total Voted : 20








Affirmative 16


Jeffrey O. Stull A detailed review is needed to ensure that the new procedures

meet the intended objectives of the method change from a

breakthrough-based testing approach to one that utilizes

cumulative permeation.

Negative 3






permeation spikes being missed. Some problems could perhaps

be overcome by reporting both cumulative and breakthrough

time and/or increasing sampling frequency but the current

revision does not do this.

James P. Zeigler I have three major concerns regarding the proposed move to

cumulative permeation: 1.) It significantly lowers the barrier

performance requirement of NFPA 1991 ensemble materials. 2.)

It is based solely on long-term systemic toxicity. The proposal

ignores short term exposure to high concentration (ceiling limits)

and the potential for skin irritation, dermatitis, sensitization and

allergic skin reactions. 3.) It provides less information about the

barrier performance of the material during the testing interval

that the current method. Two additional documents – ‘Proposed

Changes to NFPA 1991 Barrier Requirements” and “Cumulative

Permeation Performance from Breakthrough Data” have been

provided to NFPA or inclusion with this ballot response.


ballot item are: - 8.6.1.1 -- If non-encapsulating suit designs are

permitted, then ALL "visor" requirements for permeation must be

applied to all components of the external SCBA system. - 8.6.4.1

parts (1) and (2) / 8.6.4.1.1 / 8.6.4.1.2 / 8.6.4.2.1 / 8.6.5.1 /

8.6.5.3 -- Retain text as written. Should stay with NBTT - see file

"Negative - Cumulative Permeation". - 8.6.4.2 -- The section

"chemicals at its normal laboratory-grade concentration" is not

precise enough for the liquid chemicals. Suggest that text be

changed to "chemicals with at least 95%concentration..." -

8.6.11.3 -- All "visors" must be assessed to the same set of

standards. Exclusions for "rigid" visors just because they cannot

be tested in a specific test apparatus is not acceptable. Some

replacement test to assess the same performance property for

rigid visors must be included. All "visors" should be held to a

comparable performance standard.

Abstain 0


Not Returned : 11

Total Voted : 20








Affirmative 18


Philip C. Mann 8.7.4 (2) should be removed considering the specifications in

8.7.1.2 and 8.7.1.3

Negative 1


ballot item are: - 8.7.1.1 -- If non-encapsulating suit designs are

permitted, then ALL "visor" requirements for flammability must

be applied to all components of the external SCBA system. -

8.7.6.2 -- The average afterflame time should be used to

determine "pass/fail" not the longest afterflame time recorded.

My proposed data treatment is consistent with other

flammability tests used in NFPA 1971, 1975, 2112. - 8.7.6.3 -- The

average burn distance should be used to determine "pass/fail"

not the longest burn distance recorded. My proposed data

treatment is consistent with other flammability tests used in

NFPA 1971, 1975, 2112.

Abstain 0

Total Voted : 20


Not Returned : 11






Affirmative 17


Jeffrey O. Stull Further review of this test method is needed to ensure that the

specific conditions chosen will provide the expected levels of

performance appropriate for vapor-protective ensembles.

Negative 2

Ulf Nystrom We are concerned the MIST test may not be the most appropriate

method to evaluate level A suits and we are are concerned about

the reduction of the protection factor requirement to 1080.

Susan L. Lovasic Should stay with SF6 test. See file "Negative-Inward leakage-SF6

to MIST".

Abstain 0


Total Voted : 20



Not Returned : 11






Affirmative 18


Jeffrey O. Stull A similar changes is needed to remove visor materials from

puncture propagation tear resistance testing (paragraph

8.11.1.1). The requirement for visor puncture propagation tear

resistance has been proposed for deletion as part of FR-46.


Negative 0

Abstain 0


Total Voted : 20



Not Returned : 11






Affirmative 18


Jeffrey O. Stull This specific change should be validated by the examination of

available data at the new blade travel distance.


Negative 0

Abstain 0


Not Returned : 11


Total Voted : 20









Affirmative 18


Jeffrey O. Stull This specific change should be validated by the examination of

available data at the new blade travel distance.


Negative 0

Abstain 0


Not Returned : 11







Total Voted : 20


Affirmative 18


Jeffrey O. Stull The source for the standard reference material should be

provided or a more detailed specification provided. Data utilizing

the standard reference material should be provided.

Negative 1

Susan L. Lovasic While the concept of adding a reference standard for this test is

good, there is not enough detail provided. The description of the

reference standard in section 8.16.4.1 is not adequate to ensure

that test labs are using comparable materials for qualification of

the test probes. More details on physical properties such as burst

strength, breaking strength, stiffness, etc should be provided so

that the appropriate reference materials can be obtained and

used by the labs. 8.16.4.2 lists "10.3 N" as the required result for

all probes (assuming using the reference standard - that should be

added to the text also). There should be a +/- limit included with

the 10.3 N target. Otherwise the probes would only pass by

delivering that exact level of performance.

Abstain 0


Total Voted : 20



Not Returned : 11






Affirmative 19


Negative 1

Susan L. Lovasic If non-encapsulating suit designs are permitted, then ALL "visor"

requirements must be applied to all components of the external

SCBA system. That text must be added to clarify what must be

tested.

Abstain 0


Not Returned : 11





Total Voted : 20




Affirmative 19



Negative 0

Abstain 0


Not Returned : 11






Affirmative 19



Negative 0

Abstain 0

Total Voted : 20


Total Voted : 20



Not Returned : 11






Affirmative 19



Negative 0

Abstain 0


Not Returned : 11


Total Voted : 20









Affirmative 19



Negative 0

Abstain 0


Not Returned : 11






Affirmative 19


Total Voted : 20



Susan L. Lovasic Currently 8.19.1 reads "This test method shall apply to vapor-

protective footwear element soles with heels." I believe it should

read "This test method shall apply to vapor-protective footwear

element soles and heels."

Negative 0

Abstain 0


Not Returned : 11






Affirmative 19



Negative 0

Abstain 0

Total Voted : 20


Total Voted : 20



Not Returned : 11






Affirmative 19



Negative 0

Abstain 0


Not Returned : 11


Total Voted : 20

FR-66, New Section after 8.24.2.2, See FR-66








Affirmative 19


Susan L. Lovasic As written "Closure samples shall be permitted to be individual

samples cut to specimen width", this does not achieve the intent

of the change - "The TC is adding this section to allow for tacking

of the closure." The text should be changed to "Closure samples

shall be permitted to be individual samples cut to specimen width

and can be secured (tacked) at the cut edges." FR-66 is redundant

to FR-67.

Negative 0

Abstain 0


Not Returned : 11

Total Voted : 20








Affirmative 19


Susan L. Lovasic Approved as is. FR-66 is redundant to FR-67.

Negative 0

Abstain 0


Not Returned : 11






Affirmative 17


Total Voted : 20

FR-52, New Section after 8.27, See FR-52


Jeffrey O. Stull No specific criteria have been provided to go along with the

proposed test method.

Ulf Nystrom There is probably a need to look into reproducibility, repeatability

and variability arising from a number of factors including garment

sizes and fit. Also, the 6s exposure time requirement may need

some substantiation and/or furthter looking into.

Negative 1

Susan L. Lovasic The rationale for my negative vote is: (1) The existing propane

flash test is adequate for the needs since it assesses the actual

ensemble being certified. (2) The bulkiness of most suit fabrics

are not conducive to being cut and sewn into the basic coverall

pattern specified in ASTM F1930. (3) The proposed test will not

assess what the NFPA 1991 ensemble's protection from potential

burn injury will be since the pattern does not match the actual

ensemble and there is no testing of the visor or glove materials.

(4) The selection of 25% body burn as the limit is arbitrary. (5) The

selection of 6 seconds flame exposure time is arbitrary. (7) This

testing is not as relevant as the existing HTP test which is

conducted on all components of the ensemble (suit fabric, visor

material, glove materials) to determine the level of thermal

insulation (burn injury potential) of these materials when

exposure to heat and flame.

Abstain 0

Total Voted : 20


Not Returned : 11






Affirmative 18


Jeffrey O. Stull This first revision is confusing because it should be part of FR-52

instead of its own first revision.

FR-68, Sections 8.27.4, 8.27.5, 8.27.6, See FR-68


Susan L. Lovasic There are several sections that required further revisions.

8.25.4.5.3 - It should note that adjustment to the 2 +/- 1 min

suggested propane fill time is permitted to achieve the 7 +/- 1

second visible flash fire time requirement. 8.25.4.5.4 - the phrase

"..the adequate time to create.." in the first sentence should be

edited to be "..the propane fill time required to create".

8.25.4.5.4 - What if the fire time is 7 +/- 1 second, but the

measured temperatures during the verification burn are not all

within the 650 - 1150C specified? What should be done to

reconcile any differences? 8.25.5.3 is redundant to 8.25.4.5.3. In

the report section (8.25.26) will need to add a notation to record

the ambient temperature and RH when the test burn was

completed.

Negative 0

Abstain 0


Not Returned : 11

Total Voted : 20








Affirmative 18


Jeffrey O. Stull This test method is only a concept and should be validated.

Negative 1

Susan L. Lovasic If non-encapsulating suit designs are permitted, then all suit

"visor" requirements must be applied to the "visor/facepiece" of

the externally worn SCBA system.

Abstain 0


Not Returned : 11

Total Voted : 20








Affirmative 18



Negative 1




Abstain 0


Not Returned : 11





Total Voted : 20




Affirmative 18



Negative 1




Abstain 0


Not Returned : 11






Affirmative 18



Total Voted : 20


Jeffrey O. Stull This test method, as adapted from NFPA 1994, should be carefully

reviewed to ensure that it adequately addressed vapor-protective

ensemble materials.

Negative 1

Susan L. Lovasic 8.27.1.1 -- If non-encapsulating suit designs are permitted, then

all current suit "visor" requirements must also be applied to the

"visor system" of the externally worn SCBA. For chemical

permeation resistance testing, it must be applied to all exposed

components such as the face piece, rubber sealing gasket, hose

connected to air tank, etc. It must be known if any of these

external SCBA components might permit hazardous chemicals to

permeate into the breathing air system or into the suit. Excluding

the external SCBA system components from the base

performance requirements of an encapsulating suit "visor" is not

appropriate.

Abstain 0


Not Returned : 11

Total Voted : 20

FR-26, Section No. A.4.6.1, See FR-26







Affirmative 19



Negative 0

Abstain 0


Not Returned : 11






Affirmative 19



Negative 0

Total Voted : 20

FR-27, Section No. B.1.2.2, See FR-27


Abstain 0

Total Voted : 20

Negative ‐ Inward Leakage: SF6 Test Replaced with MIST Supporting statement from ballot ‐ “The technical committee is proactively addressing the expected limited availability of SF6 for test implementation by replacing the inward leakage test with the MIST test.” Negative based on the following reasons (explained further below):

1. EPA is not banning SF6 2. MIST is not equivalent to SF6 – MIST can’t meet the current inward leakage requirement in 7.6.4 of

“no inward leakage greater than 0.02 percent”. 3. Relevant protection factors for unknown hazards has been defined by OSHA

1) EPA is not banning SF6

• Committed to reducing Greenhouse Gas Emissions • Voluntary SF6 programs for the Electrical Power Systems and Magnesium Industries • It appears that no mandates, restrictions, phase out plans exist at this time for SF6

Source: http://www.epa.gov/electricpower‐sf6/ http://www.epa.gov/magnesium‐sf6

• THE PRESIDENT’S CLIMATE ACTION PLAN (June 2013) does not mention SF6

Source:

http://www.whitehouse.gov/sites/default/files/image/president27sclimateactionplan.p df

• Department for Environment, Food and Rural Affairs General Guidance Guidance: F Gas and Ozone Regulations Information Sheet GEN 3: Markets & Equipment April 2012 Laboratory and scientific applications. There are a number of minor uses of fluorinated (F) gases in specialized scientific applications. For example SF6 is used as an atmospheric tracer gas. These applications are still allowed under the EU F gas Regulation. Source: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/182572/fgas‐gen3‐markets‐equipment.pdf

2) MIST is not equivalent to SF6 – MIST can’t meet the current inward leakage requirement in 7.6.4 of “no inward leakage greater than 0.02 percent”.

• SF6 (NFPA 1991‐05) has a nearly 60 times higher external concentration level than MIST

(NFPA 1994) • Max protection factor:

• MIST is 1,350 or <0.10% inward leakage • SF6 is 5,000 (currently used today) or <0.02% inward leakage

• MIST has sensitivity issues that would need to be resolved in order to reach the current capabilities of the SF6 test Source: Presentation from Meeting Minutes Feb. 18‐20, 2014 “Incorporation of the Man‐In‐Simulant‐Test into the NFPA 1991 Standard as a Replacement for the Overall Ensemble Inward Leakage Test (SF6)”

3) Relevant protection factors for unknown hazards has been defined by OSHA

OSHA details a version of the inward leakage test that uses ammonia as the challenge vapor. The inward leakage detection capabilities were limited to a PF of 200. It clearly states multiple times in the section that any detectable ammonia in the suit interior indicates that the suit has failed the test. When other ammonia detectors are used a lower level of detection is possible, and it should be specified as the pass/fail criteria. In other words, no inward leakage of vapor is considered acceptable.

OSHA: 29 CFR 1926.65 App A

This appendix sets forth the non‐mandatory examples of tests which may be used to evaluate compliance with 1926.65(g)(4)(ii) and (iii). Other tests and other challenge agents may be used to evaluate compliance. B. "Totally‐encapsulating chemical protective suit qualitative leak test" 1.0 – Scope 1.1 This practice semi‐qualitatively tests gas tight totally‐encapsulating chemical protective suit integrity by detecting inward leakage of ammonia vapor. Since no modifications are made to the suit to carry out this test, the results from this practice provide a realistic test for the integrity of the entire suit. 2.4 "Intrusion Coefficient" means a number expressing the level of protection provided by a gas tight totally‐encapsulating chemical protective suit. The intrusion coefficient is calculated by dividing the test room challenge agent concentration by the concentration of challenge agent found inside the suit. The accuracy of the intrusion coefficient is dependent on the challenge agent monitoring methods. The larger the intrusion coefficient the greater the protection provided by the TECP suit. 6.6 After two minutes a determination of the ammonia concentration within the chamber should be made using the high range colorimetric detector tube. A concentration of 1000 ppm ammonia or greater shall be generated before the exercises are started. 6.7 To test the integrity of the suit the following four minute exercise protocol should be followed:

6.14 Any detectable ammonia in the suit interior (five ppm ammonia (NH(3)) or more for the length of stain detector tube) indicates that the suit has failed the test. When other ammonia detectors are used a lower level of detection is possible, and it should be specified as the pass/fail criteria. 6.15 By following this test method, an intrusion coefficient of approximately 200 or more can be measured with the suit in a completely operational condition. If the intrusion coefficient is 200 or more, then the suit is suitable for emergency response and field use. 8.2 The evaluation of the data shall be specified as "suit passed" or "suit failed," and the date of the test. Any detectable ammonia (five ppm or greater for the length of stain detector tube) in the suit interior indicates the suit has failed this test. When other ammonia detectors are used, a lower level of detection is possible and it should be specified as the pass fail criteria. Intrusion Coefficient = (1,000 ppm/5 ppm *limit*) = 200

Source: https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10652

Using the same principles above, but applying to chemicals that are considered skin hazards, example Benzene:

Benzene: 20,000 ppm levels quoted in http://www.cdc.gov/niosh/idlh/71432.html Current OSHA PEL: 1 ppm TWA, 5 ppm STEL Intrusion Coefficient = (20,000 ppm / 5 ppm *STEL limit*) = 4,000

4,000 > MIST PF of 1,350

MIST would not be an adequate predictor of the inward leakage limit per the current STEL from OSHA

IDLH Values for Other Chemicals can be found here: http://www.cdc.gov/niosh/idlh/intridl4.html

1

Determining Cumulative Permeation from Breakthrough Data

James P. Zeigler, Ph.D.

June 23, 2011

The purpose of this paper is to compare cumulative permeation of current commercial

barrier materials to the proposed performance requirement of 6 ug/cm2 proposed for

NFPA 1991, Vapor Protective Ensembles for Hazardous Materials Emergencies.

Permeation is a process in which the chemical is absorbed into the exposed (outside) face

of the barrier material and moves into and saturates that material. The chemical will

desorb from the barrier material when it reaches the opposite (skin-side) face.

Permeation rate is the rate of this desorption. Permeation rate is expressed in mass (ug)

per area (cm2) per minute or ug/cm

2/min. Generally, but not always, permeation rates

follow a classical curve shown in Figure 1. At the start of the exposure, there is no

chemical to desorb from the skin side of the material. As the chemical moves through and

saturates the material, it begins to desorb from the skin side at a low rate. As the amount

of chemical reaching the skin side increases, the rate of permeation increases. The

chemical can be detected with the rate reaches the “minimum detectable permeation

rate” (MDPR). The time at which the chemical is first detected permeating at MDPR is

the “actual breakthrough time”. Because breakthrough times can be “adjusted” by

changing the MDPR, a “standardized breakthrough time” (sBT) was defined as the time

at which permeation reaches 0.1 ug/cm2/min. The “breakthrough detection time”

specified in NFPA 1991 is this standardized breakthrough time. Since first approved in

1989, the chemical barrier requirements of NFPA 1991 have been based on breakthrough

detection time except for the chemical warfare agents.

Cumulative permeation is the total amount of chemical that permeates in a specified

period of time. More specifically, it is the amount of chemical that permeates a given area

of fabric in a given period of time and is expressed in ug/cm2. Cumulative permeation

can be determined by measuring all the chemical that permeates a sample in a fixed time

Measuring Cumulative Permeation from Breakthrough Data

2

or it can be determined by “integrating” the permeation rate curve. In a plot of

permeation rate versus time, cumulative permeation is the area under the curve

(Figure 2).

Cumulative permeation is used with chemical warfare agents because there are extensive,

peer reviewed, human trial data available on the skin toxicity of those chemicals. For

skin contact, that dosage would be express in mass per unit area of skin or ug/cm2. Thus

cumulative permeation describes a conservative skin dosage a wearer of a chemical

garment might see in conditions similar to the test conditions, e.g., temperature, humidity,

duration of the exposure and concentration of chemical challenge. Cumulative

permeation is generally not used with industrial chemicals because the detailed skin data

are not available or have not been peer-reviewed and adopted for use by accepted experts

such as the American Conference of Governmental Industrial Hygienists (ACGIH) or the

National Institute for Occupational Safety and Health (NIOSH).

Cumulative permeation measurements do not provide data on another important toxicity

parameter called ceiling limits. Ceiling inhalation limits are found for many chemicals

and ceiling limits apply to skin contact. A ceiling limit is the maximum concentration

that can be tolerated without injury or damage in a short exposure. For example, a person

canning pickles at home can likely tolerate 30 minutes exposure to vinegar with few ill-

effects unless they already have some skin damage or have been canning for multiple

days. Vinegar is 7% acetic acid. A 2.1 minute exposure to 100% acetic acid (glacial

acetic acid) would be an equivalent dosage, the basis of cumulative permeation.

However, 100% acetic acid will burn the skin in much less than 2.1 minutes, in fact,

almost instantaneously. Ceiling limits are especially important for chemicals that react

with the skin, such as corrosives and oxidizers. Many of the highest volume chemicals

on the roads and rails, and hence most likely to be encountered in a hazardous materials

or terrorism incident, are corrosives and oxidizers (sulfuric acid, chlorine gas and sodium

hydroxide). Ceiling limits would have to be determined and measured to accompany

cumulative permeation limits on these chemicals. Since the current breakthrough times


3

are based on a low permeation rate, permeation test reporting would report out the spike

as a breakthrough time.

Cumulative permeation metrics ignore ceiling limits; it only considers the total area under

the curve (Figure 3). A short term exposure spike would not be indicated in a cumulative

permeation value. In this example the cumulative permeation requirement would still be

meet event considering the ceiling limit excursion.

Ignoring for the moment that ceiling limits have not been mentioned so far in the

proposed revisions to NFPA 1991, let’s consider the proposed cumulative permeation

levels against those found for some current commercial products. The proposal is to

change from a breakthrough detection time of >60 minutes to a cumulative permeation of

6 ug/cm2. In theory, a chemical could permeate at a rate of 0.09999999 ug/cm

2/min for

60 or more minutes and meet the 60 minutes breakthrough detection time requirement

(Figure 4). How often does that actually occur?


4

Table 1 lists permeation data obtained using ASTM F 739 for a number of fabric-

chemical combinations obtained for current products and some recently discontinued

product. These were all the data I could find in the time allowed that met the

requirements to calculate cumulative permeation. Unless otherwise specified, the tests

were conducted at room temperature with chemical at +99% concentration. The columns

contain actual breakthrough minutes (aBT), standardized breakthrough minutes according

to ASTM F 739 (sBT), steady-state permeation rates (SSPR) and MDPR, the later two in

ug/cm2/minute.

Table 1 – Permeation Breakthrough Times and Rates

Chemical Name Material

Code aBT sBT SSPR MDPR

Methanol G 20 63 0.19 0.04

Methyl ethyl ketone G 0 64 0.36 0.001

Methanol A 25 65 0.18 0.001

Ethylene Oxide (gas) G 55 65 1.4 0.01

Methylamine B 72 73 3.9 0.017

Benzene I 44 74 1.86 0.02

Ethylene Oxide (gas) A 53 75 2.7 0.03

Ammonia (gas) G 55 79 0.76 0.001

Nitric acid (30%) K 55 80 4.6 0.001

Hexamethylendiamine I 60 80 1.52 0.01

Hexamethylendiamine I 60 80 2.13 0.01

Hydrochloric acid (16%) K 45 86 11.1 0.005

Methyl Cellosolve I 49 89 5.77 0.07

Hydrochloric acid (37%) L 53 92 1.74 0.005

Pyrrolidine (Azolidine) G 80 100 4.7 0.05

Nitrobenzene I 78 102 2.3 0.001

Methanol G 51 107 0.14 0.02

Ethylene Dichloride G 115 118 7.2 0.02

Sulfuryl Chloride E 35 120 1 0.01

Ammonia (gas) H 11 124 0.12 0.003

Hydrogen Cyanide B 108 135 0.53 0.0082

Hexane n- I 8 146 0.49 0.001

Methanol C 120 150 0.6 0.01

Acetonitrile G 84 157 0.19 0.003

Methanol B 118 159 0.83 0.001

Vinylidine Chloride E 150 170 1 0.01

Acrolein E 29 178 0.17 0.05

Cresol-o G 141 180 2.7 0.001

Dichloromethane B 61 181 0.17 0.001

Butyl ether n- G 23 194 0.13 0.001

Methyl-2-propanol 2- G 147 205 0.26 0.02

Sulfuric acid (50%) K 163 208 38 0.01

Sulfuric acid (50%) K 163 208 38 0.01

Sulfuric acid (30%) K 135 222 9.7 0.005

Methylamine B 204 232 2.2 0.001

Trichloroethane 1,1,2- G 173 232 9.1 0.01


5

Nitromethane G 157 233 0.97 0.001

Phenol G 182 238 4 0.001

Gasoline/Alcohol Mix B 170 244 0.24 0.011

Chlorobenzene G 171 246 0.16 0.05

Formic acid (96%) G 172 260 0.24 0.001

Methylene Chloride B 203 261 0.19 0.001

Dimethyl Sulfide G 139 271 1.21 0.02

Hydrazine G 269 283 2.3 0.001

Methyl hydrazine G 206 283 1 0.01

Dichloroaniline 3,4- B 216 284 2.4 0.001

Ethylene dibromide G 153 288 0.52 0.001

Tetrahydrofuran A 102.67 313 0.21 0.001

Xylene (iso-mix) G 16 328 0.16 0.001

Chloroaniline 4- B 323 344 9.4 0.001 Cumene (Isopropylbenzene) E 354 364 1.5 0.02 Potassium hydroxide (40%) K 163 366 0.12 0.005

Epichlorohydrin G 204 372 0.51 0.001

Acrylonitrile H 233 382 0.18 0.06

PCB (Gas Condensate) I 16 401 0.36 0.001

Phosphorus Oxychloride E 45 410 0.22 0.01

Pyrrolidine (Azolidine) B 407 413 9.2 0.012

Hydrochloric acid (37%) D 220 417 1 0.001

Hydrofluoric Acid E 390 420 0.16 0.01

Benzonitrile E 420 450 0.31 0.01

Tetrahydrofuran G 103 464 0.12 0.001

Oleum (40% free SO3) G 220 467 0.32 0.0001

Cumulative permeation can be determined from permeation data if the actual and

standardized breakthrough times are provided, the MDPR is < 0.1 and the permeation

curve follows the “classical” shape. This is shown in the appendix. All of these fabric-

chemical combinations follow classical permeation behavior. The minimum detectable

permeation rates for these tests were all less than 0.1 ug/cm2/min and standardized

breakthrough detection times greater than 60 minutes and less than 480 minutes.

Individually, these test results meet the barrier requirement of NFPA 1991. However,

none of these fabrics meet the barrier performance for all the chemicals listed in

NFPA 1991. NFPA 1991 requires that the garment materials exceed standardized

breakthrough times for 60 minutes for the battery of 21 standard chemicals listed in

ASTM F 1001 and a few additional industrial chemicals than could also be used as

terrorism weapons as well as meeting cumulative permeation requirements for several

chemical warfare agents.

The chemicals listed in NFPA 1991 are not the only hazards that might be encountered in

a hazmat or terrorism incident. That list is not intended to represent all of the hazards. It

is impossible to list all the chemicals that might be encountered in a hazmat incident or is

a terrorism incident. Nor is it practical to test the material against such a list if it existed.

The list in ASTM F 1001 represents many chemical classes. Requiring barrier against

this broad range of chemical classes increases the likelihood that the material will have


6

barrier against other chemicals that might be encountered in a hazmat incident. For many

of the products that are currently certified to NFPA 1991, the materials exhibit

standardized breakthrough times of greater than 8 hours for most of the chemical in the

test battery and as a result, exhibit very low cumulative permeation by those chemicals,

much lower the data provided in this table.

This list of test results, which represent materials with lower overall barrier than required

in NFPA 1991, but still meeting the performance requirements against the individual

chemicals, is a more generous way to look at the relationship of actual cumulative

permeation versus the proposed limit. It is already factoring in the consideration that the

NFPA 1991 compliant garments exhibit an exceedingly high level of barrier.

Table 2 provides the comparison of the proposed permeation cumulative requirement to

the actual 60 minutes cumulative permeation determined from these data:

Table 2 – Observed Cumulative Permeation vs. Proposal

Chemical Name Mat’l Code

aBT sBT SSPR MDPR

Cumulative Permeation

in 60 minutes

Ratio - Proposed Limit

vs. Actual

Cumulative Permeation

Methanol G 20 63 0.19 0.04 3.5 1.7

Methyl ethyl ketone G 0 64 0.36 0.001 2.8 2.1

Ethylene Oxide (gas) G 55 65 1.4 0.01 0.7 8.4

Methanol A 25 65 0.18 0.001 1.6 3.8

Methylamine B 72 73 3.9 0.017 1.0 5.9

Benzene I 44 74 1.86 0.02 1.5 3.9

Ethylene Oxide (gas) A 53 75 2.7 0.03 1.9 3.2

Ammonia (gas) G 55 79 0.76 0.001 0.1 53.8

Hexamethylendiamine I 60 80 1.52 0.01 0.6 10.0

Hexamethylendiamine I 60 80 2.13 0.01 0.6 10.0

Nitric acid (30%) K 55 80 4.6 0.001 0.1 54.8

Hydrochloric acid (16%) K 45 86 11.1 0.005 0.6 10.7

Methyl Cellosolve I 49 89 5.77 0.07 4.2 1.4

Hydrochloric acid (37%) L 53 92 1.74 0.005 0.4 16.7

Pyrrolidine (Azolidine) G 80 100 4.7 0.05 3.0 2.0

Nitrobenzene I 78 102 2.3 0.001 0.1 100.0

Methanol G 51 107 0.14 0.02 1.3 4.8

Ethylene Dichloride G 115 118 7.2 0.02 1.2 5.0

Sulfuryl Chloride E 35 120 1 0.01 0.9 6.4

Ammonia (gas) H 11 124 0.12 0.003 1.2 5.0

Hydrogen Cyanide B 108 135 0.53 0.0082 0.5 12.2

Hexane n- I 8 146 0.49 0.001 1.0 5.8

Methanol C 120 150 0.6 0.01 0.6 10.0

Acetonitrile G 84 157 0.19 0.003 0.2 33.3

Methanol B 118 159 0.83 0.001 0.1 100.0

Vinylidine Chloride E 150 170 1 0.01 0.6 10.0


7

Acrolein E 29 178 0.17 0.05 3.2 1.9

Cresol-o G 141 180 2.7 0.001 0.1 100.0

Dichloromethane B 61 181 0.17 0.001 0.1 100.0

Butyl ether n- G 23 194 0.13 0.001 0.5 13.1

Methyl-2-propanol 2- G 147 205 0.26 0.02 1.2 5.0

Sulfuric acid (50%) K 163 208 38 0.01 0.6 10.0

Sulfuric acid (50%) K 163 208 38 0.01 0.6 10.0

Sulfuric acid (30%) K 135 222 9.7 0.005 0.3 20.0

Methylamine B 204 232 2.2 0.001 0.1 100.0

Trichloroethane 1,1,2- G 173 232 9.1 0.01 0.6 10.0

Nitromethane G 157 233 0.97 0.001 0.1 100.0

Phenol G 182 238 4 0.001 0.1 100.0

Gasoline/Alcohol Mix B 170 244 0.24 0.011 0.7 9.1

Chlorobenzene G 171 246 0.16 0.05 3.0 2.0

Formic acid (96%) G 172 260 0.24 0.001 0.1 100.0

Methylene Chloride B 202.67 261 0.19 0.001 0.1 100.0

Dimethyl Sulfide G 139 271 1.21 0.02 1.2 5.0

Hydrazine G 269 283 2.3 0.001 0.1 100.0

Methyl hydrazine G 206 283 0.98 0.01 0.6 10.0

Dichloroaniline 3,4- B 216 284 2.4 0.001 0.1 100.0

Ethylene dibromide G 153 288 0.52 0.001 0.1 100.0

Tetrahydrofuran A 102.67 313 0.21 0.001 0.1 100.0

Xylene (iso-mix) G 16 328 0.16 0.001 0.4 16.3

Chloroaniline 4- B 323 344 9.4 0.001 0.1 100.0 Cumene (Isopropylbenzene) E 354 364 1.5 0.02 1.2 5.0 Potassium hydroxide (40%) K 163 366 0.12 0.005 0.3 20.0

Epichlorohydrin G 204 372 0.51 0.001 0.1 100.0

Acrylonitrile H 233 382 0.18 0.06 3.6 1.7

PCB (Gas Condensate) I 16 401 0.36 0.001 0.3 19.4

Phosphorus Oxychloride E 45 410 0.22 0.01 0.6 9.6

Pyrrolidine (Azolidine) B 407 413 9.2 0.012 0.7 8.3

Hydrochloric acid (37%) D 220 417 0.99 0.001 0.1 100.0

Hydrofluoric Acid E 390 420 0.16 0.01 0.6 10.0

Benzonitrile E 420 450 0.31 0.01 0.6 10.0

Tetrahydrofuran G 103 464 0.12 0.001 0.1 100.0

Oleum (40% free SO3) G 220 467 0.32 0.0001 0.0 1000.0

AVERAGE 51.2

The observed cumulative permeation for this list of chemicals averages 51 times less than

the proposed limit of 6.0 ug/cm2. And these materials do not do not have sufficient

barrier to meet all the barrier requirements of NFPA 1991.

It is clear from this analysis that the proposed cumulative permeation requirement of

6 ug/cm2 requires significantly less barrier than the current NFPA 1991 requirements.

The chemicals listed in NFPA 1991 are required not because they represent that possible

hazards, but because they ensure that the requirements are sufficiently broad to protect

against most chemicals. Examine the chemical barrier data published by the

manufacturers of NFPA 1991 certified garments. You will find that these materials offer


8

barrier against many chemicals. By comparison, if you can obtain a comprehensive

barrier data list for NFPA 1992 and NFPA 1994 certified materials, you will find that

there are many chemicals against which those materials do not provide adequate barrier.

Ceiling limits have not been addressed in the proposed change to NFPA 1991. As shown

in the Figure 3, a cumulative permeation requirement does not address skin damaging

peak exposure. Spiking is addressed with the current permeation testing which are

almost all conducted with continuous monitoring or on a 4-minute sampling interval.

There are no peer reviewed and accepted cumulative skin dosage values available for

most industrial chemicals. There are not skin ceiling exposure limits. While a reasonable

argument can be made that the current permeation requirements are too stringent, there

are not demonstrated and accepted limits to move to. At the levels currently set in NFPA

1991, we have not had reports of skin exposure injuries.


9

Appendix – Estimating Cumulative Permeation from Permeation Results

The area under the curve is estimated with rectangles and triangles. The formulas for

measuring the component parts are given below.

a = 60 • MDPR

b = 0.5 • (0.1 – MDPR) • (sBT – aBT)

1

Proposed Changes to NFPA 1991 Barrier Requirements

James P. Zeigler, Ph.D.

September 13, 2011

The purpose of this paper is to review a proposed change in the barrier requirements for

NFPA 1991. In brief, the proposal changes the barrier requirements for the 21 standard

chemicals from breakthrough time to cumulative permeation. Specifically, the change is from

breakthrough time greater than one hour to cumulative permeation less than 6.0 µg/cm

2

in one

hour.

The Technical Committee for Hazardous Materials Protective Clothing and Equipment will meet

on October 10, 2011 in Baltimore to consider this proposal in the form of a Tentative Interim

Amendment (TIA). If adopted, the change will go into effect shortly after the publication of the

2012 edition of the standard in late January or early February. There will be a brief period for

public review and comments on the TIA in the fourth quarter of 2011.

HISTORY OF BARRIER REQUIREMENTS IN NFPA HAZMAT CLOTHING STANDARDS

The initial edition of NFPA 1991 required breakthrough times greater than 1 hour for a list of 21

chemicals. That list (Appendix A) represents a wide range of chemistry which challenges the

barrier material with a variety of chemical interaction. The chemicals on that list consist of small

molecules which further enhances the challenge to the barrier material. The chairman of the

committee at that time recently pointed out that “The presence of any chemical in this battery

does not connote any special significance of the chemical for protecting workers from chemical

hazards. This battery of chemicals is intended to represent a range of chemical classes, hazards,

physical characteristics and other factors. Not all of the chemicals in this battery have any

significance from a skin toxicity or irritation perspective.“

Requiring at least one hour breakthrough against all 21of those chemicals has the effect of

requiring a high level of barrier against many other chemicals. When the first edition of NFPA

1991 was published in 1990, there were no commercial chemical protective garments that could

meet those barrier requirements. Those requirements stimulated development of a number of

new fabrics. Examination of permeation data for a number of those fabrics show that in general

NFPA 1991 compliant barrier fabrics provide barrier for over 95% of the chemicals with which

they are challenged.

Breakthrough time was originally defined as the first time at which the chemical was detected.

In 1995, the definition of breakthrough time was changes. Breakthrough time could be

manipulated by changing the test sensitivity. If the analytical method was less sensitive, the

observed breakthrough time would be longer. In 1995 breakthrough time was standardized as

the time at which the permeation rate reaches 0.1 µg/cm

2

/min (Figure 1). That value was chosen

because it was the lowest sensitivity that all testing laboratories could achieve for all 21

chemicals at that time. An analysis was published in the ASTM Special Technical Publication


2

(STP) demonstrating that this was a safe, conservative value. Today only standardized

breakthrough times are reported with permeation data

Figure 1 – Typical Permeation Curve and How Breakthrough Times are Determined

Figure 2 shows a typical permeation curve and the corresponding cumulative permeation for a

chemical with one hour breakthrough. Cumulative permeation is the area under the permeation

curve.

Cumulative permeation was introduced to NFPA 1991 in 1998 when an emergency amendment

(TIA) was added in response to the growing threat of chemical terrorism. The amendment

included chemical warfare agents and dual-use toxic industrial chemicals (TICs). The barrier

requirements for the chemical warfare agents were based on cumulative permeation using well

established human toxicity data. The one hour breakthrough requirement was applied to the

dual-use TICs. The chemical agents that were chosen in 1998 were lewisite, sulfur mustard,

sarin, VX and the dual-use toxic industrial chemicals were cyanogen chloride gas, phosgene gas,

Figure 2 – Cumulative Permeation – Area under the Permeation Rate Curve


3

hydrogen cyanide gas and dimethyl sulfate. That emergency amendment was incorporated as an

option in the 2000 edition of NFPA 1991 and made mandatory in the 2005 edition. In the 2005

edition, lewisite was removed because it was not considered a threat and VX was removed

because if was considered redundant when sarin was also tested.

In 2001, the Technical Committee for Hazardous Materials Protective Clothing (TC) issued

NFPA 1994 which addressed protective clothing for first responders to chemical, biological and

radioactive terrorism incidents. The chemical battery in NFPA 1994 was limited to two

chemical warfare agents (sarin and mustard) and six TICs (ammonia gas, chlorine gas,

cyanogens chloride gas, hydrogen chloride gas, phosgene gas and dimethyl sulfate. Barrier

requirements for the chemical agents were based on cumulative permeation while breakthrough

time requirements were applied to the TICs.

The initial edition of NFPA 1994 included three classes. The Class 1 testing criteria were the

same as NFPA 1991. For Class 2 and Class 3, the amount of chemical used to challenge the

barrier of fabric was significantly reduced. For Class 2 the liquid challenge concentration was

reduced by more than 10-fold and the gas challenge concentration was reduced by 1000-fold.

The liquid challenge for Class 3 materials was the same as Class 2, but Class 3 materials were

not challenged with gases. Those lower barrier requirements for Class 2 and 3 reflected the

mission of those garments – first response to CBRN terrorism incidents, not hazmat emergency

response.

During deliberation of the next edition of NFPA 1994, the barrier requirements were reduced

further. The gas concentrations were reduced from 1000 ppm in the 2001 edition to 350 ppm for

Class 2 in the 2007 edition. Gases were added back to Class 3 in the 2007 edition at a

concentration of 40 ppm. For reference, 350 pm is 3000-fold lower than required in NFPA 1991

and 40 ppm is 25,000-fold lower than the levels required for NFPA 1991. The low vapor levels

were taken from the premises used to develop the CBRN respirator standard.

In the 2007 edition, phosgene gas, cyanogens chloride gas and hydrogen cyanide gas were

replaced with acrolein and acrylonitrile. That replacement was justified on the basis that the

replacement chemicals were more skin toxic than the gases. Sarin was also replaced with soman

on the basis that soman is less volatile and a greater permeation challenge.

Soon after the 2007 edition was published a series of amendments were added to NFPA 1994.

Those amendments:

Extended the implementation of the standard for 6 months

Changed the barrier requirement for the 5 industrial chemicals from greater than

one hour standardized breakthrough to one hour cumulative permeation less than

6 µg/cm

2

.

Changed acrolein and acrylonitrile challenge concentrations from 10 g/m

2

liquid

challenge to 350 ppm (for Class 2) and 40 ppm for Class 3 vapor challenges.


4

Changed the cut resistance requirements for gloves and footwear to reflect change

in the cut test. That change reflected a change in the test methods and did not

affect the overall performance requirements.

The extension in the implementation was justified on the basis that testing laboratories

experienced delays implementing the higher temperatures and humidity required in the 2007

edition and consequently, certain manufacturers were having delays achieving products

certification to the new edition.

The switch from breakthrough time to cumulative permeation was requested by a manufacturer

which had a product showing early breakthrough times. The permeation curve for that material

exhibited a short-term spike in permeation rate then quickly returned to a low permeation rate.

The derivation of the 6 µg/cm

2

comes from the permeation curve. The 6 µg/cm

2

is the highest

possible level of cumulative permeation area that can theoretically be achieved with a

breakthrough time of one hour or greater (Figure 3). Standardized breakthrough time is the time

at which the permeation rate reaches 0.1 µg/cm

2

/min. If the permeation rate remains just below

0.1 µg/cm

2

/min, the breakthrough criteria is not reached. Multiplying 60 minutes times

0.1 µg/cm

2

/min yields 6 µg/cm

2

.

Figure 3 – Derivation of 6 µg/cm

2

Cumulative Permeation Limit

Cumulative permeation of 6 µg/cm

2

is not a substitute for one hour breakthrough time. Materials

that exhibit breakthrough times of one hour or greater have cumulative permeation that is

significantly lower than 6 µg/cm

2

. Data from 62 separate permeation tests on 11 fabrics are

provided in Appendix B and the technique used to calculate cumulative permeation given in

Appendix C. The actual cumulative permeation obtained from those 62 permeation tests

averages 36-fold less than 6 µg/cm

2

. The data and method are provided so you can confirm the

calculations yourself. All of the fabrics used in these calculations are poorer barriers than those

currently required in NFPA 1991; they do not hold out all 21 chemical for least one hour. NFPA

1991 compliant barrier have better barrier and should exhibit even lower one hour cumulative

permeation.


5

The change in the challenge concentrations for acrolein and acrylonitrile from 10 g/m

2

liquid

exposure to 350 ppm vapor exposure (for Class 2) and 40 ppm vapor exposure (for Class 3) was

justified on the basis that these chemical are volatile and would be completely evaporated during

the 60 minute test. It was further justified on the assumption that during a terrorism incident, the

threat to the responders from these chemicals would be vapor, not liquid exposure.

When the revision of the 2005 edition of NFPA 1991 was opened, a proposal was submitted to

change the barrier requirements from breakthrough time to cumulative permeation. Specifically,

from greater than 1 hour standardized breakthrough to one hour cumulative permeation less than

6 µg/cm

2

for the 21 chemicals and 3 additional TICs. That initial proposal was voted down by

the technical committee (TC). A comment requesting reconsideration of that proposal was

rejected by the TC a year later. The same proposal was presented to the Technical Correlating

Committee, which oversees all protective clothing TC activities, which referred the matter back

to the TC.

However, the final draft of the standard contained an inconsistently in the requirements for the

21 chemicals and the dual-use TICs. The final draft included one hour breakthrough

requirements at 27° C for the 21 chemicals, but one hour cumulative permeation of less than

6 µg/cm

2

at 32° C for the dual use TICs acrolein, acrylonitrile, dimethyl sulfate, chlorine and

ammonia. It appears that some members of the committee relied upon their recollections of the

meeting and did not thoroughly review the final draft language. Some assumed that the TICs

would be tested under the same criteria as the 21 chemicals.

There are other indications that the draft was not thoroughly reviewed. Acrolein and

acrylonitrile are tested as gases in NFPA 1994 and similar language was drafted for NFPA 1991.

However in NFPA 1991, the entire specimen surface is covered with test chemical. Both

chemical boil at temperatures well above 32°C, making it physical impossible to test these

chemical as gases at that temperatures. And the committee members overlooked the redundant

testing of ammonia and chlorine; once using breakthrough time criteria at 27°C then again using

cumulative permeation criteria at 32°C.

The TCC noted these inconsistencies and ordered the TC to resolve the issues. The Technical

Committee will meet on October 10 in Baltimore to consider a TIA that resolve these

inconsistencies. Use of cumulative permeation requirements for the 21 chemical will be

considered again at that meeting. If approved, the TIA would issue shortly after the new standard

in first quarter 2012. There will be a short period of public review and comment on this TIA

during the fourth quarter of 2011.

WHY CUMULATIVE PERMEATION?

The following justifications are used by advocates of cumulative permeation:

Breakthrough times are misleading. A report of “no breakthrough” does not mean that

permeation did not occur. It means that if permeation occurred, it occurred at a rate of

less than 0.1 µg/cm

2

/min.


6

The data provided in Appendix B demonstrates that most materials that exhibit

breakthrough times in excess of one hour present a very low level of cumulative

permeation exposure. Many first responders have been trained and understand that no

observed breakthrough does not mean no permeation.

Cumulative permeation is easier to understand than breakthrough times. It forces

recognition that exposure can occur at low levels. It is correlated with human dosage

values.

First responders are not toxicologist. They need simple criteria to select materials.

Breakthrough time is a simple criterion.

Chemical warfare agents are more inhalation toxic than industrial chemicals. If a level of

4 µg/cm

2

for mustard and 1.25 µg/cm

2

is sufficiently protective for mustard and the nerve

agents (GB, GD, VX) then 6.0 µg/cm

2

should be sufficient for organic chemicals.

Further, models indicate that this limit is protective for the TICs.

Equating inhalation and skin toxicity is a gross generalization. Skin toxicity consider

more than systemic poisoning including skin damage, allergic response and interactions

with human sweat.

A recent report from the Army toxicologists used models to evaluate the toxicity of 210

chemicals. [“Development of Percutaneous Toxicity-based Vapor Permeation Test

Criteria for Personal Protective Materials,” Toxicology Study No. 85-XC-04MC-07,

August 2007, U. S. Army Center for health Promotion and Preventive Medicine. ]

The authors “believe that for 88% of the chemical evaluated, the [breakthrough] criteria

are too stringent.” That suggests that a one hour breakthrough criteria is appropriate

for 12% of the chemicals (one out of ten). That report concludes “retaining the current

TIC criterion of 6.0 µg/cm

2

appears protective for the majority of TICS.” [Emphasis

added].

The authors also recommend lowering the exposure criteria for mustard and VX by a

factor of 10. They point out that hydrogen cyanide and phosgene are high threats for skin

exposure, contrary to the reason given for dropping them from NFPA 1994 in 2005.

One reference cited in the NFPA 1991 Proposal and Comments to justify the use of

cumulative permeation limit of 6 µg/cm

2

is Risk-Based Protective Clothing Material

Permeation Criteria, Technical Support Working Group Contract No. W91CRB-07-C-

0006 Project Final Report.

In response to the TC ballot on the proposed change to cumulative permeation, the

sponsor of that project stated: “The referenced TSWG-sponsored report has not been

validated by independent sources, nor has the data been published widely at this time.

Further review of the data is underway by the Government and will be shared with the

task group working on this issue.”


7

The current requirements favor impermeable material at the expense of other important

material properties such as moisture vapor transfer, material stiffness and weight. If the

permeation criteria were less stringent material that are more ergonomically friendly,

more comfortable and more functional with less potential for hazards such as heat stress

would qualify.

There is a lack of peer-reviewed studies, measuring the core body temperatures of human

subjects exercising in temperatures and humidity above average where the risk of heat

stress is greatest, that show relief of heat stress by high moisture vapor transfer

materials. Should chemical garment barrier requirements be significantly lowered

without proof of a significant benefit?

OTHER CONCERNS

Cumulative permeation does not address ceiling limits. For inhalation toxicity, both long term

exposure (cumulative exposure) and short-term exposure limits are specified. The same is true

for skin exposure. Chemicals that might not be harmful to the skin in low concentrations, such

as corrosives, can be especially dangerous in concentrated form. Figure 4 shows an example of a

spiking permeation curve. It was spiking behavior of a candidate material that initiated a number

of TIA proposals to NFPA 1994.

Figure 4 – Spiking Permeation Behavior

As shown in the Figure 4, a cumulative permeation requirement does not account for the

potential for skin damaging peak exposures. Spiking is addressed with the current permeation

testing which are almost all conducted with either continuous monitoring, a 5-minute sampling

interval or a cumulative permeation acquisition with frequent sampling. In all case, significant

spiking behavior would be detected.

There are no peer reviewed and accepted cumulative skin dosage values available for most

industrial chemicals. There are no skin ceiling exposure limits. Models based on inhalation do

not consider corrosive and allergic skin response. While a reasonable argument can be made that

the current permeation requirements may be too stringent for many chemicals, there are no peer-


8

review, generally accepted exposure limits to support making this significant of a change. The

proposed cumulative permeation limits are considerable less protective than observed with the

current breakthrough limits. And at the current NFPA 1991 requirements, we have not had

reports of skin exposure injuries.


9

Appendix A

ASTM F1001 Chemicals, Classes and Uses

Chemical Name Chemical Class Most Common Use

Acetone Ketone Solvent

Acetonitrle Nitrile Solvent

Ammonia Gas Basic Inorganic Gas Refrigerant

1,3-Butadiene Gas Unsaturated Hydrocarbon Chemical Intermediate

Carbon Disulfide Sulfur Compound Solvent

Chlorine Inorganic Gas Disinfectant

Dichloromethane Aliphatic Halocarbon Solvent

Diethylamine Inorganic Base Chemical Additive

Dimethylformamide Amide Solvent

Ethyl Acetate Carboxylic Acid Ester Solvent

Ethylene Oxide Gas Epoxide Disinfectant

Hexane Hydrocarbon Solvent

Hydrogen Chloride Gas Acidic Gas Chemical Intermediate

Methanol Alcohol Solvent

Methyl Chloride Aliphatic Halocarbon Chemical Intermediate

Nitrobenzene Aromatic Nitro Compound Solvent

Sodium Hydroxide, 50% Inorganic Caustic Solution pH Control

Sulfuric Acid, 93.1% Inorganic Acid Batteries; acid catalyst

Tetrachloroethylene Unsaturated Halocarbon Solvent

Tetrahydrofuran Ether Solvent

Toluene Aromatic Hydrocarbon Solvent

This list is taken from ASTM F1001, Standard Guide for Selection of Chemicals to Evaluate

Protective Clothing Materials


10

Appendix B

Cumulative Permeation for Materials with Breakthrough Times Greater than One Hour.

The following data shows that the assumed 6 µg/cm

2

cumulative permeation limit is significantly

higher (less barrier) than the amount of cumulative permeation observed with materials that meet

the current one hour breakthrough time requirements.

The following table contains permeation data for 62 fabric/chemical combinations that have

breakthrough times greater than one hour. All of these fabrics have poorer barrier that is

currently required by NFPA 1991; none of these fabrics can achieved greater than one hour

breakthrough time against all 21 standard chemicals. Therefore, the cumulative permeation

observed with higher barrier materials will be less than computed here. These results show than

on average, the proposed limit is 6.0 µg/cm

2

is 36 time less protective than the actual cumulative

performance of commercial barrier fabric materials that have breakthrough times greater than

one hour.

Chemical Name

Mat’l

Code

aBT

(min)

sBT

(min)

MDPR

(µg/cm

2

/min)

Observed

Cumulative

Permeation in

60 minutes

Ratio -

Proposed to

Actual

Methanol G 20 63 0.04 3.52 1.7

Methyl ethyl ketone G 0 64 0.001 2.84 2.1

Ethylene oxide gas) G 55 65 0.01 0.712 8.4

Methanol A 25 65 0.001 1.58 3.8

Methylamine B 72 73 0.017 1.02 5.9

Benzene I 44 74 0.02 1.54 3.9

Ethylene Oxide (gas) A 53 75 0.03 1.88 3.2

Ammonia (gas) G 55 79 0.001 0.112 53.8

Hexamethylendiamine I 60 80 0.01 0.600 10

Hexamethylendiamine I 60 80 0.01 0.600 10

Nitric acid (30%) K 55 80 0.001 0.110 54.8

Hydrochloric acid,16% K 45 86 0.005 0.561 10.7

Methyl Cellosolve I 49 89 0.07 4.25 1.4

Hydrochloric acid,37% L 53 92 0.005 0.360 16.7

Pyrrolidine (Azolidine) G 80 100 0.05 3.00 2

Nitrobenzene I 78 102 0.001 0.060 100

Methanol G 51 107 0.02 1.28 4.8

Ethylene Dichloride G 115 118 0.02 1.20 5

Sulfuryl Chloride E 35 120 0.01 0.931 6.4

Ammonia (gas) H 11 124 0.003 1.21 5

Hydrogen Cyanide B 108 135 0.0082 0.492 12.2

Hexane n- I 8 146 0.001 1.03 5.8

Methanol C 120 150 0.01 0.600 10

Acetonitrile G 84 157 0.003 0.180 33.3


11

Methanol B 118 159 0.001 0.060 100

Vinylidine Chloride E 150 170 0.01 0.600 10

Acrolein E 29 178 0.05 3.16 1.9

Cresol-o G 141 180 0.001 0.0600 100

Dichloromethane B 61 181 0.001 0.0600 100

Butyl ether n- G 23 194 0.001 0.457 13.1

Methyl-2-propanol 2- G 147 205 0.02 1.20 5

Sulfuric acid (50%) K 163 208 0.01 0.600 10

Sulfuric acid (50%) K 163 208 0.01 0.600 10

Sulfuric acid (30%) K 135 222 0.005 0.300 20

Methylamine B 204 232 0.001 0.0600 100

Trichloroethane 1,1,2- G 173 232 0.01 0.600 10

Nitromethane G 157 233 0.001 0.0600 100

Phenol G 182 238 0.001 0.0600 100

Gasoline/Alcohol Mix B 170 244 0.011 0.660 9.1

Chlorobenzene G 171 246 0.05 3.00 2

Formic acid (96%) G 172 260 0.001 0.0600 100

Methylene Chloride B 202.67 261 0.001 0.0600 100

Dimethyl Sulfide G 139 271 0.02 1.20 5

Hydrazine G 269 283 0.001 0.0600 100

Methyl hydrazine G 206 283 0.01 0.600 10

Dichloroaniline 3,4- B 216 284 0.001 0.0600 100

Ethylene dibromide G 153 288 0.001 0.0600 100

Tetrahydrofuran A 102.67 313 0.001 0.0600 100

Xylene (iso-mix) G 16 328 0.001 0.367 16.3

Chloroaniline 4- B 323 344 0.001 0.0600 100

Cumene

(Isopropylbenzene)

E 354 364 0.02 1.20 5

Potassium hydroxide

(40%)

K 163 366 0.005 0.300 20

Epichlorohydrin G 204 372 0.001 0.0600 100

Acrylonitrile H 233 382 0.06 3.60 1.7

PCB (Gas Condensate) I 16 401 0.001 0.309 19.4

Phosphorus

Oxychloride

E 45 410 0.01 0.628 9.6

Pyrrolidine (Azolidine) B 407 413 0.012 0.720 8.3

Hydrochloric acid

(37%)

D 220 417 0.001 0.0600 100

Hydrofluoric Acid E 390 420 0.01 0.600 10

Benzonitrile E 420 450 0.01 0.600 10

Tetrahydrofuran G 103 464 0.001 0.0600 100

AVERAGE – Proposed vs. Actual Cum Permeation 35.7

1

None of these examples are known to have exhibited abnormal permeation curves or spiking.

2

All are current or recently commercial chemical barrier materials.


12

Appendix C

Estimation of Cumulative Permeation from Breakthrough Time Data

The following calculations are used to estimate the 60 minute cumulative permeation values

provided in Appendix B from permeation breakthrough data. Cumulative permeation is the area

under the permeation curve for a given period of time. For this example, 60 minutes is used.

Further, this explanation is limited to results where the standardized breakthrough times (sBT)

are greater than one hour, to correspond to the performance requirements of NFPA 1991.

The calculation is divided into two parts as shown in Figure 5. The first part is the rectangular

area under the minimum detectable permeation rate (MDPR) line. The second component is the

triangular area above the MDPR line.

The rectangular component is used in all the calculations:

Cum Perm

Part 1

≤60*MDPR

The rectangular area is an upper estimate of the cumulative permeation. We do not know the

exact permeation rate under this curve, only that it is less than the minimum detectable rate.

Since we are limiting this estimation to cumulative permeation in 60 minutes, the triangular

component only needs to be calculated if there is actual breakthrough (aBT) observed in less

than 60 minutes. In that case, this second, triangular component of the cumulative permeation is

Cum Perm

Part 2

=

0.5*

(

60‐aBT

)

2

*(0.1‐MDPR)

(sBT‐aBT)

The upper estimate of the 60 minutes cumulative permeation is the sum of Part1 and Part 2 is it

is present.

Figure 5 – Calculating Cumulative Permeation from Breakthrough Time Data


13

The derivation of the part 2 is clearer in Figure 6. The area of the triangular section is

Cum Perm

Part 2

=0.5*

(

60‐aBT

)

*X

The area of the smaller triangular is assumed to be proportional to the larger triangle shown in

Figure 7.

Then length of X (the vertical side of the smaller triangle) can be defined as from the length of

the vertical side of the larger triangle multiplied by the ratio of the horizontal sides of the

triangles ([60 – aBT] / [sBT – aBT]).

X=

(

0.1‐mdpr

)

*

60‐aBT

sBT‐aBT

Figure 6 – Calculating the Triangular Area

Figure 7 – Deriving the Vertical Dimension of the Triangular Area


14

And substituting X back into the previous equation,

Cum Perm

Part 2

=0.5*

(

60-aBT

)

*

(

0.1-MDPR

)

*

60-aBT

sBT-aBT

or as shown above

Cum Perm

Part 2

=

0.5*

(

60-aBT

)

2

*(0.1-MDPR)

(sBT-aBT)

With nonencapsulating ensembles, there are no assurances and significant reason to be concerned that

open-circuit, SCBA cannot provide chemical barrier comparable to the requirements that are otherwise

mandated for the rest of the ensemble in NFPA 1991.

Since its inception, NFPA 1991, Standard on Vapor-Protective Ensembles for Hazardous Materials

Emergencies, has required that all ensemble components provide protection against a battery of

chemicals. Originally, this battery consisted of 21 chemicals. This battery was selected for its wide

range in chemical solubility and polymer diffusion characteristics, critical factors in the chemical

permeation through protective materials. The chemicals were not chosen because their represent a

specific threat, although the list includes some high volume, frequently encountered, toxic chemicals.

The requirements that the ensembles protect against all of these chemicals provides a high probability

that the NFPA 1991 compliant ensembles would protect against a high concentration of an unknown

chemical, an unknown mixture mixture or a peculiar environmental condition.

In contrast, military chemical protective equipment is tested against specific chemicals and specific

concentrations, based on the assumption that both the identity and concentration of the chemical

hazards can be determined beforehand. Along these lines, additional chemicals barrier requirements

were added to NFPA 1991, first as options, and then mandated in the 2005 edition, in response the

threat of chemical terrorism. These additional chemicals consisted of chemical warfare agents and

industrial chemicals recognized as potential terrorism weapons. The latter are sometime described as

“dual-use” chemical agents. These five additional chemicals are also utilized in NFPA 1994, Standard on

Protective Ensembles for First Responders to CBRN Terrorism Incidents.

When NFPA 1994 was being developed, the lack of chemical barrier testing of SCBA was recognized.

NIOSH developed a set performance requirements for respirators to accompany that standard. The

testing requirements in the NIOSH CBRN certification program only involve 2 chemicals – sulfur mustard

and sarin. The sarin challenge is only vapor and at a concentration about ½ that of saturated

environment. There is no liquid challenge with sarin. Mustard barrier is determined against liquid and

vapor challenges. The vapor challenge is about 1/3 saturated vapor concentration and the liquid

challenge consists of 43 – 20 uL droplets placed (total of 0.86 ml or 0.03 oz) around the facepiece and

interfaces. There are no other chemicals used on the barrier testing of the respirator. By comparison,

NFPA 1991 requires barrier testing of all ensemble components with exposure to 100% of the chemical

(liquid or vapor) and complete coverage. Therefore, the testing requirements of the NIOSH CBRN

certification are significantly lower than required for components of NFPA 1991 ensembles.

Butyl rubber has become a common polymer for the construction of military facepieces. We do not

have barrier data on the facepieces, but we do have generic data on butyl gloves. The data taken from

the most recent edition of the Pocket Guide for Chemical Protective Clothing for the 26 chemicals in the

proposed NFPA 1991 battery shows that butyl provides poor barrier (< 60 minutes) against 7 and

marginal barrier (<4 hours) against 3 of 25 chemicals. There is no data on the 26th chemicals. This is far

from the high level of chemical performance mandated in NFPA 1991.

Therefore if the committee choses to permit non-encapsulating garment, it is endorsing the use of

respirators with unknown, but likely poorer barrier performance than mandated for the remainder of

the garment.

Change from Normalized Breakthrough Time to Cumulative Permeation Negative based on the following reasons:

1) Cumulative Permeation End‐point 6.0 μg/cm2 is not the same as >60 minute breakthrough time (at 0.1 μg/cm2/min). 6.0 μg/cm2 was chosen arbitrarily with no supporting data to back the performance criteria.

2) Permeation resistance was chosen as the appropriate barrier test for NFPA 1991 and 1994 because the TC determined that the highest level of barrier performance was needed for first responders encountering potentially high hazard chemicals under unknown or uncharacterized conditions that could quickly change.1

3) The thinking on the part of the TC at the time was that relatively no contact with any chemical

should be permitted.1

4) The rate was set at what was considered the lower level of analytical sensitivity for the majority of test chemicals, but also was validated through an analysis of exposure effects of an individual wearer of chemical protective clothing based on the work of Kairys (1989), which was determined to be 0.14 μg/cm2‐min.1

5) End‐user (on the phone during the meeting in Feb. 2014) specifically said that he utilizes the “Manufacturer Data” and not the Technical Data package to make decisions; therefore, should the committee not consider testing all materials to 8 hours since the 1 hour data isn’t being utilized?

6) I proposed that the committee is responsible to prove through data (not statistics) that cumulative is more accurate than breakthrough time. Where is the data to support this conclusion? It’s been proven in “theory” but no data to show the claimed accuracy improvement has been shown to the technical committee to validate the statistical model.

7) If cumulative mass permeation is considered further, the committee should consider consulting a Toxicologist before making the change to ensure the end‐users are going to be adequately protected.

8) Recommendations (one or all of the below):

a) Continue to utilize normalized breakthrough time as the pass/fail criteria for NFPA 1991 b) Specify the required analytical detection method and minimum detectable permeation

rate (MDPR) for all NFPA 1991 Chemicals on the Permeation List c) Increase sampling frequency for normalized breakthrough time to at least 1 minute out

of every 5 minutes during the duration of the test will increase the accuracy to approach cumulative mass

d) Set breakthrough time requirement to actual breakthrough time based on the specified analytical detection method instead of 0.1 μg/cm2/min.

e) Calculate cumulative mass permeation from breakthrough times to collect data for future consideration (Collect cumulative mass permeation data for 60 minutes).

1NFPA Standards on Chemical Protective Clothing – History, Evolution and Current Criteria p. 83‐84

Negative – Permitting Non‐Encapsulating Suit Designs Negative based on the following reasons:

1) Encapsulating and Non‐encapsulating definitions used in NFPA Standards (1992, 1994)

Encapsulating ‐ A type of ensemble that provides vapor‐ or gastight protection, or liquidtight protection, or both, and completely covers the wearer and the wearer's respirator. 1992 (2012) Encapsulating ‐ A type of CBRN protective ensemble that provides vaportight or liquidtight protection to the upper and lower torso, head, hands, and feet and completely covers the wearer and the wearer's respirator. (See also 3.3.56.1, CBRN Terrorism Incident Protective Ensembles and Ensemble Elements, and 3.3.48, Non‐Encapsulating.) 1994 (2012) Non‐encapsulating ‐ A type of ensemble that provides liquid splash protection, but does not provide vapor‐ or gastight protection or liquidtight protection and does not cover the wearer's respirator. 1992 (2012) Non‐Encapsulating ‐ A type of CBRN protective ensemble and ensemble elements that provides liquid splash protection, but does not provide vaportight protection, or liquidtight protections, and does not cover the wearer's respirator. 1994 (2012) Source: http://www.nfpa.org/~/media/Files/Codes%20and%20standards/Glossary%20of%20terms/glossary_of_terms_2013.pdf

2) Level A/NFPA 1991/Fully encapsulating definitions are heavily linked in OSHA, EPA and many

other publications

OSHA: 29 CFR 1926.65 App A A. "Totally‐encapsulating chemical protective suit pressure test" 1.0 ‐ Scope 1.1 This practice measures the ability of a gas tight totally‐encapsulating chemical protective suit material, seams, and closures to maintain a fixed positive pressure. The results of this practice allow the gas tight integrity of a totally‐encapsulating chemical protective suit to be evaluated. 1.2 Resistance of the suit materials to permeation, penetration, and degradation by specific hazardous substances is not determined by this test method.

2.0 ‐ Definition of terms 2.1 "Totally‐encapsulated chemical protective suit (TECP suit)" means a full body garment which is constructed of protective clothing materials; covers the wearer's torso, head, arms, legs and respirator; may cover the wearer's hands and feet with tightly attached gloves and boots; completely encloses the wearer and respirator by itself or in combination with the wearer's gloves and boots. 2.2 "Protective clothing material" means any material or combination of materials used in an item of clothing for the purpose of isolating parts of the body from direct contact with a potentially hazardous liquid or gaseous chemicals. 2.3 "Gas tight" means, for the purpose of this test method, the limited flow of a gas under pressure from the inside of a TECP suit to atmosphere at a prescribed pressure and time interval. Source: https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10652

OSHA: 29 CFR 1910.120 App B Part A. Personal protective equipment is divided into four categories based on the degree of protection afforded. (See Part B of this appendix for further explanation of Levels A, B, C, and D hazards.) I. Level A ‐ To be selected when the greatest level of skin, respiratory, and eye protection is required. The following constitute Level A equipment; it may be used as appropriate; 1. Positive pressure, full face‐piece self‐contained breathing apparatus (SCBA), or positive pressure supplied air respirator with escape SCBA, approved by the National Institute for Occupational Safety and Health (NIOSH). 2. Totally‐encapsulating chemical‐protective suit. 3. Coveralls.(1) 4. Long underwear.(1) 5. Gloves, outer, chemical‐resistant. 6. Gloves, inner, chemical‐resistant. 7. Boots, chemical‐resistant, steel toe and shank.

8. Hard hat (under suit).(1) 9. Disposable protective suit, gloves and boots (depending on suit construction, may be worn over totally‐encapsulating suit). _________ Footnote(1) Optional, as applicable. Part B. The types of hazards for which levels A, B, C, and D protection are appropriate are described below: I. Level A ‐ Level A protection should be used when: 1. The hazardous substance has been identified and requires the highest level of protection for skin, eyes, and the respiratory system based on either the measured (or potential for) high concentration of atmospheric vapors, gases, or particulates; or the site operations and work functions involve a high potential for splash, immersion, or exposure to unexpected vapors, gases, or particulates of materials that are harmful to skin or capable of being absorbed through the skin, 2. Substances with a high degree of hazard to the skin are known or suspected to be present, and skin contact is possible; or 3. Operations must be conducted in confined, poorly ventilated areas, and the absence of conditions requiring Level A have not yet been determined. Source: https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9767

OSHA Technical Manual (OTM) Section VIII: Chapter 1 (See Section C, Table VIII: 1‐1. EPA Levels of Protection) Level A: Vapor Protective suit (meets NFPA 1991) Source: https://www.osha.gov/dts/osta/otm/otm_viii/otm_viii_1.html

EPA Level A

Level A protection is required when the greatest potential for exposure to hazards exists, and when the greatest level of skin, respiratory, and eye protection is required. Examples of Level A clothing and equipment include: positive pressure, full face‐piece self contained breathing apparatus (SCBA) or positive pressure supplied air respirator with escape SCBA; totally encapsulated chemical‐ and vapor‐protective suit; inner and outer chemical‐resistant gloves; and

disposable protective suit, gloves, and boots. Source: http://www2.epa.gov/emergency‐response/personal‐protective‐equipment

Science and Technology of Terrorism and Counterterrorism, Second Edition By Mark A. Prelas, Dabir S. Viswanath, Sudarshan K. Loyalka

“Vapor‐protective clothing is designed to fully encapsulate the user and their respiratory protection within a vapor‐resistant envelope that provides vapor, liquid splash, and particulate protection from the hazardous chemicals that pose the risk.” “Selecting a liquid splash‐protective garment or a vapor‐protective garment can be difficult considering the vast option in the market place. … The most widely utilized consensus documents for chemically protective clothing are those produced by the National Fire Protection Association (NFPA). The NFPA issues a number of standards that define minimum performance requirements for PPE utilized during emergency response… The NFPA technical committees responsible for these standards have emphasized an ensemble concept that ensures that a PPE is designed and tested in such a way as to ensure protection…”

The Complete Guide to OSHA Compliance Joel M. Cohen, Robert D. Peterson, p. 404 (Appendix 6B) “The following constitute a Level A suit… 2. Totally‐encapsulating chemical‐protective suit”

3) Several other key performance requirements have been proposed to be changed in the First

Revision of NFPA 1991‐2015, is the goal to continue reducing requirements until a NFPA 1991 compliant and certified ensemble is found to be “hazardous” per section 4.6.1?

Inward Leakage Requirements have gone from PF 5,000 to PF 1,000 – Decrease by 5x

Permeation Requirements have been decreased by changing to cumulative mass @ 6.0 μg/cm2

4) What aspects of adding non‐encapsulating designs to NFPA 1991 are not already covered by NFPA 1994 Class 2?

What is the advantage/need to now permit non‐encapsulating suits to be certified to NFPA 1991?



the garment.

m e m o r a n d u m - nfpa.org 0 abstain 0 eligible to vote: 31 not returned : 11 donald b....

Documents