The world of hazmat emergency response is, appropriately, mercurial and dynamic. Change is inevitable, and when those first responders who are unwilling to embrace that fact emerge from hibernation, they will be left bewildered by the sight of a new response capability landscape.
The fire service has experienced, and embraced, rapid procedural and technological progress during the past couple of generations, and the hazmat emergency response community has been at the forefront of that advance. Nevertheless, with new specifications and requirements sprouting left and right, it’s easy for even the most dedicated “hazmatician” to lose sight of the latest standards and the significance of the changes.
Some of the changes that have created confusion and prompted head-scratching within the response community are the latest revisions to standards for PPE and chemical protective clothing (CPC) ensembles. The days of simply thumbing through an equipment catalog to find a plain ol’ Level B suit are, for hazmat teams and first responders, essentially over; the threat of chemical, biological, radiological and/or nuclear (CBRN) attacks has complicated the issue. The original civilian CPC specifications did not directly address warfare agents and that created a capability gap in need of immediate remedy. Although initial testing suggested that the CPC available 15 years ago might provide basic, short-term protection for response personnel from some potential terrorist agents, the risks faced, based upon plausible threat assessment, made it clear that “might” and “some” were not suitable words for the CBRN response vocabulary.
When the murmurs of concern began to include not only the traditional fire service and hazmat response teams, but also law enforcement organizations, federal agencies and military assets, it became clear that a new era in CPC had dawned. As a result, a series of revisions to our national standards has altered the way we think about how we respond to hazardous materials emergencies and how we choose our CPC inventory.
The NFPA has been developing codes for protective ensembles in hazmat environments for more than 2 decades and has established standards for CPC that are in use by hazmat teams around the world. Originally developed by the standing Subcommittee on Hazardous Materials Protective Clothing during the mid- to late-1980s, the first edition of NFPA 1991: Standard on Vapor-Protective Suits for Hazardous Chemical Emergencies was a landmark project to create a protective clothing benchmark for use by hazmat emergency responders while working within a hazardous chemical environment. The scope of the standard was designed around the concerns of the day: industrial chemical incidents that occurred in facilities and during transport. To that end, the regulation focused on creating specifications for a suit that would protect the responder in chemical vapor and liquid splash surroundings.
The standard evolved through two more editions, during which time project reorganization saw the subcommittee elevated to the current Technical Committee on Hazardous Materials Protective Clothing and Equipment. With the new editions came technical updates, provisions for optional chemical and biological warfare agent protection criteria, and a new perspective of the garment as an ensemble (hence the current, updated title: Standard on Vapor-Protective Ensembles for Hazardous Materials Emergencies).
By the time the third edition of NFPA 1991 became effective in February 2000, the technical committee had already begun work on a new standard to address the needs of fire and emergency services personnel operating at incidents involving terrorist use of chemical or biological (chem/bio) agents. This regulation, NFPA 1994: Standard on Protective Ensemble for Chemical/Biological Terrorism Incidents, was approved in 2001 and sought to shed some light on the murky issues surrounding protective clothing options and use for emergency responders. Furthermore, NFPA 1994 endeavored to institute requirements that the ensemble be appropriate for single-exposure usage, adaptable to the incident based on the risks faced, and easy to don and use.
In order to meet those goals, three classes of protective ensembles were designated:
- Class 1 ensembles specified the highest level of protection at chem/bio terrorism incidents for unknown vapor or liquid agents or concentrations, to prevent exposure to hazardous vapors, and to preclude skin contact with extremely hazardous liquids; many were very similar to the NFPA 1991 suits of the time.
- Class 2 ensembles were designed for incidents involving non-ambulatory, symptomatic patients and probable contact with liquid or aerosol agents.
- Class 3 ensemble specifications were developed to address an incident where the victims are ambulatory and symptomatic, and there was a possibility of contact with liquid or aerosol agents.
This was the first foray into standardizing protective clothing requirements for the emerging terrorist threat.
Here & Now: NFPA 1991 vs. NFPA 1994
When NFPA 1991 was revised for the 2005 edition, the CBRN criteria from the NFPA 1994 Class 1 Ensemble were absorbed into the 1991 standard. To solve the resulting ensemble redundancy, the Class 1 designation was discontinued from use in NFPA 1994 when it was revised in 2007; while three classes still remained, the numbering order now extended from Class 2 to Class 4, and the intended use shifted as well.
Confused? Think of it this way: NFPA 1991 applies primarily to protective clothing and equipment for hazmat response teams working at the scene of a hazmat release, while NFPA 1994 applies the standard to first responders as well as hazmat teams operating at the scene of a CBRN terrorist incident.
Basically, in order to get a broader view of the needs and mission requirements of first responders, the technical committee actually took a step back so that the specification could move forward to become more logical, accessible and user-friendly. By adopting a wider field of view for mission needs, the target audience became more inclusive, embracing law enforcement, emergency medical personnel and any other public safety responder, in addition to the traditional fire and emergency response services. As such, NFPA 1994 has something for everyone in the emergency response community.
A Closer Look
NFPA 1991 establishes the standards for vapor-protective ensembles that ensure their performance during the most demanding hot-zone conditions, from industrial chemical releases to terrorist attacks—conditions under which a hazmat technician or well-trained responder will need the highest level of protection available to complete the required tasks. These ensembles have been put through a rigorous battery of tests to ensure the specifications meet real-world requirements for maximum, fully encapsulated protection when used with the specified SCBA.
All NFPA 1994 ensembles are designed for use during CBRN terrorism incidents, all require the use of a NIOSH-approved CBRN respirator, and all are designed for single-exposure use. Note: The ensembles may be certified to meet the requirements of more than one class, and can also be designed to meet the exacting standards of NFPA 1991 and 1992 as well.
The NFPA 1994 Class 2 ensemble is the highest level of protection recommended for use by first responders functioning in environments containing CBRN terrorism agents. The ensemble is tested against several industrial chemicals, albeit fewer chemicals than NFPA 1991 garments, and also against chemical warfare agents. These, too, are designed to withstand a comprehensive performance challenge, although it is less stringent. They are designed for use at incidents where vapor, liquid or particulate hazards from terrorist dissemination are at or above immediately dangerous to life and health (IDLH) levels and require the use of an approved CBRN SCBA.
Class 3 ensembles are designed for missions where the vapor, liquid or particulate hazards are below IDLH levels, thus allowing the use of a CBRN air-purifying respirator (APR) or a CBRN powered air-purifying respirator (PAPR). Because this class of ensemble and higher were developed under the premise of longer-duration operations, the performance specification includes a total heat loss (THL) requirement; this has led to the introduction of breathable semi-permeable or selectively permeable materials for suit construction.
The final NFPA 1994 category, the Class 4 ensemble, was developed to meet the needs of responders operating on the periphery of an incident or at an incident with unique circumstances. These garments were designed to provide protection from biological and radiological (bio/rad) particulate matter below IDLH levels when used with an appropriate CBRN APR or PAPR. They do not provide any specified chemical agent protection, nor do they provide a barrier for vapors, gases or aerosols, although they may provide some liquid protection to allow decontamination. They also have a higher THL requirement than Class 3 ensembles, making them suitable for extended operational periods. This class of garment is very suitable for the “white powder” responses that have become so familiar to many.
For CBRN terrorism incidents, NFPA 1994 classification somewhat aligns with traditional control zones: Class 2 for the hot zone, Class 3 for hot or warm zones, and Class 4 for cold zone areas or distinct particulate situations. Of course, there will always be complex situations that pose a dilemma when the hazards overlap, so a thorough understanding of the specifications and capabilities of each ensemble is still important.
Which Standard Should You Follow?
Choosing which standard is appropriate for use really comes down to an honest assessment of the potential threats faced by a jurisdiction, the training and capabilities of the response personnel, and the plan to align the two. NFPA 1991 designates very high-performance protective ensembles that are more suitable for hazmat teams and well-trained operators, due not only to the fact that these garments are appropriate for multi-faceted hot zone duties, but also because of the increased difficulty in donning, doffing and maintaining them, as well as functioning in them. NFPA 1994, on the other hand, targets an audience that perceives the need to be prepared for a low-probability/high-consequence event by providing an array of low-maintenance, effective protection that’s suitable for first-arriving emergency personnel.
Another way of looking at this would be assessing where the responder will work at the scene of an incident. If personnel will be performing mitigation duties in the hot zone of a train derailment spill involving multiple undetermined industrial chemicals, then those tasks would require hazmat technicians, and NFPA 1991 is the obvious way to go—initially. And what if it’s a CBRN terrorist incident? Is NFPA 1991 or NFPA 1994 Class 2 most appropriate? It depends on the level of concern for the hazards present, the training level of the responders and the resources available to support tactical operations. Developing standard operating procedures or guidelines (SOPs/SOGs) in conjunction with garment purchase will help alleviate decision-matrix fears at the time of use and promote rapid deployment of resources.
Factors Affecting Suit Selection
Beyond the mission requirements, there are a number of other factors that affect suit selection. Cost is an obvious issue (although this has been offset lately by Homeland Security grant funding), and the 1991 standard ensembles are typically more expensive, sometimes considerably more, than those designed for NFPA 1994 requirements. The cost factor can affect the number of garments of a certain specification that can be fielded during an incident or series of incidents.
Comfort is another issue that must be considered, particularly for long-duration incidents where responders will need to remain in their PPE for extended operational periods. If conditions allow, breathable NFPA 1994 Class 3 and Class 4 ensembles are much more comfortable to wear than those that lack a THL requirement. And don’t forget: NFPA 1994 allows ensembles to be certified to meet the requirements of NFPA 1991 and NFPA 1992, so it may be possible to find breathable garments that can be used beyond the CBRN WMD environment. The flip side of this flexibility is that the purchaser needs to choose ensembles very carefully to prevent needless purchase of suits that have duplicate capabilities in spite of their different primary classification.
There are many ensembles available to meet the needs of each response community, with more being developed at a rapid rate. For the latest information on grant-purchasable ensembles and equipment, check with the FEMA Responder Knowledge Base (www.therkb.com) and the InterAgency Board for Equipment Standardization and Interoperability (IAB) Standardized Equipment List (https://iab.gov/SEL.aspx).
The hazmat PPE selection process shouldn’t be a daunting task, but rather an opportunity—a chance to network with peers and partner agencies, as well as to develop contacts within the supplier industry. Discussing needs and challenges within the local and regional response communities and beyond can lead to creative solutions to the PPE selection paradox—solutions that promote the overall goal of our profession: saving lives, including our own.
National Hazardous Materials Fusion Center launches Web portal to promote sharing resources
First responders now have one more tool in their hazmat response toolbox: the National Hazardous Materials Fusion Center’s Web portal (www.hazmatfc.com), a responder-driven data collection, analysis and education center. The portal is the central element of the Hazmat Fusion Center, a program established and supported through a cooperative agreement between the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) and the IAFC.
The portal aims to close a gap in the nationwide, hazmat-information sharing capabilities by providing responders with the opportunity to both contribute to and access a suite of readily available resources. This free resource serves as a one-stop shop for hazmat-response information, including training packages, reports, incident-based case studies, statistics, trends, alerts, recommendations and peer-to-peer networking.
Emergency responders must register either an individual or agency user to access secure portions of the portal. Registered responders may view full Regional Incident Survey Teams (RIST) survey reports, smart practices and lessons learned and may participate in the hazmat discussion forum and bulletin boards. Agencies that respond to hazmat incidents may register to use the Hazmat Fusion Center’s incident-reporting system. Registration is free.
For more information, visit the Hazmat Fusion Center online or e-mail [email protected].