Technical Committee on Flash Protective Garments

Date: October 6, 2014

To: Technical Committee on Flash Fire Protective Garments

From: Eric Nette, Staff Liaison/Engineer

Re: Agenda Package – NFPA 2112 A2016 First Meeting – November 4-6, 2014

Enclosed is the agenda package for the November 4-6, 2014 meeting for the NFPA 2112 First Draft Meeting. Please ensure that you have reviewed the public input and the other agenda items in advance to prepare for discussion. The agenda and public input will be posted on the document information pages (www.nfpa.org/2112).

Some items to have available during the meeting include:  Agenda package with public input  A copy of NFPA 2112 (visit the NFPA 2112 Document information pages for your free committee copy)  Any previous copies of the technical committees standard  A laptop

Optional items that are sometimes useful include:  Review of NFPA’s Process, www.nfpa.org/regs

If you have any questions or comments, please feel free to reach me at (617) 984-7434 or by e-mail at [email protected]. I look forward to our meeting to begin the revision cycle!

Technical Committee on Flash Fire Protective Garments AGENDA

NFPA 2112 A2016 First Draft Meeting November 4-6, 2014 Doubletree Hotel New Orleans http://nfpa.adobeconnect.com/flg-aaa/ 8:00 a.m. to 5:00 p.m. (Central Time Zone)

1. Meeting opening, introduction and attendance

2. Approval of Second Draft Web/teleconference Meeting Minutes of September 17, 2013 (Attachment A. 2113 Meeting Minutes). 3. Chair's remarks, Steven Corrado 4. ASTM F1930 5. Staff Liaison update: a. A2016 Schedule (Attachment B. A2016 Revision Cycle) b. Committee Membership Update (Attachment C. FLG-AAA Membership) c. Standards Process Review (Attachment D. NFPA Process – Quick Reference Guide) 6. New Business a. Public Input for NFPA 2112 (Attachment E., NFPA 2112 - A2016 Public Input) b. Development of First Revisions (Attachment D. NFPA Process – Quick Reference Guide) 7. Other business 8. Date/Location of Next Meeting. (Second Draft Meeting between July 1, 2015 and October 30, 2015) 9. Adjournment

Attachments: A. 2113 SD Web/teleconference Meeting Minutes B. A2016 – Revision Cycle C. FLG-AAA Committee Membership D. NFPA Process – Quick Reference Guide E. NFPA 2112 - A2016 Public Input

Attachment A: 2113 Second Draft Web/teleconference Meeting Minutes

COMMITTEE ON FLASH FIRE PROTECTIVE GARMENTS

TO: COMMITTEE ON FLASH FIRE PROTECTIVE GARMENTS

FROM: G. R. Colonna, Staff Liaison

DATE: September 30, 2013

SUBJ: Minutes of NFPA 2113 Second Draft Meeting, September 17, 2013 ______

I. Attendance: (web and conference call meeting)

Members and Alternates:

Steven Corrado, UL LLC, NC, Committee Chair

Steven Addington, Eastman Chemical Company, TN Peter Clark, Apparel Solutions International Inc., AB (Alberta Burn Rehabilitation Society) James Dale, University of Alberta, AB William Fithian, Safety Equipment Institute (SEI), VA Tricia Hock, Safety Equipment Institute (SEI), VA Amanda Newsom, UL LLC, NC Roger Parry, DuPont, VA David Pickard, XTO Energy, TX Mark Saner, Workrite Uniform Company, Inc., CA Brian Spears, Dow Corning Corporation, KY (NFPA Industrial Fire Protection Section) Denise Statham, VF Imageware/Bulwark Protective Apparel, TN Guy R. Colonna, NFPA, Staff Liaison

Guests:

Sean Deaton, NC State, NC Scott Margolin, Westex, IL Laura Montville, NFPA Staff

II. Minutes of Meeting

1. The Chair called the meeting to order at 1:00 p.m., Tuesday, September 17, 2013 and staff conducted a roll-call of attendees. FLG-AAA Meeting Minutes September 17, 2013 (Conference call and web meeting)

2. The Chair outlined the key action item for the meeting - completion of the Committee review of Public Comments to the First Draft of NFPA 2113 and development of the Second Draft for the standard.

3. Staff provided an update on the Committee membership, the new standards making process, and recruitment for the open NFPA staff position. The remaining document revision schedule was also reviewed for the Annual 2014 schedule.

4. The Committee began work by reviewing the one Public Comment submitted. An SR was developed to incorporate the recommended changes from the PC. The Committee also approved a second SR. There being no other agenda items related to the Second Draft of NFPA 2113, the Committee directed staff to finalize the SR actions and prepare the letter ballot.

5. Other Business.

A. Sean Deaton, North Carolina State, shared information regarding his research on stand-alone protection for head and hands. The work involves burn prediction, but no specific standardized test methods are in place yet. The Chair acknowledged that this might be something to discuss as part of the next 2112 revision. The Chair asked whether the Committee should expand 2112 to cover full body - boots, gloves, head, and hands. It was noted that boots and gloves have other mechanical issues to be addressed before focusing on fire resistance. The general consensus of the Committee at this stage was to not go forward with any expansion of the standard; however, the Committee would be prepared to address expansion requests if proposed by others.

B. As a result of incidents involving iron dust flash and resultant personnel burns, another item raised deals with the suitability of current FRC test methods in 2112 when applied to combustible metals. The number of variables introduced when the dispersed is a combustible metal complicates the testing and evaluation of garment performance against flash fires involving such materials. No members of the Committee were aware of any proposed work to look into these questions further at this time. No further action item resulted from this discussion at this time.

6. Next Meeting. The Committee's next meeting will be to review and act on Public Input to NFPA 2112 and to develop the First Draft. NFPA 2112 is currently in the Annual 2016 revision cycle, which means a closing date for submitting Public Input of July 7, 2014. The Committee must meet to prepare the First Draft no later than December 12, 2014. The Chair and Staff will review the dates further and propose options for dates and location for the meeting.

7. There being no further business, the meeting adjourned at 2:35 p.m., Tuesday, September 17, 2013.

Respectfully submitted, G. R. Colonna, Staff Liaison

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Attachment B: A2016 Revision Cycle

2016 ANNUAL REVISION CYCLE *Public Input Dates may vary according to standards and schedules for Revision Cycles may change. Please check the NFPA Website for the most up‐to‐date information on Public Input Closing Dates and schedules at www.nfpa.org/document # (i.e. www.nfpa.org/101) and click on the Next Edition tab. Dates for Process Process Step Dates for TC with Stage TC CC Public Input Closing Date for Paper Submittal* 6/6/2014 6/6/2014 Public Input Closing Date for Online Submittal (e‐PI)* 7/7/2014 7/7/2014 Final Date for TC First Draft Meeting 12/12/2014 9/12/2014 Public Input Posting of First Draft and TC Ballot 1/30/2015 10/24/2014 Stage Final date for Receipt of TC First Draft ballot 2/20/2015 11/14/2014 (First Draft) Final date for Receipt of TC First Draft ballot ‐ recirc 2/27/2015 11/21/2014 Posting of First Draft for CC Meeting 11/28/2014 Final date for CC First Draft Meeting 1/9/2015 Posting of First Draft and CC Ballot 1/30/2015 Final date for Receipt of CC First Draft ballot 2/20/2015 Final date for Receipt of CC First Draft ballot ‐ recirc 2/27/2015 Post First Draft Report for Public Comment 3/6/2015 3/6/2015

Public Comment Closing Date for Paper Submittal* 4/10/2015 4/10/2015 Public Comment Closing Date for Online Submittal (e‐PC)* 5/15/2015 5/15/2015 Final Date to Publish Notice of Consent Standards (Standards that 5/29/2015 5/29/2015 received no Comments) Appeal Closing Date for Consent Standards (Standards that received 6/12/2015 6/12/2015 no Comments) Final date for TC Second Draft Meeting 10/30/2015 7/24/2015 Comment Posting of Second Draft and TC Ballot 12/11/2015 9/4/2015 Stage Final date for Receipt of TC Second Draft ballot 1/4/2016 9/25/2015 (Second Final date for receipt of TC Second Draft ballot ‐ recirc 1/11/2016 10/2/2015 Draft) Posting of Second Draft for CC Meeting 10/9/2015 Final date for CC Second Draft Meeting 11/20/2015 Posting of Second Draft for CC Ballot 12/11/2015 Final date for Receipt of CC Second Draft ballot 1/4/2016 Final date for Receipt of CC Second Draft ballot ‐ recirc 1/11/2016 Post Second Draft Report for NITMAM Review 1/18/2016 1/18/2016

Tech Session Notice of Intent to Make a Motion (NITMAM) Closing Date 2/19/2016 2/19/2016 Preparation Posting of Certified Amending Motions (CAMs) and Consent 4/15/2016 4/15/2016 Standards (& Issuance) Appeal Closing Date for Consent Standards 5/3/2016 5/3/2016 SC Issuance Date for Consent Standards 5/13/2016 5/13/2016

Tech Session Association Meeting for Standards with CAMs 6/6‐9/2016 6/6‐9/2016

Appeals and Appeal Closing Date for Standards with CAMs 6/29/2016 6/29/2016 Issuance SC Issuance Date for Standards with CAMs 8/4/2016 8/4/2016

Approved:__October 30, 2012 Revised___March 7, 2013______

NFPA 2112 Revision Cycle KEY DATES Annual 2016

NFPA 2112 A2016 [FLG-AAA] Important Dates For the Cycle: Public Input Closing (Paper) June 6, 2014 (DONE) Public Input Closing (Digital) July 7, 2014 (DONE) Posting of First Draft January 30, 2015 Public Comment Closing (Paper) April 10, 2015 Public Comment Closing (Digital) May 15, 2015 Posting of Second Draft December 11, 2015 Notice of Intent to Make Motion (NITMAM) February 19, 2016 Issuance of Consent Standard May 13, 2016 (published bit later) NFPA Annual Meeting with CAMs June 6-9, 2016 Issuance of Standard – with CAMs August 4, 2016 (published bit later)

Attachment C: FLG-AAA Committee Membership

Address List No Phone 10/03/2014 Eric Nette Flash Fire Protective Garments FLG-AAA

Steven D. Corrado RT 7/22/1999 Steven Addington U 8/5/2009 Chair FLG-AAA Principal FLG-AAA UL LLC Eastman Chemical Company 12 Laboratory Drive 100 Eastman Road, B54D PO Box 13995 Kingsport, TN 37662 Research Triangle Park, NC 27709-3995 Alternate: Amanda H. Newsom

Peter Clark M 1/1/1999 Terry K. Clark U 8/2/2010 Principal FLG-AAA Principal FLG-AAA Apparel Solutions International Inc. Anadarko Petroleum Corporation 8708 - 106 Street, Suite 601 1099 18th Street, Suite 1800 Edmonton, AB T6E 4J5 Canada Denver, CO 80202 Alberta Burn Rehabilitation Society Alternate: Michael R. Farris

James Douglas Dale RT 1/1/1999 Alec Feldman SE 8/2/2010 Principal FLG-AAA Principal FLG-AAA University of Alberta Fulcrum Consultants Department of Mechanical Engineering 47, Rathfarnham Park Edmonton, AB T6G 2G8 Canada Dublin, 14 Ireland JOIFF-International Organisation for Industrial Hazard Management

William A. Fithian RT 7/23/2008 Keith W. Harned U 03/05/2012 Principal FLG-AAA Principal FLG-AAA Safety Equipment Institute (SEI) Louisiana Pacific Building Products 1307 Dolley Madison Blvd., Suite 3A 414 Union Street, Suite 2000 McLean, VA 22101 Nashville, TN 37122 Alternate: Tricia L. Hock

Darren D. Hewston U 08/11/2014 Pamela A. Kavalesky RT 10/28/2008 Principal FLG-AAA Principal FLG-AAA Plains Exploration & Production Company Intertek Testing Services 717 Texas Avenue, Suite 2100 3933 US Route 11 Houston, TX 77002 Cortland, NY 13045-9717 Alternate: Jason L. Allen

Joshua D. Moody M 4/14/2005 Catherine J. Morin SE 1/1/1999 Principal FLG-AAA Principal FLG-AAA Milliken & Company/Westex, Inc. Morin Associates 2845 West 48th Place 118 Andrew Court Chicago, IL 60632 Centreville, MD 21617

Roger F. Parry M 4/28/2000 David P. Pickard U 8/2/2010 Principal FLG-AAA Principal FLG-AAA The DuPont Company, Inc. XTO Energy 5401 Jefferson Davis Highway One Riverway, Suite 700 PO Box 27001 Houston, TX 77056 Richmond, VA 23234 Alternate: David C. Klinger

1 Address List No Phone 10/03/2014 Eric Nette Flash Fire Protective Garments FLG-AAA

Jason P. Reason SE 07/29/2013 Mark S. Saner M 7/28/2006 Principal FLG-AAA Principal FLG-AAA Lewellyn Technology Workrite Uniform Company, Inc. 321 North 18th Avenue 1701 North Lombard Street Beech Grove, IN 46107 Oxnard, CA 93030

Brian P. Shiels M 08/11/2014 Brian M. Spears U 3/1/2011 Principal FLG-AAA Principal FLG-AAA PBI Performance Products, Inc. Dow Corning Corporation 9800-D Southern Pine Boulevard 4770 Highway 42E Charlotte, NC 28273 Carrollton, KY 41008 NFPA Industrial Fire Protection Section

Michael T. Stanhope M 4/28/2000 Denise N. Statham M 10/20/2010 Principal FLG-AAA Principal FLG-AAA TenCate/Southern Mills, Inc. VF Imagewear/Bulwark Protective Apparel 6501 Mall Boulevard 545 Marriott Drive PO Box 289 Nashville, TN 37214 Union City, GA 30291-1519

James J. Swiss SE 1/1/1999 David C. Wedge M 3/1/2011 Principal FLG-AAA Principal FLG-AAA Swiss Environment & Safety Inc. Draper Knitting Company, Inc. 145 Evergreen Way SW 28 Draper Lane Calgary, AB T2Y 3K8 Canada Canton, MA 02021

James A. Womble U 1/1/1999 Neil P. Wu SE 3/4/2009 Principal FLG-AAA Principal FLG-AAA Avista Corporation Exponent, Inc. 1411 East Mission Avenue 17000 Science Drive, Suite 200 Spokane, WA 99220 Bowie, MD 20715-4427 Alternate: Andrew D. Ellison

Jason L. Allen RT 10/28/2008 Andrew D. Ellison SE 8/2/2010 Alternate FLG-AAA Alternate FLG-AAA Intertek Testing Services Exponent, Inc. 3933 US Route 11 9 Strathmore Road Cortland, NY 13045-9715 Natick, MA 01760-2418 Principal: Pamela A. Kavalesky Principal: Neil P. Wu

Michael R. Farris U 8/2/2010 Tricia L. Hock RT 03/05/2012 Alternate FLG-AAA Alternate FLG-AAA Anadarko Petroleum Corporation Safety Equipment Institute (SEI) PO Box 8482 1307 Dolley Madison Blvd., Suite 3A The Woodlands, TX 77387 McLean, VA 22101 Principal: Terry K. Clark Principal: William A. Fithian

2 Address List No Phone 10/03/2014 Eric Nette Flash Fire Protective Garments FLG-AAA

David C. Klinger M 10/20/2010 Amanda H. Newsom RT 10/20/2010 Alternate FLG-AAA Alternate FLG-AAA The DuPont Company, Inc. UL LLC 5401 Jefferson Davis Highway 12 Laboratory Drive Richmond, VA 23112 PO Box 13995 Principal: Roger F. Parry Research Triangle Park, NC 27709-3995 Principal: Steven D. Corrado

Eric Nette 04/16/2014 Staff Liaison FLG-AAA National Fire Protection Association 1 Batterymarch Park Quincy, MA 02169-7471

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Attachment D: NFPA Process – Quick Reference Guide

New Process – Quick Reference Guide For additional information on the Regulations visit: www.nfpa.org/Regs

There are only three actions a TC can take at the First Draft (ROP) meeting: 1. Resolve a Public Input (no change to the document) 2. Create a First Revision (change to the document) 3. Create Committee Input

Resolve Public Input (no change to the document)  TC must provide a response (Committee Statement/CS) to ALL Public Input (proposal).  CS for not doing what is suggested  Sample Motion: “I make a motion to resolve PI#_ with the following committee statement__.” Approval by meeting vote (simple majority). Not subject to Ballot.

Create a First Revision (change to the document)  TC must create a First Revision (FR) for each change they wish to make to the document, either using Public Input for the basis of the change or not using a Public Input for the basis. One or more Public Input can be considered for the FR.  All Public Input requires a response  TC can use a Public Input for basis i. Sample Motion: “I make a motion to revise section __ using PI#_ as the basis for change.” Approval by meeting vote (simple majority) and final approval through ballot.  TC develops revision without a Public Input for basis i. Sample Motion: “I make a motion to revise section __ as follows___.” Approval by meeting vote (simple majority) and final approval through ballot.  First Revisions require a committee statement

Committee Input  TC may create a Committee Input (CI). This replaces the old system “rejected” Committee Proposals. CIs will get printed in the report but will not be balloted or shown as a change in the draft. CIs are used to solicit public comments and/or as a placeholder for the comment stage. i. Sample Motion: “I make a motion to create a CI with a proposed revision to section__ as follows___.” Approval by meeting vote (simple majority). Not subject to ballot.  Requires a committee statement to explain the intent of making a CI.

Comparison to Previous Process:

PREVIOUS ACTIONS CURRENT PROCESS ACTIONS SAMPLE MOTION Accept or any variation of Accept 1) Committee generates a First 1) “I make a motion to (APA, APR, APP) on a public Revision and Substantiation (CS) revise section __ using proposal for change PI#_ as the basis for change.” 2) Committee provides response (CS) 2) “ I make a motion to to each PI that is associated with the resolve PIs#_ through ## revision with the following

statement__”

Rejected Public Proposal Committee provides response (CS) “I make a motion to resolve to PI PI#_ with the following committee statement__.”

Accepted Committee Proposal Committee generates a First Revision “I make a motion to revise and Substantiation (CS) for change section __ as follows___.”

Committee generates a statement for reason for change Rejected Committee Proposal Committee generates a Committee “I make a motion to create a CI Input (CI) and reason (CS) for with a proposed revision to proposed change section__ as follows___.”

Committee generates a statement for reason for CI. Notes: 1) All meeting actions require a favorable vote of a simple majority of the members present. 2) All First Revisions will be contained in the ballot and will require a 2/3 affirmative vote to confirm the meeting action. 3) Only the First Revisions will be balloted. PIs and CIs will be contained in the report but will not be balloted. 4) Comments may be submitted on all PIs, FRs and CIs

Term Comparison between Current and Old:

CURRENT TERM OLD TERM

Input Stage ROP Stage

Public Input (PI) Proposal

First Draft Meeting ROP Meeting

Committee Proposal that Fail Committee Input Ballot Committee Statement Committee Statement (CS) Committee Proposal or Accepted First Revision (FR) Public Proposal

First Draft Report ROP

First Draft ROP Draft

Comment Stage ROC Stage

Public Comment Public Comment

Second Draft Meeting ROC Meeting

Committee Comment that Fail Committee Comment Ballot

Committee Action Committee Action

Committee Comment or Accepted Second Revision Public Comment

Second Draft Report ROC

Second Draft ROC Draft

Note: The highlighted terms are the ones that will be most applicable at the First Draft Meeting.

Attachment E: NFPA 2112 – A2016 Public Input

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

Public Input No. 26-NFPA 2112-2014 [ Global Input ]

Change title to: “Flame-Resistant Garments Clothing for Protection of Industrial Personnel Against Flash Fire.”

Additional Proposed Changes

File Name Description Approved 2112_Stull_Public_Input_Global-done.pdf PI Form

Statement of Problem and Substantiation for Public Input

A change in the scope for this standard has been proposed to extend criteria to helmets, hoods, gloves, footwear, and rainwear. A previous petition to the Standards Council indicated that these changes were considered with the scope of the current Technical Committee. Additional input showing specific changes to the standard are being submitted electronically. The industry for flash protection current lacks any specific criteria for these additional items, which are equally important to the protection of workers who may be exposed to accidental flash fires.

Submitter Information Verification

Submitter Full Name: Jeffrey Stull Organization: International Personnel Protec Street Address: City: State: Zip: Submittal Date: Mon Jun 09 12:50:24 EDT 2014

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NOTE: All Public Input must be received by 5:00 pm EST/EDST on the published Public Input Closing Date. FOR OFFICE USE ONLY For further information on the standards-making process, please contact the Codes and Standards Administration at 617-984-7249 or visit www.nfpa.org/codes. Log #: For technical assistance, please call NFPA at 1-800-344-3555 Date Rec’d:

Date 5/31/2014 Name Jeffrey O. Stull Tel. No. 512-288-8272 Company International Personnel Protection, Inc. Email [email protected] Street Address P. O. Box 92493 City Austin State TX Zip 78709 Please indicate organization represented (if any) 1. (a) Title of NFPA Flame-Resistant Garments for Protection of Industrial NFPA No. & Year 2112 (2012) Standard Personnel Against Flash Fire (b) Section/Paragraph

2. Public Input Recommends (check one): new text revised text deleted text 3. Proposed Text of Public Input (include proposed new or revised wording, or identification of wording to be deleted): [Note: Proposed text should be in legislative format; i.e., use underscore to denote wording to be inserted (inserted wording) and strike- through to denote wording to be deleted (deleted wording).]

Change title to: “Flame-Resistant Garments Clothing for Protection of Industrial Personnel Against Flash Fire.”

4. Statement of Problem and Substantiation for Public Input: (Note: State the problem that would be resolved by your recommendation; give the specific reason for your Public Input, including copies of tests, research papers, fire experience, etc. If more than 200 words, it may be abstracted for publication.)

A change in the scope for this standard has been proposed to extend criteria to helmets, hoods, gloves, footwear, and rainwear. A previous petition to the Standards Council indicated that these changes were considered with the scope of the current Technical Committee. Additional input showing specific changes to the standard are being submitted electronically. The industry for flash protection current lacks any specific criteria for these additional items, which are equally important to the protection of workers who may be exposed to accidental flash fires. 5. Copyright Assignment (a) I am the author of the text or other material (such as illustrations, graphs) proposed in the Public Input. (b) Some or all of the text or other material proposed in this Public Input was not authored by me. Its source is as follows: (please identify which material and provide complete information on its source)

I hereby grant and assign to the NFPA all and full rights in copyright in this Public Input (including both the Proposed Text and the Statement of Problem and Substantiation). I understand that I acquire no rights in any publication of NFPA in which this Public Input in this or another similar or analogous form is used. Except to the extent that I do not have authority to make an assignment in materials that I have identified in (b) above, I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this assignment.

Signature (Required) Jeffrey O. Stull

PLEASE USE SEPARATE FORM FOR EACH PUBLIC INPUT

To: Secretary, Standards Council National Fire Protection Association 1 Batterymarch Park · Quincy, MA 02169-7471 OR Fax to: (617) 770-3500 OR Email to: [email protected]

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

Public Input No. 34-NFPA 2112-2014 [ Global Input ]

Revise the title of this standard to: Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Short Duration Thermal Exposures from Fire

Statement of Problem and Substantiation for Public Input

"Flash" fires, or vapor cloud fires, are a very small subset of actual fire types experienced in industrial environments with fire hazards. The potential fires that exist can be in the form of pressurized flammable line breaks (jet fires), flammable liquid spills (pool and running pool fires), combustible dust fires, and fireballs (from Boiling Liquid Vapor Explosions or flammable material container BLEVE). Actual thermal exposures can be in the form of full or partial flame contact or engulfment and/or exposure to the radiant energy from a fire's flame emissive power (e.g., when a worker is not in contact with the flames but is escaping the hazard). The purpose of this standard is to provide minimum specification requirements for PPE to address all of these industrial thermal hazards. This goal is better served with the appropriate generic description "short duration thermal exposures from fire" in the title, which covers all of the noted hazards this standard is designed to address.

Submitter Information Verification

Submitter Full Name: Roger Parry Organization: The DuPont Company, Inc. Street Address: City: State: Zip: Submittal Date: Tue Jul 01 14:12:37 EDT 2014

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Public Input No. 75-NFPA 2112-2014 [ Global Input ]

The standard should be modified to also address single use garments by the modification of the conditioning criteria applied to these products.

Statement of Problem and Substantiation for Public Input

The current edition identified single use garments and the committee has not endeavored to fill this industry gap. Standardization of this arena is needed to provide concurrent performance for products being claimed to offered industrial work protection from flash fires.

Submitter Information Verification

Submitter Full Name: Jeffrey Stull Organization: International Personnel Protection, Inc. Street Address: City: State: Zip: Submittal Date: Mon Jul 07 16:57:09 EDT 2014

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Public Input No. 29-NFPA 2112-2014 [ Chapter 1 ]

Chapter 1 Administration 1.1 Scope. The standard shall specify the minimum design, performance requirements and test methods , testing, and certification requirements for flame-resistant fabrics and components and the design and certification requirements for garments for garments, hoods/balaclavas, gloves, footwear, and rainwear for use in areas at risk from flash fires. 1.2 Purpose. 1.2.1* This standard shall provide minimum requirements for the design, construction, evaluation, and certification of flame-resistant garments, hoods/balaclavas, gloves, footwear, and rainwear for use by industrial personnel, with the intent of not contributing to the burn injury of the wearer, providing a degree of protection to the wearer, and reducing the severity of burn injuries resulting from short-duration thermal exposures or accidental exposure to flash fires. 1.2.2* Controlled laboratory tests used to determine compliance with the performance requirements of this standard shall not be deemed as establishing performance levels for all situations to which personnel can be exposed. 1.2.3* This standard shall not be intended to be utilized as a detailed manufacturing or purchasing specification but shall be intended to be referenced in purchase specifications as minimum requirements. 1.3 Application. 1.3.1 This standard shall apply to the design, manufacturing, and certification of new flame-resistant garments, hoods/balaclavas, gloves, footwear, and rainwear . 1.3.2* This standard shall not apply to protective clothing for wildland fire fighting, technical rescue, structural fire fighting, proximity fire fighting, or any other fire-fighting operations or hazardous materials emergencies. This standard shall not apply to single-use or limited-use garments. This standard shall not apply to protection from electrical flashes, radiological agents, biological agents, or hazardous materials. 1.3.3 Certification of flame-resistant garments to the requirements of this standard shall not preclude certification to additional appropriate standards where the garment, hood/balaclava, gloves, footwear, or rainwear meets all the applicable requirements of each standard. 1.3.4 The requirements of this standard shall not apply to accessories that might be attached to flame-resistant garments, hoods/balaclavas, gloves, footwear, or rainwear unless specifically addressed herein. 1.3.5 The minimum requirements identified in this standard are not intended to meet all the protection needs of a user in areas at risk from flash fires. Users shall refer to NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire, for conducting the appropriate hazard assessment to identify the in-use area’s minimum protection requirements. 1.4 Retroactivity. This standard shall only apply to garments, hoods/balaclavas, gloves, footwear, or rainwear manufactured on or after the effective date of the standard. 1.5 Equivalency. Nothing herein shall restrict any jurisdiction or manufacturer from exceeding these minimum requirements. 1.6 Units. In this standard, values for measurement are followed by an equivalent in parentheses, but only the first stated value shall be regarded as the requirement. Equivalent values in parentheses shall not be considered as the requirement, as these values might be approximate.

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Statement of Problem and Substantiation for Public Input

The scope of the standard is limited to garments and does not address other items of clothing that equally can ignite and cause injuries to industrial personnel. Industry claims for flame resistance should be standardized for these other items of clothing.

Submitter Information Verification

Submitter Full Name: Jeffrey Stull Organization: International Personnel Protection, Inc. Street Address: City: State: Zip: Submittal Date: Thu Jun 26 19:21:48 EDT 2014

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Public Input No. 35-NFPA 2112-2014 [ Section No. 1.1 ]

1.1 Scope. The standard shall specify the minimum performance requirements and test methods for flame-resistant fabrics and components and the design and certification requirements for garments for use in areas at risk from flash short duration thermal exposures from industrial fires.

Statement of Problem and Substantiation for Public Input

"Flash" fires, or vapor cloud fires are a very small subset of actual fire types experienced in industrial environments with fire hazards. The potential fires that exist can be in the form of pressurized flammable line breaks (jet fires), flammable liquid spills (pool and running pool fires), combustible dust, and fireballs (from Boiling Liquid Expanding Vapor Explosions or flammable material container BLEVE). Actual thermal exposures can be in the form of full or partial flame contact or engulfment and/or exposure to the radiant energy from a fire's flame emissive power (e.g., when a worker is not in contact with the flames but is escaping the hazard). The standard is better served by identifying thermal exposures to fire, which encompasses all of the noted hazards and fits with the established standard's Purpose (1.2.1).

Submitter Information Verification

Submitter Full Name: Roger Parry Organization: The DuPont Company, Inc. Street Address: City: State: Zip: Submittal Date: Tue Jul 01 15:02:20 EDT 2014

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Public Input No. 36-NFPA 2112-2014 [ Section No. 1.3.5 ]

1.3.5 The minimum requirements identified in this standard are not intended to meet all the protection needs of a user in areas at risk from flash short duration thermal exposures from fires. Users shall refer to NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Short Duration Thermal Exposures from Fire, for conducting the appropriate hazard assessment to identify the in-use area’s minimum protection requirements.

Statement of Problem and Substantiation for Public Input

For the first change, "flash" fires, or vapor cloud fires are a very small subset of actual fire types experienced in industrial environments with fire hazards. The potential fires that exist can be in the form of pressurized flammable line breaks (jet fires), flammable liquid spills (pool and running pool fires), combustible dust, and fireballs (from Boiling Liquid Expanding Vapor Explosions or flammable material container BLEVE). Actual thermal exposures can be in the form of full or partial flame contact or engulfment and/or exposure to the radiant energy from a fire's flame emissive power (e.g., when a worker is not in contact with the flames but is escaping the hazard). The standard is better served by identifying thermal exposures to fire, which encompasses all of the noted hazards and fits with the established standard's Purpose (1.2.1).

The second corrects the title for NFPA 2113 (2015 Edition).

Submitter Information Verification

Submitter Full Name: Roger Parry Organization: The DuPont Company, Inc. Street Address: City: State: Zip: Submittal Date: Tue Jul 01 15:14:03 EDT 2014

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Public Input No. 27-NFPA 2112-2014 [ Chapter 2 ]

Chapter 2 Referenced Publications 2.1 General. The documents or portions thereof listed in this chapter are referenced within this standard and shall be considered part of the requirements of this document. 2.2 NFPA Publications. National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169-7471. NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire, 2012 edition 2015 . 2.3 Other Publications. 2.3.1 AATCC Publications. American Association of Textile Chemists and Colorists, P.O. Box 12215, Research Triangle Park, NC 27709. AATCC 135, Dimensional Changes of Fabrics After Home Laundering, 2004 2012 . AATCC 158, Dimensional Changes on Dry-Cleaning in Perchloroethylene: Machine Method, 2005 2011 . 2.3.2 ASTM Publications. ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959. ASTM D 6413/D 6413M , Standard Test Method for Flame Resistance of Textiles (Vertical Test), 2008 2013B . ASTM F 1930, Standard Test Method for Evaluation of Flame Resistant Clothing for Protection Against Flash Fire Simulations Using an Instrumented Manikin, 2000 2013 . (Reaffirmed 2008) ASTM F 2700, Standard Test Method for Unsteady-State Heat Transfer Evaluation of Flame Resistant Materials for Clothing with Continuous Heating, 2008, reapproved 2013 . 2.3.3 GSA Publications. U.S. General Services Administration, 1800 F Street, N.W., Washington, DC 20405. Federal Test Method Standard 191A, Textile Test Methods, July 20, 1978. 2.3.4 ISO Publications. International Organization for Standardization, 1, rue de Varembé, Case postale 56, CH-1211 Geneve 20, Switzerland. ISO DIS 9001, Quality Management Systems — Requirements, 2008 2014 . ISO/IEC 17025, General Requirements for the Competence of Testing and Calibration Laboratories, 2005. ISO/IEC Guide 65, General 17065 , Conformity Accessment - Requirements for Bodies Operating st Product Certification Systems, 1996 Certifiying Products, Processes, and Services , 1 edition, 2012 .

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2.3.5 Other Publications. Merriam-Webster’s Collegiate Dictionary, 11th edition, Merriam-Webster, Inc., Springfield, MA, 2003. 2.4 References for Extracts in Mandatory Sections. NFPA 270, Standard Test Method for Measurement of Obscuration Using a Conical Radiant Source in a Single Closed Chamber, 2008 edition 2013 . NFPA 921, Guide for Fire and Explosion Investigations, 2011 edition 2014 . NFPA 1971, Standard on Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting, 2007 edition 2013 . NFPA 1975, Standard on Station/Work Uniforms for Emergency Services, 2009 edition 2014 . NFPA 1977, Standard on Protective Clothing and Equipment for Wildland Fire Fighting, 2011 edition . NFPA 1983, Standard on Life Safety Rope and Equipment for Emergency Services, 2006 edition 2012 . NFPA 1991, Standard on Vapor-Protective Ensembles for Hazardous Materials Emergencies, 2005 edition .

Statement of Problem and Substantiation for Public Input

Referenced current editions and titles.

Related Public Inputs for This Document

Related Input Relationship Public Input No. 28-NFPA 2112-2014 [Chapter C]

Submitter Information Verification

Submitter Full Name: Aaron Adamczyk Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Fri Jun 13 17:55:38 EDT 2014

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Public Input No. 37-NFPA 2112-2014 [ Section No. 2.2 ]

2.2 NFPA Publications. National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169-7471. NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Short Duration Thermal Exposures from Fire,2012 2015 edition.

Statement of Problem and Substantiation for Public Input

The proposed change provides the correct title to NFPA 2113 (2015 Edition).

Submitter Information Verification

Submitter Full Name: Roger Parry Organization: The DuPont Company, Inc. Street Address: City: State: Zip: Submittal Date: Tue Jul 01 15:21:15 EDT 2014

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Public Input No. 53-NFPA 2112-2014 [ New Section after 2.3.2 ]

2.3.2 ASTM Publications Add: D 1683 Standard Test Method for Failure In Sewn Seams of Woven Fabrics

Statement of Problem and Substantiation for Public Input

Move Standard D 1683 from Appendix to body of document to make it mandatory. (1)This test method is currently listed in Appendix B, Table B.1, a section of the standard that is not usually read by users because it is not mandatory data. In addition to to the wrong identification in column 1 for the primary measurement (should be"seam strength" not"seam efficiency") the wording used in the description identifies 3 distinct issues: the wording for the application contradicts the phrase "stronger seams" without explaining how or why the fabric that is "stronger" than the seam means that the garment has to be discarded instead of repaired. (2)This test method. D 1683, is the single protocol used with all other NFPA protective clothing standards to determine if the garment manufacturers who are supplied with fabric from ISO 9001/3rd Party certified fabric suppliers and ISO 9001/3rd Party certified recognized component suppliers of buttons, zippers, sewing thread, etc. have assembled all all of the parts together in a way that they can meet the performance requirements in a new garment for major seams and minor seams. The distinction between these two categories of seams will be addressed in Section 3 and in other sections of the standard.

Submitter Information Verification

Submitter Full Name: Vincent Diaz Organization: Atlantic Thread & Supply Compa Street Address: City: State: Zip: Submittal Date: Fri Jul 04 08:49:11 EDT 2014

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Public Input No. 54-NFPA 2112-2014 [ New Section after 2.3.2 ]

Add: D 6193 Standard Practice for Stitches and Seams TITLE OF NEW CONTENT Type your content here ...

Statement of Problem and Substantiation for Public Input

This standard, which was formerly the Fed Std 751 for Stitches and Seams, was transitioned to ASTM in 1995, would provide a ready reference for end users to better understand how a garment is being manufactured or repaired. 1. In additiion to complete descriptions and drawings of every type of stitch formation (sewing thread configurations), there are line drawings that show the wide range of seam types (fabric configurations) that can be made before two or more planar structures are joined together. It also includes drawings and descriptions of bartacks, buttonholes, and zig-zag stitches, etc. 2. Part of the usefulness associated with this standard is the combination of the stitching and seaming vocabulary with the images and drawings. This includes terms such as: overedged seams, lapped seams; lapped-felled seams, chainstitch, safetystitch, lockstitch, and many more.

Submitter Information Verification

Submitter Full Name: Vincent Diaz Organization: Atlantic Thread & Supply Compa Street Address: City: State: Zip: Submittal Date: Fri Jul 04 09:22:20 EDT 2014

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Public Input No. 55-NFPA 2112-2014 [ New Section after 2.3.2 ]

Add: D 7138 Standard Test Method to Determine Melting Temperature of Synthetic Fibers Type your content here ...

Statement of Problem and Substantiation for Public Input

1. This is the ASTM standard developed when Fed Std 191, Test Method 1534, was transitioned in 2005. 2. The standard allows for the use of two instruments to determine the termperature at which a solid becomes a liquid. 3. Test Method I use a Differential Scanning Calorimetry (DSC) instrument; Test Method II uses the same instrument as used in the original Fed Std.

Submitter Information Verification

Submitter Full Name: Vincent Diaz Organization: Atlantic Thread & Supply Compa Street Address: City: State: Zip: Submittal Date: Fri Jul 04 09:41:16 EDT 2014

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Public Input No. 31-NFPA 2112-2014 [ Section No. 2.3.2 ]

2.3.2 ASTM Publications. ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959. ASTM D 6413 D6413/D6413M , Standard Test Method for Flame Resistance of Textiles (Vertical Test), 2008 2013b . ASTM F 1930 F1930 , Standard Test Method for Evaluation of Flame Resistant Clothing for Protection Against Flash Fire Simulations Using an Instrumented Manikin, 2000 2013 . (Reaffirmed 2008) ASTM F 2700 F2700 , Standard Test Method for Unsteady-State Heat Transfer Evaluation of Flame Resistant Materials for Clothing with Continuous Heating, 2008 (2013) .

Statement of Problem and Substantiation for Public Input

date updates

Submitter Information Verification

Submitter Full Name: Marcelo Hirschler Organization: GBH International Street Address: City: State: Zip: Submittal Date: Sat Jun 28 18:25:26 EDT 2014

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Public Input No. 38-NFPA 2112-2014 [ Section No. 2.3.2 ]

2.3.2 ASTM Publications. ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959. ASTM D 6413 / D 6413M-13b , Standard Test Method for Flame Resistance of Textiles (Vertical Test), 2008 2013 . ASTM F 1930, Standard Test Method for Evaluation of Flame Resistant Clothing for Protection Against Flash Fire Simulations Using an Instrumented Manikin, 2000. (Reaffirmed 2008) 2013. ASTM F 2700, Standard Test Method for Unsteady-State Heat Transfer Evaluation of Flame Resistant Materials for Clothing with Continuous Heating, 2008. (Reaffirmed 2013)

Statement of Problem and Substantiation for Public Input

The proposed changes denote corrections to issue dates and titles of the identified ASTM standards.

Submitter Information Verification

Submitter Full Name: Roger Parry Organization: The DuPont Company, Inc. Street Address: City: State: Zip: Submittal Date: Tue Jul 01 15:23:10 EDT 2014

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Public Input No. 67-NFPA 2112-2014 [ Section No. 2.3.2 ]

2.3.2 ASTM Publications. ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959. ASTM D 6413/D6413M , Standard Test Method for Flame Resistance of Textiles (Vertical Test), 2008 2013b . ASTM F 1930, Standard Test Method for Evaluation of Flame Resistant Clothing for Protection Against Flash Fire Simulations Using an Instrumented Manikin, 2000 2013 . (Reaffirmed 2008) ASTM F 2700, Standard Test Method for Unsteady-State Heat Transfer Evaluation of Flame Resistant Materials for Clothing with Continuous Heating, 2008 08(2013) .

Statement of Problem and Substantiation for Public Input

Update the year date for standard(s)

Submitter Information Verification

Submitter Full Name: Steve Mawn Organization: ASTM International Street Address: City: State: Zip: Submittal Date: Mon Jul 07 14:19:13 EDT 2014

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Public Input No. 56-NFPA 2112-2014 [ New Section after 2.3.3 ]

2.3.3 Change Title of Section from GSA to US Government Publications, Military Specifications and Commercial Items Descriptions (CID's) Delete: Fed Std 191 A, Test Method 1534 See: Section 2.3.2 Add: Commercial Item Descriptions (CID's) Submitter proposes that the following CID's be added to reference documents: A-A-55126, Fastener Tape, Hook and Loop, Synthetic, 2006 A-A-55217, Aramid, Spun Thread, (Type I Normal Performance, Type II, High Performance) 2011 A-A-55634, Zippers (Fasteners, Slide Interlocking) 2004

Statement of Problem and Substantiation for Public Input

Starting in the 1990's, the US Government transitioned from military specifications (descriptive based documents) to CID's (performance based documents) so that purchases could be made from commercial inventories. These inventories would meet consensus performance requirements that had been agreed to by industry, DLA, and Natick R&D. Each of these identified CID's have multiple performance requirements, that were agreed to by the DoD and industry, that use various tests to evaluate the performance of the following components: (a) Hook and Loop: Uses an Aviation Interiors test for FR treated fastener testing and two ASTM test methods for shear and pull testing (b) Sewing thread: Uses three ASTM test methods to measure (1) melt testing of yarn; (2) break strength, yarn size, and yardage, (3) seam strength of major seams and minor seams (c) Zippers: Uses three ASTM test methods to measure: (1) melt testing of yarn, (2) break strength, yarn size, and yardage, (3) strength of interlocking components

Submitter Information Verification

Submitter Full Name: Vincent Diaz Organization: Atlantic Thread & Supply Compa Street Address: City: State: Zip: Submittal Date: Fri Jul 04 09:53:12 EDT 2014

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Public Input No. 65-NFPA 2112-2014 [ Chapter 3 ]

Chapter 3 Definitions 3.1 General. The definitions contained in this chapter shall apply to the terms used in this standard. Where terms are not defined in this chapter or within another chapter, they shall be defined using their ordinarily accepted meanings within the context in which they are used. Merriam-Webster’s Collegiate Dictionary, 11th edition, shall be the source for the ordinarily accepted meaning. 3.2 NFPA Official Definitions. 3.2.1* Approved. Acceptable to the authority having jurisdiction. 3.2.2* Authority Having Jurisdiction (AHJ). An organization, office, or individual responsible for enforcing the requirements of a code or standard, or for approving equipment, materials, an installation, or a procedure. 3.2.3 Labeled. Equipment or materials to which has been attached a label, symbol, or other identifying mark of an organization that is acceptable to the authority having jurisdiction and concerned with product evaluation, that maintains periodic inspection of production of labeled equipment or materials, and by whose labeling the manufacturer indicates compliance with appropriate standards or performance in a specified manner. 3.2.4* Listed. Equipment, materials, or services included in a list published by an organization that is acceptable to the authority having jurisdiction and concerned with evaluation of products or services, that maintains periodic inspection of production of listed equipment or materials or periodic evaluation of services, and whose listing states that either the equipment, material, or service meets appropriate designated standards or has been tested and found suitable for a specified purpose. 3.2.5 Shall. Indicates a mandatory requirement. 3.2.6 Should. Indicates a recommendation or that which is advised but not required. 3.2.7 Standard. A document, the main text of which contains only mandatory provisions using the word “shall” to indicate requirements and which is in a form generally suitable for mandatory reference by another standard or code or for adoption into law. Nonmandatory provisions shall be located in an appendix or annex, footnote, or fine-print note and are not to be considered a part of the requirements of a standard. 3.3 General Definitions. 3.3.1 Accreditation/Accredited. A system whereby a certification organization determines that a laboratory has demonstrated the ability to conduct tests in an accurate and precise manner consistent with the requirements of this standard, accepts the laboratory's test data, and continues to monitor laboratory practices to ensure accurate and precise testing consistent with the requirements of this standard. 3.3.2 Agents. 3.3.2.1 Biological Agents. Biological materials that are capable of causing an acute disease or long-term damage to the human body. [1991, 2005] 3.3.2.2 Radiological Agents. Radiation associated with x-rays, alpha, beta, and gamma emissions from radioactive isotopes, or other materials in excess of normal background radiation levels. 3.3.3 Body. 3.3.3.1 Lower Body. The area of the body below the waist including the legs but excluding the ankles and feet. 3.3.3.2 Upper Body. The area of body above the waist and extending to the shoulders, including the arms and wrists but excluding the hands.

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3.3.4 Certification/Certified. A system whereby a certification organization determines that a manufacturer has demonstrated the ability to produce a product that complies with the requirements of this standard, authorizes the manufacturer to use a label on listed products that comply with the requirements of this standard, and establishes a follow-up program conducted by the certification organization as a check on the methods the manufacturer uses to determine continued compliance with the requirements of this standard. [1971, 2007] 3.3.5 Certification Organization. An independent, third-party organization that determines product compliance with the requirements of this standard with a labeling/listing/follow-up program. [1971, 2007] 3.3.6* Cold Weather Insulation Material. A fabric that consists of one or more nonseparable layers that is used for protection in a low-temperature environment. 3.3.7 Compliance/Compliant. Meeting or exceeding all applicable requirements of this standard. [1971, 2007] 3.3.8 Component(s). Any material, part, or subassembly used in the construction of the compliant product. [1971, 2007] 3.3.9 Drip. A flow of liquid that lacks sufficient quantity or pressure to form a continuous stream and runs or falls in drops. 3.3.10 Emblem(s). Shields, heraldry, or printing that designates a governmental entity or a specific organization; rank, title, position, or other professional status that is painted, screened, embroidered, sewn, glued, bonded, or otherwise attached in a permanent manner. 3.3.11* Fabric. The one or more layers of textile material(s) used in the primary construction of protective garments. 3.3.11.1 Textile Fabric. A planar structure consisting of yarns or fibers. [1977, 2011] 3.3.12* Flame Resistance. The property of a material whereby combustion is prevented, terminated, or inhibited following the application of a flaming or nonflaming source of ignition, with or without subsequent removal of the ignition source. 3.3.13* Flash Fire. A fire that spreads by means of a flame front rapidly through a diffuse fuel, such as dust, gas, or the vapors of an ignitible liquid, without the production of damaging pressure. [921, 2011] 3.3.14 Follow-Up Program. The sampling, inspections, tests, or other measures conducted by the certification organization on a periodic basis to determine the continued compliance of labeled and listed products that are being produced by the manufacturer to the requirements of this standard. [1977, 2011] 3.3.15 Garments. Clothing including, but not limited to, coveralls, trousers, shirts, outerwear, and rainwear. 3.3.15.1 Limited-Use Garment. A garment whose service life is limited by the manufacturer to a specified number of wear cycles and does not meet the testing requirements of this standard. 3.3.15.2* Single-Use Garment. A garment that is designed to be used one time and then disposed of. 3.3.16 Hardware. Nonfabric components of the protective garment including, but not limited to, those made of metal or plastic. 3.3.17 Hazardous Material. Any solid, liquid, gas, or mixture thereof that can potentially cause harm to the human body through respiration, ingestion, skin absorption, or contact. 3.3.18 Hazardous Materials Emergencies. Incidents involving the release or potential release of hazardous materials. [1971, 2007] 3.3.19 Industrial Personnel. Workers who might be exposed to flash fire.

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3.3.20 Interlining. Any textile that is incorporated into any garment as a layer between outer and inner layers. [1975, 2009] 3.3.21 Lining. Any material that is attached and used to cover or partially cover the inside surface of a flame-resistant garment. 3.3.22 Melt. A response to heat by a material resulting in evidence of flowing or dripping. [1983, 2006] 3.3.23 Model. The collective term used to identify a group of elements or items of the same basic design and components from a single manufacturer produced by the same manufacturing and quality assurance procedures that are covered by the same certification. [1971, 2007] 3.3.24 Product. The compliant flame-resistant garment. 3.3.25* Product Label. A label or marking affixed to a product by the manufacturer containing compliant statements, certification statements, manufacturer or model information, or similar dates. [1971, 2007] 3.3.26 Reflective Striping. Material added to the exterior of the garment to enhance nighttime or daytime visibility. 3.3.27 Reinforcement. An additional layer of a textile material applied to a specific area of the protective garment to make that portion of the protective garment more resistant to wear. 3.3.28 Sample. An amount of the material, product, or assembly to be tested that is representative of the item as a whole. [270, 2008] 3.3.29 Seam. Any permanent attachment of two or more protective garment fabrics in a line formed by joining the separate material pieces. 3.3.29.1 Sewn Seam. A series of stitches joining two or more separate plies of material(s) of planar structure, such as textiles. [1975, 2009] 3.3.30 Separate. A material response evidenced by splitting or delaminating. [1971, 2007] 3.3.31 Specimen. The item that undergoes testing; in some cases, the specimen is also the sample. [1971, 2007]

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3.3.32 Trouser. A garment that is designed to provide minimum protection to the lower torso and legs, excluding the ankles and feet. 3.3.33 Balaclava/ Hood. A clothing item worn over the head that generally includes a face opening and is designed to provide minimum protection to the wearer's head and neck less the face opening. 3.3.34 Glove. An article of clothing worn over the hands that is designed to provide minimum protection to the wearer's hands, wrist, and a portion of the forearms. 3.3.35 Footwear. An item of personal protective equipment worn over the feet that is designed to provide minimum protection to the wearer's feet, ankles, and a portion of the lower legs. 3.3.36 Rainwear. A garment which provides protection from protection for the head, limbs, and body of the wearer. 3.3.37 Functional. The ability of an clothing item or component to continue to be utilized for its intended purpose . 3.3.38 Glove Body. The part of the glove that extends from the tip of the fingers to the wrist crease or to a specified distance beyond the wrist crease. 3.3.39 Gauntlet. A component of the glove that provides limited protection to the garment/glove interface area. 3.3.40 Insole. The inner component of the footwear upon which the foot rests. 3.3.41 Gusset. The part of the footwear that is a relatively flexible material joining the footwear upper (quarter) and the tongue, which is intended to provide expansion of the footwear front to enable donning of the footear while maintaining continuous thermal integrity of the footwear. 3.3.42 Tongue. The part of the footwear that is provided for lace up of footwear with a closure that extends from the vamp to the top line of the footwear between the sides of the footwear upper and is exposed to the exterior environment when the footwear is correctly donned. 3.3.43 Top Line. The top edge of the footwear that includes the tongue, gusset quarter, collar, and shaft. 3.3.44 Upper. The part of the footwear including, but not limited to, the toe, vamp, quarter, shaft, collar, and throat, but excluding the sole with heel, puncture resistant device, and insole. 3.3.45 Wear Surface. The bottom of the footwear sole, including the heel.

Statement of Problem and Substantiation for Public Input

The proposed definitions are needed to address new elements of protective clothing that have been recommended for addition to the standard.

Submitter Information Verification

Submitter Full Name: Jeffrey Stull

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Organization: International Personnel Protection, Inc. Street Address: City: State: Zip: Submittal Date: Mon Jul 07 13:22:29 EDT 2014

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Public Input No. 5-NFPA 2112-2013 [ Section No. 3.3.6 ]

3.3.6 * Cold Weather Insulation Material. A fabric that consists of one or more nonseparable layers that is used for protection in a low-temperature environment. A cold weather insulation material is not an interlining (see interlining) .

Additional Proposed Changes

File Name Description Approved Proposed_TIA_1105_2112_.docx Balloted TIA

Statement of Problem and Substantiation for Public Input

Note: This Public Input originates from Tentative Interim Amendment 2112-12-2 (TIA 1105) issued by the Standards Council on August 1, 2013.

The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out) representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance

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requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

• A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

• Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

• Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

• Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

• A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

• Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

• Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

Submitter Information Verification

Submitter Full Name: TC on FLG-AAA

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Organization: TC on Flash Fire Protective Garments Street Address: City: State: Zip: Submittal Date: Fri Sep 06 14:05:04 EDT 2013

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NFPA 2112®-2012 Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire TIA Log No. 1105 Reference: Various Comment Closing Date: June 14, 2013 Submitter: Jeffrey O. Stull, International Personnel Protection, Inc.

1. Revise 3.3.6, A.3.3.6, and 3.3.20, and add a new A.3.3.20 to read as follows:

3.3.6* Cold Weather Insulation Material. A fabric that consists of one or more nonseparable layers that is used for protection in a low-temperature environment. A cold weather insulation material is not an interlining (see interlining).

A.3.3.6 Cold Weather Insulation Material. Examples of insulation materials are include textile battings(s) alone or batting(s) that are attached to a face cloth. For example, an insulation material consisting of two layers are considered nonseparable by the attachment that combines the two layers. The insulation material may or may not have a face cloth. Cold weather insulation materials generally are provided within the garment such that their area of coverage coincides with the majority of garment area covering the wearer’s body. Cold weather insulation material as defined in this standard does not preclude the use of intermediate layers for additional protection against thermal hazards.

3.3.20* Interlining. Any textile that is incorporated into any garment as a layer between outer and inner layers that only covers a small portion of the overall garment. [1975, 2009]

A.3.3.20 Interlining. The outer and inner layers are compliant to the fabric requirements of this standard. Examples of an interlining are a fabric layer used to stiffen the waist band in a pair of pants or a facing fabric used inside the closure flap of a coverall. Interlining materials do not come in contact with the wearer’s skin or underclothing.

2. Revise subsections 5.1.2, 5.1.9(7), and 5.1.12, and add a new 5.1.13 to read as follows:

5.1.2 At least one product label shall be conspicuously located inside each flame-resistant garment. when the item is properly assembled with all layers and components in place.

5.1.9(7) Fiber content for each primary fabric layer including cold weather insulation materials, but excluding interlinings and labels.

5.1.12 Garments with multiple layers, including an outer layer and removable cold weather insulation layer, shall specify the certified wearable configurations on the label configuration and include a warning on the label stating that all layers must be properly secured and worn in accordance with the manufacturer’s instructions.

5.1.13 For garments with multiple layers that include an outer layer and a removable cold weather insulation layer, a label shall be conspicuously attached to the removable insulation layer that states “DO NOT WEAR THIS LINER BY ITSELF. FOR COMPLIANCE WITH THE FLASH FIRE REQUIREMENTS OF NFPA 2112, THE COMPLETE GARMENT MUST BE WORN. FOR COMPLIANCE INFORMATION, SEE THE PRODUCT LABEL ON OUTER GARMENT.”

3. Add new Section 6.4 and subsections 6.4.1, and A.6.4.1 to read as follows:

6.4 Use of a Liner for Cold Weather Insulation. Garments shall be permitted to include liners in their construction including cold weather insulation materials where the liner is either integral to the garment or removable.

6.4.1* Where garments incorporate a cold weather insulation material as part of a removable lining system, the garment shall be designed such that the removable liner consisting of the cold weather insulation material cannot be independently worn.

A.6.4.1 Removable liners are permitted to be worn separately if the liner material(s) independently meets the appropriate fabric requirements in Chapter 7 including 7.1.1 for heat transfer performance and 7.1.5 for overall flash fire performance. If the liner contains cold weather insulation materials that are not evaluated to 7.1.1 and 7.1.5 and do not pass the thermal shrinkage resistance requirement in 7.1.3, then the manufacturer must label the liner as specified in 5.1.13 and provide a design that does not allow separate wearing of the liner without the outer layer. This may be demonstrated by the absence of a means of closure for the closure area of shirts, pants, and coveralls.

4. Add new subsections 7.1.1.1 and 7.1.1.2 to read as follows:

7.1.1.1 Where the flame-resistant garment consists of multiple and separable layers intended to be worn separately, the outer layer and the inner layer or layers shall be separately tested.

7.1.1.2 Where the flame-resistant garment consists of multiple layers intended only to be worn together, only the outer layer shall be tested.

5. Revise subsections 7.1.2 and 7.1.3 to read as follows:

7.1.2 Fabric, cold weather insulation material, and reflective striping utilized in the construction of flame-resistant garments shall be tested for flame resistance as specified in Section 8.3, and shall have a char length of not more than 100 mm (4 in.) and an after-flame of not more than 2 seconds, and shall not melt and drip.

7.1.3 Fabric utilized in the construction of flame-resistant garments, excluding manufacturer’s labels, interlinings, and cold weather insulation materials, shall be individually tested for thermal shrinkage resistance as specified in Section 8.4, and shall not shrink more than 10 percent in any direction.

6. Delete existing subsection 7.1.3.1 as follows:

7.1.3.1 Cold weather insulation materials utilized in the construction of flame-resistant garments shall be tested in accordance with Section 8.4 and shall not shrink more than 20 percent in any direction.

7. Revise subsection 7.1.4 to read as follows:

7.1.4 Fabric, cold weather insulation materials, other textile materials, and reflective striping other than those items described in 7.1.4.1 and 7.1.4.2, used in the construction of flame-resistant garments shall be individually tested for heat resistance in their original form as specified in Section 8.4, and shall not melt and drip, separate, or ignite.

8. Add a new subsection 8.3.1.7 to read as follows:

8.3.1.7 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.3.13.

9. Revise subsections 8.3.3.1, 8.3.3.2, and 8.3.3.3 to read as follows

8.3.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3.

8.3.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after 100 cycles of dry cleaning as specified in 8.1.4.

8.3.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3, or after 100 cycles of dry cleaning as specified in 8.1.4.

10. Add new subsections to 8.3.13 to read as follows:

8.3.13 Specific Requirements for Testing Cold Weather Insulation Materials.

8.3.13.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 66-cm × 66-cm (26-in. × 26-in.) panel of the cold weather insulation material. A similar-sized piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0- oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric.

8.3.13.2 Following wash or dry-clean conditioning, 5 specimens measuring 75 mm × 300 mm (3 in. × 12 in.) from each of the warp and filling direction shall be removed from the cold weather insulation material layer of the conditioned panels.

8.3.13.3 If applicable, all specimens shall be prepared for testing by trimming the scrim material, batting, or other layer(s) away from the face cloth by 50 mm ± 3 mm (2.0 in. ± 1/8 in.) such that the face cloth can be folded back covering the scrim, batting, or other layer(s) by 50 mm ± 3 mm (2.0 in. ± 1/8 in.); the folded specimen shall be secured in the specimen holder.

8.3.13.4 Testing shall be performed as described in 8.3.2 through 8.3.7.

11. Revise subsection 8.4.1 and add new subsections 8.4.1.1 through 8.4.1.5 to read as follows:

8.4.1 Application. The heat and thermal shrinkage resistance test method shall apply to flame resistant garment fabrics, components, and hardware.

8.4.1.1 This test method shall apply to flame-resistant garment fabrics, components, hardware, and cold weather insulation materials.

8.4.1.2 Modifications to this test method for testing flame-resistant garment textile materials shall be as specified in 8.4.8.

8.4.1.3 Modifications to this test method for testing other flame-resistant garment materials, including reflective striping, shall be as specified in 8.4.9.

8.4.1.4 Modifications to this test method for testing hardware shall be as specified in 8.4.10.

8.4.1.5 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.4.11.

12. Revise subsections 8.4.2.1 and 8.4.3.1 through 8.4.3.3 to read as follows:

8.4.2.1 Only heat resistance testing shall be conducted on not fewer than three specimens for each hardware item, label material, and other flame-resistant garment fabrics, and cold weather insulation materials not listed in 8.4.2.2 and 8.4.2.3.

8.4.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3.

8.4.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after three cycles of dry-cleaning as specified in 8.1.4.

8.4.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3, after three cycles of dry-cleaning as specified in 8.1.4.

13. Delete existing subsection 8.4.8.2 and renumber 8.4.8.3 to 8.4.8.2 to read as follows:

8.4.8.2 Measurements of cold weather insulation material thermal shrinkage shall be made on the side of the fabric facing the wearer as used in the construction of the garment.

8.4.8.3 8.4.8.2 Testing shall be performed in accordance with 8.4.2 through 8.4.7.

14. Add new subsection 8.4.11 to read as follows:

8.4.11 Specific Requirements for Testing Cold Weather Insulation Materials.

8.4.11.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 50-cm × 20-cm (20-in. × 8-in.) panel of the cold weather insulation material. A similar-sized cloth piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0-oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric .

8.4.11.2 Following wash or dry-clean conditioning, 3 specimens measuring 152 mm × 152 mm (6 in. × 6 in.) shall be removed from the cold weather insulation material layer of the conditioned panel.

8.4.11.3 Testing shall be performed in accordance with 8.4.2 through 8.4.7, and thermal shrinkage shall not be measured.

Submitter’s Substantiation: The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out)

representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

 A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

 Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

 Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

 Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

 A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

 Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

 Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes

criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

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Public Input No. 57-NFPA 2112-2014 [ Section No. 3.3.12 ]

3.3.12 * Flame Resistance. The property of a material whereby combustion is prevented, terminated, or inhibited following the application of a flaming or nonflaming source of ignition, with or without subsequent removal of the ignition source. The definition is not the complete NFPA definition for this term, there is more wording that was omitted. The omitted wording was "Flame resistance can be an inherent property of a material or it can be imparted by specific treatment" The committee has two options to correct this error: 1. Make the change by adding the omitted wording to the current definition for the term "flame resistance", or 2. Add the term "inherent flame resistance" and its definition to Chapter 3: inherent flame resistance -- flame resistance that is derived from the essential characteristics of the fiber or polymer from which the textile is made

Statement of Problem and Substantiation for Public Input

The current definition for the term "flame resistance is not the complete NFPA definition for this term, there is more wording that was omitted. The omitted wording was "Flame resistance can be an inherent property of a material or it can be imparted by specific treatment "

The committee has two options to correct this error: 1. Make the change by adding the omitted owrding to the current defiinition for the term "flame resistance", or add the term "inherent flame resistance" and its definition to Chapter 3: Inherent flame resistance - flame resistance that is derived from the essential characteristics of the fiber or polymer from which the textile is made.

Submitter Information Verification

Submitter Full Name: Vincent Diaz Organization: Atlantic Thread & Supply Compa Street Address: City: State: Zip: Submittal Date: Fri Jul 04 10:31:37 EDT 2014

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Public Input No. 39-NFPA 2112-2014 [ New Section after 3.3.13 ]

3.3.x Fire. A rapid oxidation process which is a chemical reaction resulting in the evolution of light and heat in varying intensities. [921, 2014]

Statement of Problem and Substantiation for Public Input

A definition of fire is missing from this standard (which defines the minimum PPE requirements for the hazard). In addition, the definition offered for Flash Fire (3.3.13) is actually a fire subclass which requires a definition for fire if it is retained in the standard (a separate Public Input from this submitter).

Submitter Information Verification

Submitter Full Name: Roger Parry Organization: The DuPont Company, Inc. Street Address: City: State: Zip: Submittal Date: Tue Jul 01 15:31:04 EDT 2014

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Public Input No. 40-NFPA 2112-2014 [ Section No. 3.3.13 ]

3.3.13 * Flash Fire. A fire that spreads by means of a flame front rapidly through a diffuse fuel, such as dust, gas, or the vapors of an ignitible liquid, without the production of damaging pressure. [ 921, 2011]

Statement of Problem and Substantiation for Public Input

This standard establishes the minimum performance requirements of PPE for protection of industrial personnel from short duration thermal exposures from industrial fires, not from a specific type of fire. "Flash" fires, or vapor cloud fires are a very small subset of actual fire types experienced in industrial environments with fire hazards. The potential fires that exist can be in the form of pressurized flammable line breaks (jet fires), flammable liquid spills (pool and running pool fires), combustible dust, and fireballs (from Boiling Liquid Expanding Vapor Explosions or flammable material container BLEVE). Actual thermal exposures can be in the form of full or partial flame contact or engulfment and/or exposure to the radiant energy from a fire's flame emissive power (e.g., when a worker is not in contact with the flames but is escaping the hazard). The standard is better served by identifying thermal exposures to fire, which encompasses all of the noted hazards and fits with the established standard's Purpose (1.2.1), rather than singling out a specific fire type (as in the case of "Flash Fires"). As such, a definition specific to "Flash Fires" is not required.

Submitter Information Verification

Submitter Full Name: Roger Parry Organization: The DuPont Company, Inc. Street Address: City: State: Zip: Submittal Date: Tue Jul 01 15:42:52 EDT 2014

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Public Input No. 6-NFPA 2112-2013 [ Section No. 3.3.20 ]

3.3.20 * Interlining. Any textile that is incorporated into any garment as a layer between outer and inner layers . [ 1975, 2009] that only covers a small portion of the overall garment.

Additional Proposed Changes

File Name Description Approved Proposed_TIA_1105_2112_.docx Balloted TIA

Statement of Problem and Substantiation for Public Input

Note: This Public Input originates from Tentative Interim Amendment 2112-12-2 (TIA 1105) issued by the Standards Council on August 1, 2013.

The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out) representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance

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requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

• A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

• Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

• Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

• Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

• A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

• Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

• Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

Submitter Information Verification

Submitter Full Name: TC on FLG-AAA

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Organization: TC on Flash Fire Protective Garments Street Address: City: State: Zip: Submittal Date: Fri Sep 06 14:07:06 EDT 2013

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NFPA 2112®-2012 Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire TIA Log No. 1105 Reference: Various Comment Closing Date: June 14, 2013 Submitter: Jeffrey O. Stull, International Personnel Protection, Inc.

1. Revise 3.3.6, A.3.3.6, and 3.3.20, and add a new A.3.3.20 to read as follows:

3.3.6* Cold Weather Insulation Material. A fabric that consists of one or more nonseparable layers that is used for protection in a low-temperature environment. A cold weather insulation material is not an interlining (see interlining).

A.3.3.6 Cold Weather Insulation Material. Examples of insulation materials are include textile battings(s) alone or batting(s) that are attached to a face cloth. For example, an insulation material consisting of two layers are considered nonseparable by the attachment that combines the two layers. The insulation material may or may not have a face cloth. Cold weather insulation materials generally are provided within the garment such that their area of coverage coincides with the majority of garment area covering the wearer’s body. Cold weather insulation material as defined in this standard does not preclude the use of intermediate layers for additional protection against thermal hazards.

3.3.20* Interlining. Any textile that is incorporated into any garment as a layer between outer and inner layers that only covers a small portion of the overall garment. [1975, 2009]

A.3.3.20 Interlining. The outer and inner layers are compliant to the fabric requirements of this standard. Examples of an interlining are a fabric layer used to stiffen the waist band in a pair of pants or a facing fabric used inside the closure flap of a coverall. Interlining materials do not come in contact with the wearer’s skin or underclothing.

2. Revise subsections 5.1.2, 5.1.9(7), and 5.1.12, and add a new 5.1.13 to read as follows:

5.1.2 At least one product label shall be conspicuously located inside each flame-resistant garment. when the item is properly assembled with all layers and components in place.

5.1.9(7) Fiber content for each primary fabric layer including cold weather insulation materials, but excluding interlinings and labels.

5.1.12 Garments with multiple layers, including an outer layer and removable cold weather insulation layer, shall specify the certified wearable configurations on the label configuration and include a warning on the label stating that all layers must be properly secured and worn in accordance with the manufacturer’s instructions.

5.1.13 For garments with multiple layers that include an outer layer and a removable cold weather insulation layer, a label shall be conspicuously attached to the removable insulation layer that states “DO NOT WEAR THIS LINER BY ITSELF. FOR COMPLIANCE WITH THE FLASH FIRE REQUIREMENTS OF NFPA 2112, THE COMPLETE GARMENT MUST BE WORN. FOR COMPLIANCE INFORMATION, SEE THE PRODUCT LABEL ON OUTER GARMENT.”

3. Add new Section 6.4 and subsections 6.4.1, and A.6.4.1 to read as follows:

6.4 Use of a Liner for Cold Weather Insulation. Garments shall be permitted to include liners in their construction including cold weather insulation materials where the liner is either integral to the garment or removable.

6.4.1* Where garments incorporate a cold weather insulation material as part of a removable lining system, the garment shall be designed such that the removable liner consisting of the cold weather insulation material cannot be independently worn.

A.6.4.1 Removable liners are permitted to be worn separately if the liner material(s) independently meets the appropriate fabric requirements in Chapter 7 including 7.1.1 for heat transfer performance and 7.1.5 for overall flash fire performance. If the liner contains cold weather insulation materials that are not evaluated to 7.1.1 and 7.1.5 and do not pass the thermal shrinkage resistance requirement in 7.1.3, then the manufacturer must label the liner as specified in 5.1.13 and provide a design that does not allow separate wearing of the liner without the outer layer. This may be demonstrated by the absence of a means of closure for the closure area of shirts, pants, and coveralls.

4. Add new subsections 7.1.1.1 and 7.1.1.2 to read as follows:

7.1.1.1 Where the flame-resistant garment consists of multiple and separable layers intended to be worn separately, the outer layer and the inner layer or layers shall be separately tested.

7.1.1.2 Where the flame-resistant garment consists of multiple layers intended only to be worn together, only the outer layer shall be tested.

5. Revise subsections 7.1.2 and 7.1.3 to read as follows:

7.1.2 Fabric, cold weather insulation material, and reflective striping utilized in the construction of flame-resistant garments shall be tested for flame resistance as specified in Section 8.3, and shall have a char length of not more than 100 mm (4 in.) and an after-flame of not more than 2 seconds, and shall not melt and drip.

7.1.3 Fabric utilized in the construction of flame-resistant garments, excluding manufacturer’s labels, interlinings, and cold weather insulation materials, shall be individually tested for thermal shrinkage resistance as specified in Section 8.4, and shall not shrink more than 10 percent in any direction.

6. Delete existing subsection 7.1.3.1 as follows:

7.1.3.1 Cold weather insulation materials utilized in the construction of flame-resistant garments shall be tested in accordance with Section 8.4 and shall not shrink more than 20 percent in any direction.

7. Revise subsection 7.1.4 to read as follows:

7.1.4 Fabric, cold weather insulation materials, other textile materials, and reflective striping other than those items described in 7.1.4.1 and 7.1.4.2, used in the construction of flame-resistant garments shall be individually tested for heat resistance in their original form as specified in Section 8.4, and shall not melt and drip, separate, or ignite.

8. Add a new subsection 8.3.1.7 to read as follows:

8.3.1.7 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.3.13.

9. Revise subsections 8.3.3.1, 8.3.3.2, and 8.3.3.3 to read as follows

8.3.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3.

8.3.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after 100 cycles of dry cleaning as specified in 8.1.4.

8.3.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3, or after 100 cycles of dry cleaning as specified in 8.1.4.

10. Add new subsections to 8.3.13 to read as follows:

8.3.13 Specific Requirements for Testing Cold Weather Insulation Materials.

8.3.13.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 66-cm × 66-cm (26-in. × 26-in.) panel of the cold weather insulation material. A similar-sized piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0- oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric.

8.3.13.2 Following wash or dry-clean conditioning, 5 specimens measuring 75 mm × 300 mm (3 in. × 12 in.) from each of the warp and filling direction shall be removed from the cold weather insulation material layer of the conditioned panels.

8.3.13.3 If applicable, all specimens shall be prepared for testing by trimming the scrim material, batting, or other layer(s) away from the face cloth by 50 mm ± 3 mm (2.0 in. ± 1/8 in.) such that the face cloth can be folded back covering the scrim, batting, or other layer(s) by 50 mm ± 3 mm (2.0 in. ± 1/8 in.); the folded specimen shall be secured in the specimen holder.

8.3.13.4 Testing shall be performed as described in 8.3.2 through 8.3.7.

11. Revise subsection 8.4.1 and add new subsections 8.4.1.1 through 8.4.1.5 to read as follows:

8.4.1 Application. The heat and thermal shrinkage resistance test method shall apply to flame resistant garment fabrics, components, and hardware.

8.4.1.1 This test method shall apply to flame-resistant garment fabrics, components, hardware, and cold weather insulation materials.

8.4.1.2 Modifications to this test method for testing flame-resistant garment textile materials shall be as specified in 8.4.8.

8.4.1.3 Modifications to this test method for testing other flame-resistant garment materials, including reflective striping, shall be as specified in 8.4.9.

8.4.1.4 Modifications to this test method for testing hardware shall be as specified in 8.4.10.

8.4.1.5 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.4.11.

12. Revise subsections 8.4.2.1 and 8.4.3.1 through 8.4.3.3 to read as follows:

8.4.2.1 Only heat resistance testing shall be conducted on not fewer than three specimens for each hardware item, label material, and other flame-resistant garment fabrics, and cold weather insulation materials not listed in 8.4.2.2 and 8.4.2.3.

8.4.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3.

8.4.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after three cycles of dry-cleaning as specified in 8.1.4.

8.4.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3, after three cycles of dry-cleaning as specified in 8.1.4.

13. Delete existing subsection 8.4.8.2 and renumber 8.4.8.3 to 8.4.8.2 to read as follows:

8.4.8.2 Measurements of cold weather insulation material thermal shrinkage shall be made on the side of the fabric facing the wearer as used in the construction of the garment.

8.4.8.3 8.4.8.2 Testing shall be performed in accordance with 8.4.2 through 8.4.7.

14. Add new subsection 8.4.11 to read as follows:

8.4.11 Specific Requirements for Testing Cold Weather Insulation Materials.

8.4.11.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 50-cm × 20-cm (20-in. × 8-in.) panel of the cold weather insulation material. A similar-sized cloth piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0-oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric .

8.4.11.2 Following wash or dry-clean conditioning, 3 specimens measuring 152 mm × 152 mm (6 in. × 6 in.) shall be removed from the cold weather insulation material layer of the conditioned panel.

8.4.11.3 Testing shall be performed in accordance with 8.4.2 through 8.4.7, and thermal shrinkage shall not be measured.

Submitter’s Substantiation: The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out)

representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

 A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

 Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

 Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

 Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

 A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

 Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

 Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes

criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

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Public Input No. 58-NFPA 2112-2014 [ Section No. 3.3.29 ]

3.3.29 Seam. Any permanent attachment of two or more protective garment fabrics in a line formed by joining the separate material pieces. 3.3.29.1 Sewn Seam. A series of stitches joining two or more separate plies of material(s) of planar structure, such as textiles. [1975, 2009] Proposal: Submitter proposes that these terms be deleted and replaced with several new terms that provide the end user with valuable, objective, and measurable data that indicates performance.

Statement of Problem and Substantiation for Public Input

While these terms and definitions might indicate the joining of two separate pieces of fabric, I believe a different image would come to mind with the following: a. structural integrity - the integration of fabric, components, and seam engineering needed to meet the major seam and minor seam performance requirements of a new FR garment. b. major seam - a critical sewn seam that demonstrates a new garment minimum seam strength of 70 lbf (315N) c. minor seam - a non-critical sewn seam that demonstrates a new garment minimum seam strength of 50 lbf (225N) d. critical seam- a single layer garment junction where failure prevents the wearer from performing assigned tasks because of immediate or imminent danger caused by the failure; requires immediate replacement *on a pair of trousers: this can include the outside seam, the inside seam, the crotch seam, the seat seam, the zipper attachment *on a shirt - this can include the side seam, the shoulder seams, the collar *on a coverall - this can include the outside seam (top - along torso/bottom-along lower trunk), the inside/crotch seat seams, shoulder seams, zipper e. non-critical seams - in a single layer garment junction where failure allows the wearer to continue performing the assigned tasks until the earliest opportunity for replacement or repair * on a pair of trousers - this can include a button, a hem, a pocket, a belt loop, a pocket flap * on a shirt - this can include a hem, a pocket, a collar flap, a button * on a coverall - this can include a hem, a pocket, a pocket flap *

Submitter Information Verification

Submitter Full Name: Vincent Diaz Organization: Atlantic Thread & Supply Compa Street Address: City: State: Zip: Submittal Date: Fri Jul 04 10:47:39 EDT 2014

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Public Input No. 69-NFPA 2112-2014 [ Chapter 4 ]

Chapter 4 Certification 4.1 General. 4.1.1 All flame-resistant garments, balaclavas/hoods, gloves, and footwear that are labeled as being compliant with this standard shall meet or exceed all applicable requirements specified in this standard and shall be certified. 4.1.2 All test data used to determine compliance of flame-resistant garments, balaclavas/hoods, gloves, and footwear with this standard shall be provided by an accredited testing laboratory. 4.1.3 All flame-resistant garments, balaclavas/hoods, gloves, and footwear shall be labeled and listed. 4.1.4 All flame-resistant garments shall have a product label, which shall meet the requirements of Section 5.1. 4.1.5* The certification organization's label, symbol, or identifying mark shall be attached to the product label, be part of the product label, or be immediately adjacent to the product label. 4.1.6 Manufacturers shall not claim compliance with a portion(s) or segment(s) of the requirements of this standard and shall not use the name or identification of this standard in any statements about their respective product(s) unless the product(s) is certified as compliant to this standard. 4.1.7 The certification organization shall not certify any flame-resistant garments to the 2007 edition of this standard on or after August 1, 2012. 4.1.8 The certification organization shall not permit any manufacturer to label any flame-resistant garments as compliant with the 2007 edition of this standard on or after August 1, 2012. 4.2 Certification Program. 4.2.1* The certification organization shall not be owned or controlled by manufacturers or vendors of the product being certified. 4.2.2 The certification organization shall be primarily engaged in certification work and shall not have a monetary interest in the product's ultimate profitability. 4.2.3 The certification organization shall be accredited for personal protective equipment in accordance with ISO/IEC Guide 65, General Requirements for Bodies Operating Product Certification Systems. 4.2.4 The certification organization shall refuse to certify products to this standard that do not comply with all applicable requirements of this standard. 4.2.5* The contractual provisions between the certification organization and the manufacturer shall specify that certification is contingent on compliance with all applicable requirements of this standard. 4.2.5.1 There shall be no conditional, temporary, or partial certifications. 4.2.5.2 Manufacturers shall not be authorized to use any label or reference to the certification organization on products that are not manufactured in compliance with all applicable requirements of this standard. 4.2.6 The certification organization shall have a program to accredit laboratories to perform the tests required by this standard.

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4.2.6.1 The accredited laboratory shall conduct the required tests and maintain documentation of test results. 4.2.6.2 The accredited laboratory shall have laboratory facilities and equipment available for conducting required tests. 4.2.7 A program for calibration of all instruments shall be in place and operating, and procedures shall be in use to ensure proper control of all testing. 4.2.8 In the absence of an accredited laboratory, the certification organization shall be permitted to have its own laboratory facilities and equipment available for conducting required tests. 4.2.9* The certification organization shall require the manufacturer to establish and maintain a program of production inspection and testing that meets the requirements of Section 4.4. 4.2.9.1 The certification organization shall ensure that the audit assurance program provides continued product compliance with this standard. 4.2.9.2 The certification organization shall permit the manufacturer to be registered to ISO 9001, Quality Management Systems — Requirements, in lieu of meeting the requirements of Section 4.4. 4.2.10 The certification organization and the manufacturer shall evaluate any changes affecting the form, fit, or function of the certified product to determine its continued certification to this standard. 4.2.11* The certification organization shall have a follow-up inspection program of the manufacturing facilities of the certified product, with a minimum of one visit per 12-month period. 4.2.12 As part of the follow-up inspection program, the certification organization shall review the manufacturer's records and sample product to ensure the following:

(1) Garments conform with the requirements of this standard. (2) The manufacturer has documentation that the fabric and components used in the garment were tested by an accredited laboratory and comply with this standard. (3) A manufacturing quality assurance plan meeting the requirements of this standard is in place.

4.2.13 The certification organization shall also have a follow-up inspection program of the accredited testing laboratory(ies). 4.2.13.1 The certification organization shall conduct a minimum of one visit per 12-month period. 4.2.13.2 The certification organization shall review the accredited laboratory's records and facilities to ensure required documentation is maintained and to ensure conformance with testing requirements. 4.2.14 The certification organization shall have a program for investigating field reports alleging malperformance or failure of listed products. 4.2.15* The certification organization shall require the manufacturer to have a product recall system as part of the manufacturer's quality assurance program. 4.2.16 The certification organization's operating procedures shall provide a mechanism for the manufacturer to appeal decisions, which shall include the presentation of information from both sides of a controversy to a designated appeals panel. 4.2.17 The certification organization shall be in a position to use legal means to protect the integrity of its name and label, which shall be registered and legally defended.

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4.3 Inspection and Testing. 4.3.1 For the certification of flame-resistant garments, balaclavas/hoods, gloves, and footwear, the certification organization shall conduct inspections of the manufacturing facility and the accredited laboratory, as specified in 4.3.2 through 4.3.9. 4.3.2 All inspections, evaluations, conditioning, and testing for certification or for recertification shall be conducted by the certification organization or a facility accredited for inspections, evaluations, conditioning, and testing in accordance with all requirements pertaining to testing laboratories in ISO 17025, General Requirements for the Competence of Testing and Calibration Laboratories. 4.3.3 All inspections, evaluations, conditioning, or testing conducted by a product manufacturer shall not be used in the certification or recertification process unless the facility for inspections, evaluations, conditioning, or testing has been accredited in accordance with all requirements pertaining to testing laboratories in ISO 17025, General Requirements for the Competence of Testing and Calibration Laboratories. 4.3.4 Inspection by the certification organization shall include a review of all product labels to ensure that all required label attachment, compliance statements, certification statements, and other product information are as specified for the specific item in Section 5.1. 4.3.5 Inspection by the certification organization shall include a review of any graphic representations used on product labels, as permitted in 5.1.6 to ensure that the systems are consistent with the worded statements, are readily understood, and clearly communicate the intended message. 4.3.6 Inspection by the certification organization shall include a review of the user information required by Section 5.2 to ensure that the information has been developed and is available. 4.3.7 Inspection by the certification organization for determining compliance with the design requirements specified in Chapter 6 shall be performed on whole or complete products. 4.3.8 Testing conducted by the accredited laboratory in accordance with the testing requirements of Chapter 8, for determining product compliance with the applicable requirements specified in Chapter 7, shall be performed on samples representative of materials and components used in the actual construction of the flame-resistant garment, balaclava/hood, glove, or footwear, or sample materials cut from a representative product. 4.3.9 Recertification. 4.3.9.1 Any change in the design, construction, or material of a compliant product shall require new inspection and testing to verify compliance with all applicable requirements of this standard that the certification organization determines can be affected by such change. 4.3.9.2 Recertification shall be conducted before labeling the modified products as being compliant with this standard. 4.3.10 Product Modifications. 4.3.10.1 The certification organization shall not permit any modifications, pretreatment, conditioning, or other such special processes of the product or any product component prior to the product's submission for evaluation and testing by the accredited laboratory. 4.3.10.2 The accredited laboratory shall accept, from the manufacturer for evaluation and testing for certification, only product or product components that are the same in every respect to the actual final product or product component. 4.3.10.3 The accredited laboratory shall not permit the substitution, repair, or modification, other than as specifically permitted herein, of any product or any product component during testing. 4.4 Manufacturer's Quality Assurance Program. 4.4.1 General.

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4.4.1.1 The manufacturer shall provide and maintain a quality assurance program that includes a documented inspection and product recall system. 4.4.1.2 The manufacturer shall have an inspection system to substantiate conformance to this standard. 4.4.1.3* The manufacturer shall be permitted to be registered to ISO 9001, Quality Management Systems — Requirements, in lieu of meeting the requirements of 4.4.2 through 4.4.8. 4.4.2 Instructions. 4.4.2.1 The manufacturer shall maintain written inspection and testing instructions. 4.4.2.2 The instructions shall prescribe inspection and test of materials, work in process, and completed articles. 4.4.2.3 Criteria for acceptance and rejection of materials, processes, and final product shall be part of the instructions. 4.4.3 Records. 4.4.3.1 The manufacturer shall maintain records of all “pass” and “fail” tests. 4.4.3.2 Records shall indicate the disposition of the failed materials or products. 4.4.4 Inspection System. The manufacturer's inspection system shall provide for procedures that assure the latest applicable drawings, specifications, and instructions are used for fabrication, inspection, and testing. 4.4.5 Calibration Program. 4.4.5.1 The manufacturer shall maintain, as part of the quality assurance program, a calibration program of all instruments used to ensure proper control of testing. 4.4.5.2 The calibration program shall be documented as to the date of calibration and performance verification. 4.4.6 Inspection Status. The manufacturer shall maintain a system for identifying the inspection status of component materials, work in process, and finished goods. 4.4.7 Nonconforming Materials. 4.4.7.1 The manufacturer shall establish and maintain a system for controlling nonconforming material, including procedures for the identification, segregation, and disposition of rejected material. 4.4.7.2 All nonconforming materials or products shall be identified to prevent use, shipment, and intermingling with conforming materials or products. 4.4.8 Third-Party Audit. The manufacturer's quality assurance program shall be audited by the third-party certification organization to determine that the program ensures continued product compliance with this standard.

Statement of Problem and Substantiation for Public Input

Changes in certification section to address the additional of other clothing elements proposed as part of the revised scope for NFPA 2112

Submitter Information Verification

Submitter Full Name: Jeffrey Stull Organization: International Personnel Protection, Inc. Street Address: City:

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State: Zip: Submittal Date: Mon Jul 07 15:01:16 EDT 2014

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Public Input No. 59-NFPA 2112-2014 [ New Section after 4.4.8 ]

Performance after Cleaning (1) retained seam strength -- the seam strength of either a major seam or a minor seam after a specified number of washings (2) retained seam strength -- the percentage of structural integrity of a major seam or a minor seam after a specified number of washings Type your content here ...

Statement of Problem and Substantiation for Public Input

Following a discussion about NFPA 2112 and NFPA 1977 the submitter and chairman talked about the issue of seam strength after multiple washings. Because there is no "new" garment requirement identified in NFPA 2112, it was agreed to use the NFPA 1977 value for major seams and minor seams. The study will include: 1. Using at least 2 seam engneering strategies, make samples of major seams and minor seams for testing four groups of NFPA 2112 fabrics identified by chairman* 2. Using D 1683 confirm the structural integrity of major seams and minor seams for the four groups of NFPA identified fabrics* 3. Using AATCC 135, 1,V,Ai wash same number of samples of the four groups of fabrics a specified number of times, e.g. 25, 50, 100 times. 4. Following the washing of the samples in accordance with AATCC procedure, test specimens for retains seam strength using D 1683. 5. Create a report of findings to share with NFPA 2112 committee at fall 2014 meeting (Bring quantity of samples for examination) Fabrics identified: (R) IIIA; Protera(TM); ComfortBlen(TM); FR Cotton(88/12)

retained seam strength: substantiation for a definition of term to be determined following this study

Submitter Information Verification

Submitter Full Name: Vincent Diaz Organization: Atlantic Thread & Supply Compa Street Address: City: State: Zip: Submittal Date: Fri Jul 04 11:46:20 EDT 2014

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Public Input No. 70-NFPA 2112-2014 [ Chapter 5 ]

Chapter 5 Labeling and Information 5.1 Product Label Requirements. 5.1.1* All flame-resistant garments, balaclavas/hoods, gloves, and footwear shall have a product label or labels permanently and conspicuously attached to each flame-resistant garment, balaclava/hood, glove, and footwear item . 5.1.2 At least one product label shall be conspicuously located inside each flame-resistant garment, balaclava/hood, glove, and footwear item when the item is properly assembled with all layers and components in place. 5.1.3 Multiple label pieces shall be permitted in order to carry all statements and information required to be on the product label. 5.1.4* The certification organization's label, symbol, or identifying mark shall be permanently attached to the product label or shall be part of the product label. 5.1.5 All worded portions of the required product label shall be printed in English. Supplementary languages, in addition to English, shall be permitted. 5.1.6 Symbols and other pictorial graphic representations shall be permitted to be used to supplement worded statements on the product label or labels. 5.1.7 Graphic representations shall be consistent to clearly communicate the intended message. 5.1.8 The following statement shall be printed legibly on the product label in letters at least 2.5 mm (0.10 in.) high: THIS GARMENT [or BALACLAVA/HOOD or GLOVE or FOOTWEAR] MEETS THE REQUIREMENTS OF NFPA 2112, STANDARD ON FLAME-RESISTANT GARMENTS CLOTHING FOR PROTECTION OF INDUSTRIAL PERSONNEL AGAINST FLASH FIRE, 2012 EDITION. NFPA 2113 REQUIRES UPPER AND LOWER BODY COVERAGE. 5.1.9 The following information shall also be printed legibly on the product label in letters at least 1.6 mm (0.063 in.) high:

(1) Model name, number, or design (2) Manufacturer's name, identification, or designation (3) Manufacturer's address (4) Country of manufacture (5) Manufacturer's garment identification [or balaclava/hood, or glove, or footwear] identification number, lot number, or serial number (6) Size (7) Fiber content (8) “DO NOT REMOVE”

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5.1.10 The product label shall also include the international symbol for “Read user instructions before use,” as shown in Figure 5.1.10. Figure 5.1.10 “Read User Instructions Before Use” Symbol.

5.1.11 The manufacturer shall be permitted to exclude the international symbol for “Read user instructions before use,” as described in 5.1.10, when all of the information specified in 5.2.1 is provided on the product label or other labels adjacent to the product label. 5.1.12 Garments with multiple layers, including an outer layer and removable cold weather insulation material layer, shall specify the certified wearable configurations on the label. 5.2 User Information. 5.2.1* The flame-resistant garment, balaclava/hood, glove, and footwear manufacturer shall provide information including, but not limited to, warnings, information, and instructions with each flame-resistant garment, balaclava/hood, glove, and footwear . 5.2.2* Manufacturers shall provide a sizing chart that indicates the range of key wearer measurements that are accommodated by each specific size of garment, balaclava/hood, glove, and footwear offered.

Statement of Problem and Substantiation for Public Input

The proposed changes address labeling and user information requirements for other recommended clothing elements suggested to be added to the scope.

Submitter Information Verification

Submitter Full Name: Jeffrey Stull Organization: International Personnel Protection, Inc. Street Address: City: State: Zip: Submittal Date: Mon Jul 07 15:30:53 EDT 2014

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Public Input No. 9-NFPA 2112-2013 [ Section No. 5.1.2 ]

5.1.2 At least one product label shall be conspicuously located inside each flame-resistant garment when the item is properly assembled with all layers and components in place .

Additional Proposed Changes

File Name Description Approved Proposed_TIA_1105_2112_.docx Balloted TIA

Statement of Problem and Substantiation for Public Input

Note: This Public Input originates from Tentative Interim Amendment 2112-12-2 (TIA 1105) issued by the Standards Council on August 1, 2013.

The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out) representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance

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requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

• A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

• Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

• Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

• Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

• A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

• Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

• Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

Submitter Information Verification

Submitter Full Name: TC on FLG-AAA

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Organization: TC on Flash Fire Protective Garments Street Address: City: State: Zip: Submittal Date: Fri Sep 06 14:13:30 EDT 2013

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NFPA 2112®-2012 Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire TIA Log No. 1105 Reference: Various Comment Closing Date: June 14, 2013 Submitter: Jeffrey O. Stull, International Personnel Protection, Inc.

1. Revise 3.3.6, A.3.3.6, and 3.3.20, and add a new A.3.3.20 to read as follows:

3.3.6* Cold Weather Insulation Material. A fabric that consists of one or more nonseparable layers that is used for protection in a low-temperature environment. A cold weather insulation material is not an interlining (see interlining).

A.3.3.6 Cold Weather Insulation Material. Examples of insulation materials are include textile battings(s) alone or batting(s) that are attached to a face cloth. For example, an insulation material consisting of two layers are considered nonseparable by the attachment that combines the two layers. The insulation material may or may not have a face cloth. Cold weather insulation materials generally are provided within the garment such that their area of coverage coincides with the majority of garment area covering the wearer’s body. Cold weather insulation material as defined in this standard does not preclude the use of intermediate layers for additional protection against thermal hazards.

3.3.20* Interlining. Any textile that is incorporated into any garment as a layer between outer and inner layers that only covers a small portion of the overall garment. [1975, 2009]

A.3.3.20 Interlining. The outer and inner layers are compliant to the fabric requirements of this standard. Examples of an interlining are a fabric layer used to stiffen the waist band in a pair of pants or a facing fabric used inside the closure flap of a coverall. Interlining materials do not come in contact with the wearer’s skin or underclothing.

2. Revise subsections 5.1.2, 5.1.9(7), and 5.1.12, and add a new 5.1.13 to read as follows:

5.1.2 At least one product label shall be conspicuously located inside each flame-resistant garment. when the item is properly assembled with all layers and components in place.

5.1.9(7) Fiber content for each primary fabric layer including cold weather insulation materials, but excluding interlinings and labels.

5.1.12 Garments with multiple layers, including an outer layer and removable cold weather insulation layer, shall specify the certified wearable configurations on the label configuration and include a warning on the label stating that all layers must be properly secured and worn in accordance with the manufacturer’s instructions.

5.1.13 For garments with multiple layers that include an outer layer and a removable cold weather insulation layer, a label shall be conspicuously attached to the removable insulation layer that states “DO NOT WEAR THIS LINER BY ITSELF. FOR COMPLIANCE WITH THE FLASH FIRE REQUIREMENTS OF NFPA 2112, THE COMPLETE GARMENT MUST BE WORN. FOR COMPLIANCE INFORMATION, SEE THE PRODUCT LABEL ON OUTER GARMENT.”

3. Add new Section 6.4 and subsections 6.4.1, and A.6.4.1 to read as follows:

6.4 Use of a Liner for Cold Weather Insulation. Garments shall be permitted to include liners in their construction including cold weather insulation materials where the liner is either integral to the garment or removable.

6.4.1* Where garments incorporate a cold weather insulation material as part of a removable lining system, the garment shall be designed such that the removable liner consisting of the cold weather insulation material cannot be independently worn.

A.6.4.1 Removable liners are permitted to be worn separately if the liner material(s) independently meets the appropriate fabric requirements in Chapter 7 including 7.1.1 for heat transfer performance and 7.1.5 for overall flash fire performance. If the liner contains cold weather insulation materials that are not evaluated to 7.1.1 and 7.1.5 and do not pass the thermal shrinkage resistance requirement in 7.1.3, then the manufacturer must label the liner as specified in 5.1.13 and provide a design that does not allow separate wearing of the liner without the outer layer. This may be demonstrated by the absence of a means of closure for the closure area of shirts, pants, and coveralls.

4. Add new subsections 7.1.1.1 and 7.1.1.2 to read as follows:

7.1.1.1 Where the flame-resistant garment consists of multiple and separable layers intended to be worn separately, the outer layer and the inner layer or layers shall be separately tested.

7.1.1.2 Where the flame-resistant garment consists of multiple layers intended only to be worn together, only the outer layer shall be tested.

5. Revise subsections 7.1.2 and 7.1.3 to read as follows:

7.1.2 Fabric, cold weather insulation material, and reflective striping utilized in the construction of flame-resistant garments shall be tested for flame resistance as specified in Section 8.3, and shall have a char length of not more than 100 mm (4 in.) and an after-flame of not more than 2 seconds, and shall not melt and drip.

7.1.3 Fabric utilized in the construction of flame-resistant garments, excluding manufacturer’s labels, interlinings, and cold weather insulation materials, shall be individually tested for thermal shrinkage resistance as specified in Section 8.4, and shall not shrink more than 10 percent in any direction.

6. Delete existing subsection 7.1.3.1 as follows:

7.1.3.1 Cold weather insulation materials utilized in the construction of flame-resistant garments shall be tested in accordance with Section 8.4 and shall not shrink more than 20 percent in any direction.

7. Revise subsection 7.1.4 to read as follows:

7.1.4 Fabric, cold weather insulation materials, other textile materials, and reflective striping other than those items described in 7.1.4.1 and 7.1.4.2, used in the construction of flame-resistant garments shall be individually tested for heat resistance in their original form as specified in Section 8.4, and shall not melt and drip, separate, or ignite.

8. Add a new subsection 8.3.1.7 to read as follows:

8.3.1.7 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.3.13.

9. Revise subsections 8.3.3.1, 8.3.3.2, and 8.3.3.3 to read as follows

8.3.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3.

8.3.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after 100 cycles of dry cleaning as specified in 8.1.4.

8.3.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3, or after 100 cycles of dry cleaning as specified in 8.1.4.

10. Add new subsections to 8.3.13 to read as follows:

8.3.13 Specific Requirements for Testing Cold Weather Insulation Materials.

8.3.13.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 66-cm × 66-cm (26-in. × 26-in.) panel of the cold weather insulation material. A similar-sized piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0- oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric.

8.3.13.2 Following wash or dry-clean conditioning, 5 specimens measuring 75 mm × 300 mm (3 in. × 12 in.) from each of the warp and filling direction shall be removed from the cold weather insulation material layer of the conditioned panels.

8.3.13.3 If applicable, all specimens shall be prepared for testing by trimming the scrim material, batting, or other layer(s) away from the face cloth by 50 mm ± 3 mm (2.0 in. ± 1/8 in.) such that the face cloth can be folded back covering the scrim, batting, or other layer(s) by 50 mm ± 3 mm (2.0 in. ± 1/8 in.); the folded specimen shall be secured in the specimen holder.

8.3.13.4 Testing shall be performed as described in 8.3.2 through 8.3.7.

11. Revise subsection 8.4.1 and add new subsections 8.4.1.1 through 8.4.1.5 to read as follows:

8.4.1 Application. The heat and thermal shrinkage resistance test method shall apply to flame resistant garment fabrics, components, and hardware.

8.4.1.1 This test method shall apply to flame-resistant garment fabrics, components, hardware, and cold weather insulation materials.

8.4.1.2 Modifications to this test method for testing flame-resistant garment textile materials shall be as specified in 8.4.8.

8.4.1.3 Modifications to this test method for testing other flame-resistant garment materials, including reflective striping, shall be as specified in 8.4.9.

8.4.1.4 Modifications to this test method for testing hardware shall be as specified in 8.4.10.

8.4.1.5 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.4.11.

12. Revise subsections 8.4.2.1 and 8.4.3.1 through 8.4.3.3 to read as follows:

8.4.2.1 Only heat resistance testing shall be conducted on not fewer than three specimens for each hardware item, label material, and other flame-resistant garment fabrics, and cold weather insulation materials not listed in 8.4.2.2 and 8.4.2.3.

8.4.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3.

8.4.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after three cycles of dry-cleaning as specified in 8.1.4.

8.4.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3, after three cycles of dry-cleaning as specified in 8.1.4.

13. Delete existing subsection 8.4.8.2 and renumber 8.4.8.3 to 8.4.8.2 to read as follows:

8.4.8.2 Measurements of cold weather insulation material thermal shrinkage shall be made on the side of the fabric facing the wearer as used in the construction of the garment.

8.4.8.3 8.4.8.2 Testing shall be performed in accordance with 8.4.2 through 8.4.7.

14. Add new subsection 8.4.11 to read as follows:

8.4.11 Specific Requirements for Testing Cold Weather Insulation Materials.

8.4.11.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 50-cm × 20-cm (20-in. × 8-in.) panel of the cold weather insulation material. A similar-sized cloth piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0-oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric .

8.4.11.2 Following wash or dry-clean conditioning, 3 specimens measuring 152 mm × 152 mm (6 in. × 6 in.) shall be removed from the cold weather insulation material layer of the conditioned panel.

8.4.11.3 Testing shall be performed in accordance with 8.4.2 through 8.4.7, and thermal shrinkage shall not be measured.

Submitter’s Substantiation: The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out)

representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

 A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

 Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

 Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

 Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

 A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

 Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

 Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes

criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

Public Input No. 41-NFPA 2112-2014 [ Section No. 5.1.8 ]

5.1.8 The following statement shall be printed legibly on the product label in letters at least 2.5 mm (0.10 in.) high: THIS GARMENT MEETS THE REQUIREMENTS OF NFPA 2112, STANDARD ON FLAME-RESISTANT GARMENTS FOR PROTECTION OF INDUSTRIAL PERSONNEL AGAINST FLASH SHORT DURATION THERMAL EXPOSURES FROM FIRE, 2012 2017 EDITION. NFPA 2113 REQUIRES UPPER AND LOWER BODY COVERAGE.

Statement of Problem and Substantiation for Public Input

"Flash" fires, or vapor cloud fires are a very small subset of actual fire types experienced in industrial environments with fire hazards. The potential fires that exist can be in the form of pressurized flammable line breaks (jet fires), flammable liquid spills (pool and running pool fires), combustible dust, and fireballs (from Boiling Liquid Expanding Vapor Explosions or flammable material container BLEVE). Actual thermal exposures can be in the form of full or partial flame contact or engulfment and/or exposure to the radiant energy from a fire's flame emissive power (e.g., when a worker is not in contact with the flames but is escaping the hazard). The standard is better served by identifying short duration thermal exposures from fire in the label, which encompasses all of the noted hazards and fits with the established standard's Purpose (1.2.1). Also added correction for the next edition (2017).

Submitter Information Verification

Submitter Full Name: Roger Parry Organization: The DuPont Company, Inc. Street Address: City: State: Zip: Submittal Date: Tue Jul 01 15:49:41 EDT 2014

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Public Input No. 10-NFPA 2112-2013 [ Section No. 5.1.9 ]

5.1.9 The following information shall also be printed legibly on the product label in letters at least 1.6 mm (0.063 in.) high:

(1) Model name, number, or design (2) Manufacturer's name, identification, or designation (3) Manufacturer's address (4) Country of manufacture (5) Manufacturer's garment identification number, lot number, or serial number (6) Size (7) Fiber content for each primary fabric layer including cold weather insulation materials, but excluding interlinings and labels (8) “DO NOT REMOVE”

Additional Proposed Changes

File Name Description Approved Proposed_TIA_1105_2112_.docx Balloted TIA

Statement of Problem and Substantiation for Public Input

Note: This Public Input originates from Tentative Interim Amendment 2112-12-2 (TIA 1105) issued by the Standards Council on August 1, 2013.

The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

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Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out) representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

• A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

• Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

• Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

• Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

• A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

• Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

• Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has

46 of 142 7/10/2014 8:54 AM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

Submitter Information Verification

Submitter Full Name: TC on FLG-AAA Organization: TC on Flash Fire Protective Garments Street Address: City: State: Zip: Submittal Date: Fri Sep 06 14:14:33 EDT 2013

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NFPA 2112®-2012 Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire TIA Log No. 1105 Reference: Various Comment Closing Date: June 14, 2013 Submitter: Jeffrey O. Stull, International Personnel Protection, Inc.

1. Revise 3.3.6, A.3.3.6, and 3.3.20, and add a new A.3.3.20 to read as follows:

3.3.6* Cold Weather Insulation Material. A fabric that consists of one or more nonseparable layers that is used for protection in a low-temperature environment. A cold weather insulation material is not an interlining (see interlining).

A.3.3.6 Cold Weather Insulation Material. Examples of insulation materials are include textile battings(s) alone or batting(s) that are attached to a face cloth. For example, an insulation material consisting of two layers are considered nonseparable by the attachment that combines the two layers. The insulation material may or may not have a face cloth. Cold weather insulation materials generally are provided within the garment such that their area of coverage coincides with the majority of garment area covering the wearer’s body. Cold weather insulation material as defined in this standard does not preclude the use of intermediate layers for additional protection against thermal hazards.

3.3.20* Interlining. Any textile that is incorporated into any garment as a layer between outer and inner layers that only covers a small portion of the overall garment. [1975, 2009]

A.3.3.20 Interlining. The outer and inner layers are compliant to the fabric requirements of this standard. Examples of an interlining are a fabric layer used to stiffen the waist band in a pair of pants or a facing fabric used inside the closure flap of a coverall. Interlining materials do not come in contact with the wearer’s skin or underclothing.

2. Revise subsections 5.1.2, 5.1.9(7), and 5.1.12, and add a new 5.1.13 to read as follows:

5.1.2 At least one product label shall be conspicuously located inside each flame-resistant garment. when the item is properly assembled with all layers and components in place.

5.1.9(7) Fiber content for each primary fabric layer including cold weather insulation materials, but excluding interlinings and labels.

5.1.12 Garments with multiple layers, including an outer layer and removable cold weather insulation layer, shall specify the certified wearable configurations on the label configuration and include a warning on the label stating that all layers must be properly secured and worn in accordance with the manufacturer’s instructions.

5.1.13 For garments with multiple layers that include an outer layer and a removable cold weather insulation layer, a label shall be conspicuously attached to the removable insulation layer that states “DO NOT WEAR THIS LINER BY ITSELF. FOR COMPLIANCE WITH THE FLASH FIRE REQUIREMENTS OF NFPA 2112, THE COMPLETE GARMENT MUST BE WORN. FOR COMPLIANCE INFORMATION, SEE THE PRODUCT LABEL ON OUTER GARMENT.”

3. Add new Section 6.4 and subsections 6.4.1, and A.6.4.1 to read as follows:

6.4 Use of a Liner for Cold Weather Insulation. Garments shall be permitted to include liners in their construction including cold weather insulation materials where the liner is either integral to the garment or removable.

6.4.1* Where garments incorporate a cold weather insulation material as part of a removable lining system, the garment shall be designed such that the removable liner consisting of the cold weather insulation material cannot be independently worn.

A.6.4.1 Removable liners are permitted to be worn separately if the liner material(s) independently meets the appropriate fabric requirements in Chapter 7 including 7.1.1 for heat transfer performance and 7.1.5 for overall flash fire performance. If the liner contains cold weather insulation materials that are not evaluated to 7.1.1 and 7.1.5 and do not pass the thermal shrinkage resistance requirement in 7.1.3, then the manufacturer must label the liner as specified in 5.1.13 and provide a design that does not allow separate wearing of the liner without the outer layer. This may be demonstrated by the absence of a means of closure for the closure area of shirts, pants, and coveralls.

4. Add new subsections 7.1.1.1 and 7.1.1.2 to read as follows:

7.1.1.1 Where the flame-resistant garment consists of multiple and separable layers intended to be worn separately, the outer layer and the inner layer or layers shall be separately tested.

7.1.1.2 Where the flame-resistant garment consists of multiple layers intended only to be worn together, only the outer layer shall be tested.

5. Revise subsections 7.1.2 and 7.1.3 to read as follows:

7.1.2 Fabric, cold weather insulation material, and reflective striping utilized in the construction of flame-resistant garments shall be tested for flame resistance as specified in Section 8.3, and shall have a char length of not more than 100 mm (4 in.) and an after-flame of not more than 2 seconds, and shall not melt and drip.

7.1.3 Fabric utilized in the construction of flame-resistant garments, excluding manufacturer’s labels, interlinings, and cold weather insulation materials, shall be individually tested for thermal shrinkage resistance as specified in Section 8.4, and shall not shrink more than 10 percent in any direction.

6. Delete existing subsection 7.1.3.1 as follows:

7.1.3.1 Cold weather insulation materials utilized in the construction of flame-resistant garments shall be tested in accordance with Section 8.4 and shall not shrink more than 20 percent in any direction.

7. Revise subsection 7.1.4 to read as follows:

7.1.4 Fabric, cold weather insulation materials, other textile materials, and reflective striping other than those items described in 7.1.4.1 and 7.1.4.2, used in the construction of flame-resistant garments shall be individually tested for heat resistance in their original form as specified in Section 8.4, and shall not melt and drip, separate, or ignite.

8. Add a new subsection 8.3.1.7 to read as follows:

8.3.1.7 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.3.13.

9. Revise subsections 8.3.3.1, 8.3.3.2, and 8.3.3.3 to read as follows

8.3.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3.

8.3.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after 100 cycles of dry cleaning as specified in 8.1.4.

8.3.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3, or after 100 cycles of dry cleaning as specified in 8.1.4.

10. Add new subsections to 8.3.13 to read as follows:

8.3.13 Specific Requirements for Testing Cold Weather Insulation Materials.

8.3.13.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 66-cm × 66-cm (26-in. × 26-in.) panel of the cold weather insulation material. A similar-sized piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0- oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric.

8.3.13.2 Following wash or dry-clean conditioning, 5 specimens measuring 75 mm × 300 mm (3 in. × 12 in.) from each of the warp and filling direction shall be removed from the cold weather insulation material layer of the conditioned panels.

8.3.13.3 If applicable, all specimens shall be prepared for testing by trimming the scrim material, batting, or other layer(s) away from the face cloth by 50 mm ± 3 mm (2.0 in. ± 1/8 in.) such that the face cloth can be folded back covering the scrim, batting, or other layer(s) by 50 mm ± 3 mm (2.0 in. ± 1/8 in.); the folded specimen shall be secured in the specimen holder.

8.3.13.4 Testing shall be performed as described in 8.3.2 through 8.3.7.

11. Revise subsection 8.4.1 and add new subsections 8.4.1.1 through 8.4.1.5 to read as follows:

8.4.1 Application. The heat and thermal shrinkage resistance test method shall apply to flame resistant garment fabrics, components, and hardware.

8.4.1.1 This test method shall apply to flame-resistant garment fabrics, components, hardware, and cold weather insulation materials.

8.4.1.2 Modifications to this test method for testing flame-resistant garment textile materials shall be as specified in 8.4.8.

8.4.1.3 Modifications to this test method for testing other flame-resistant garment materials, including reflective striping, shall be as specified in 8.4.9.

8.4.1.4 Modifications to this test method for testing hardware shall be as specified in 8.4.10.

8.4.1.5 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.4.11.

12. Revise subsections 8.4.2.1 and 8.4.3.1 through 8.4.3.3 to read as follows:

8.4.2.1 Only heat resistance testing shall be conducted on not fewer than three specimens for each hardware item, label material, and other flame-resistant garment fabrics, and cold weather insulation materials not listed in 8.4.2.2 and 8.4.2.3.

8.4.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3.

8.4.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after three cycles of dry-cleaning as specified in 8.1.4.

8.4.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3, after three cycles of dry-cleaning as specified in 8.1.4.

13. Delete existing subsection 8.4.8.2 and renumber 8.4.8.3 to 8.4.8.2 to read as follows:

8.4.8.2 Measurements of cold weather insulation material thermal shrinkage shall be made on the side of the fabric facing the wearer as used in the construction of the garment.

8.4.8.3 8.4.8.2 Testing shall be performed in accordance with 8.4.2 through 8.4.7.

14. Add new subsection 8.4.11 to read as follows:

8.4.11 Specific Requirements for Testing Cold Weather Insulation Materials.

8.4.11.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 50-cm × 20-cm (20-in. × 8-in.) panel of the cold weather insulation material. A similar-sized cloth piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0-oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric .

8.4.11.2 Following wash or dry-clean conditioning, 3 specimens measuring 152 mm × 152 mm (6 in. × 6 in.) shall be removed from the cold weather insulation material layer of the conditioned panel.

8.4.11.3 Testing shall be performed in accordance with 8.4.2 through 8.4.7, and thermal shrinkage shall not be measured.

Submitter’s Substantiation: The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out)

representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

 A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

 Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

 Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

 Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

 A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

 Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

 Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes

criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

Public Input No. 33-NFPA 2112-2014 [ Section No. 5.1.9 ]

5.1.9 The following information shall also be printed legibly on the product label in letters at least 1.6 mm (0.063 in.) high:

(1) Model name, number, or design (2) Manufacturer's name, identification, or designation (3) Manufacturer's address (4) Country of manufacture (5) Manufacturer's garment identification number, lot number, or serial number (6) Size (7) Fiber content (8) Wash cycles the garment can withstand (9) “DO NOT REMOVE”

Additional Proposed Changes

File Name Description Approved NFPA_public_input_T.Shelby.pdf NFPA 2112 Public Input section 5.1.9 (8)

Statement of Problem and Substantiation for Public Input

The system would not save my added revision in section 5.1.9 (8)

Submitter Information Verification

Submitter Full Name: thomas shelby Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Tue Jul 01 08:46:25 EDT 2014

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Public Input No. 33-NFPA 2112-2014

5.1.9 The following information shall also be printed legibly on the product label in letters at least 1.6 mm (0.063 in.) high: (1) Model name, number, or design (2) Manufacturer's name, identification, or designation (3) Manufacturer's address (4) Country of manufacture (5) Manufacturer's garment identification number, lot number, or serial number (6) Size (7) Fiber content (8) Wash cycles the garment can withstand (9) “DO NOT REMOVE”

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Public Input No. 11-NFPA 2112-2013 [ Section No. 5.1.12 ]

5.1.12 Garments with multiple layers, including an outer layer and removable cold weather insulation material layer, shall specify the certified wearable configurations configuration and include a warning on the label stating that all layers must be properly secured and worn in accordance with the manufacturer’s instructions . 5.1.13 For garments with multiple layers that include an outer layer and a removable cold weather insulation layer, a label shall be conspicuously attached to the removable insulation layer that states “DO NOT WEAR THIS LINER BY ITSELF. FOR COMPLIANCE WITH THE FLASH FIRE REQUIREMENTS OF NFPA 2112, THE COMPLETE GARMENT MUST BE WORN. FOR COMPLIANCE INFORMATION, SEE THE PRODUCT LABEL ON OUTER GARMENT.”

Additional Proposed Changes

File Name Description Approved Proposed_TIA_1105_2112_.docx Balloted TIA

Statement of Problem and Substantiation for Public Input

Note: This Public Input originates from Tentative Interim Amendment 2112-12-2 (TIA 1105) issued by the Standards Council on August 1, 2013.

The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with

49 of 142 7/10/2014 8:54 AM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out) representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

• A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

• Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

• Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

• Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

• A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

• Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

• Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified

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to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

Submitter Information Verification

Submitter Full Name: TC on FLG-AAA Organization: TC on Flash Fire Protective Garments Street Address: City: State: Zip: Submittal Date: Fri Sep 06 14:16:10 EDT 2013

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NFPA 2112®-2012 Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire TIA Log No. 1105 Reference: Various Comment Closing Date: June 14, 2013 Submitter: Jeffrey O. Stull, International Personnel Protection, Inc.

1. Revise 3.3.6, A.3.3.6, and 3.3.20, and add a new A.3.3.20 to read as follows:

3.3.6* Cold Weather Insulation Material. A fabric that consists of one or more nonseparable layers that is used for protection in a low-temperature environment. A cold weather insulation material is not an interlining (see interlining).

A.3.3.6 Cold Weather Insulation Material. Examples of insulation materials are include textile battings(s) alone or batting(s) that are attached to a face cloth. For example, an insulation material consisting of two layers are considered nonseparable by the attachment that combines the two layers. The insulation material may or may not have a face cloth. Cold weather insulation materials generally are provided within the garment such that their area of coverage coincides with the majority of garment area covering the wearer’s body. Cold weather insulation material as defined in this standard does not preclude the use of intermediate layers for additional protection against thermal hazards.

3.3.20* Interlining. Any textile that is incorporated into any garment as a layer between outer and inner layers that only covers a small portion of the overall garment. [1975, 2009]

A.3.3.20 Interlining. The outer and inner layers are compliant to the fabric requirements of this standard. Examples of an interlining are a fabric layer used to stiffen the waist band in a pair of pants or a facing fabric used inside the closure flap of a coverall. Interlining materials do not come in contact with the wearer’s skin or underclothing.

2. Revise subsections 5.1.2, 5.1.9(7), and 5.1.12, and add a new 5.1.13 to read as follows:

5.1.2 At least one product label shall be conspicuously located inside each flame-resistant garment. when the item is properly assembled with all layers and components in place.

5.1.9(7) Fiber content for each primary fabric layer including cold weather insulation materials, but excluding interlinings and labels.

5.1.12 Garments with multiple layers, including an outer layer and removable cold weather insulation layer, shall specify the certified wearable configurations on the label configuration and include a warning on the label stating that all layers must be properly secured and worn in accordance with the manufacturer’s instructions.

5.1.13 For garments with multiple layers that include an outer layer and a removable cold weather insulation layer, a label shall be conspicuously attached to the removable insulation layer that states “DO NOT WEAR THIS LINER BY ITSELF. FOR COMPLIANCE WITH THE FLASH FIRE REQUIREMENTS OF NFPA 2112, THE COMPLETE GARMENT MUST BE WORN. FOR COMPLIANCE INFORMATION, SEE THE PRODUCT LABEL ON OUTER GARMENT.”

3. Add new Section 6.4 and subsections 6.4.1, and A.6.4.1 to read as follows:

6.4 Use of a Liner for Cold Weather Insulation. Garments shall be permitted to include liners in their construction including cold weather insulation materials where the liner is either integral to the garment or removable.

6.4.1* Where garments incorporate a cold weather insulation material as part of a removable lining system, the garment shall be designed such that the removable liner consisting of the cold weather insulation material cannot be independently worn.

A.6.4.1 Removable liners are permitted to be worn separately if the liner material(s) independently meets the appropriate fabric requirements in Chapter 7 including 7.1.1 for heat transfer performance and 7.1.5 for overall flash fire performance. If the liner contains cold weather insulation materials that are not evaluated to 7.1.1 and 7.1.5 and do not pass the thermal shrinkage resistance requirement in 7.1.3, then the manufacturer must label the liner as specified in 5.1.13 and provide a design that does not allow separate wearing of the liner without the outer layer. This may be demonstrated by the absence of a means of closure for the closure area of shirts, pants, and coveralls.

4. Add new subsections 7.1.1.1 and 7.1.1.2 to read as follows:

7.1.1.1 Where the flame-resistant garment consists of multiple and separable layers intended to be worn separately, the outer layer and the inner layer or layers shall be separately tested.

7.1.1.2 Where the flame-resistant garment consists of multiple layers intended only to be worn together, only the outer layer shall be tested.

5. Revise subsections 7.1.2 and 7.1.3 to read as follows:

7.1.2 Fabric, cold weather insulation material, and reflective striping utilized in the construction of flame-resistant garments shall be tested for flame resistance as specified in Section 8.3, and shall have a char length of not more than 100 mm (4 in.) and an after-flame of not more than 2 seconds, and shall not melt and drip.

7.1.3 Fabric utilized in the construction of flame-resistant garments, excluding manufacturer’s labels, interlinings, and cold weather insulation materials, shall be individually tested for thermal shrinkage resistance as specified in Section 8.4, and shall not shrink more than 10 percent in any direction.

6. Delete existing subsection 7.1.3.1 as follows:

7.1.3.1 Cold weather insulation materials utilized in the construction of flame-resistant garments shall be tested in accordance with Section 8.4 and shall not shrink more than 20 percent in any direction.

7. Revise subsection 7.1.4 to read as follows:

7.1.4 Fabric, cold weather insulation materials, other textile materials, and reflective striping other than those items described in 7.1.4.1 and 7.1.4.2, used in the construction of flame-resistant garments shall be individually tested for heat resistance in their original form as specified in Section 8.4, and shall not melt and drip, separate, or ignite.

8. Add a new subsection 8.3.1.7 to read as follows:

8.3.1.7 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.3.13.

9. Revise subsections 8.3.3.1, 8.3.3.2, and 8.3.3.3 to read as follows

8.3.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3.

8.3.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after 100 cycles of dry cleaning as specified in 8.1.4.

8.3.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3, or after 100 cycles of dry cleaning as specified in 8.1.4.

10. Add new subsections to 8.3.13 to read as follows:

8.3.13 Specific Requirements for Testing Cold Weather Insulation Materials.

8.3.13.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 66-cm × 66-cm (26-in. × 26-in.) panel of the cold weather insulation material. A similar-sized piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0- oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric.

8.3.13.2 Following wash or dry-clean conditioning, 5 specimens measuring 75 mm × 300 mm (3 in. × 12 in.) from each of the warp and filling direction shall be removed from the cold weather insulation material layer of the conditioned panels.

8.3.13.3 If applicable, all specimens shall be prepared for testing by trimming the scrim material, batting, or other layer(s) away from the face cloth by 50 mm ± 3 mm (2.0 in. ± 1/8 in.) such that the face cloth can be folded back covering the scrim, batting, or other layer(s) by 50 mm ± 3 mm (2.0 in. ± 1/8 in.); the folded specimen shall be secured in the specimen holder.

8.3.13.4 Testing shall be performed as described in 8.3.2 through 8.3.7.

11. Revise subsection 8.4.1 and add new subsections 8.4.1.1 through 8.4.1.5 to read as follows:

8.4.1 Application. The heat and thermal shrinkage resistance test method shall apply to flame resistant garment fabrics, components, and hardware.

8.4.1.1 This test method shall apply to flame-resistant garment fabrics, components, hardware, and cold weather insulation materials.

8.4.1.2 Modifications to this test method for testing flame-resistant garment textile materials shall be as specified in 8.4.8.

8.4.1.3 Modifications to this test method for testing other flame-resistant garment materials, including reflective striping, shall be as specified in 8.4.9.

8.4.1.4 Modifications to this test method for testing hardware shall be as specified in 8.4.10.

8.4.1.5 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.4.11.

12. Revise subsections 8.4.2.1 and 8.4.3.1 through 8.4.3.3 to read as follows:

8.4.2.1 Only heat resistance testing shall be conducted on not fewer than three specimens for each hardware item, label material, and other flame-resistant garment fabrics, and cold weather insulation materials not listed in 8.4.2.2 and 8.4.2.3.

8.4.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3.

8.4.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after three cycles of dry-cleaning as specified in 8.1.4.

8.4.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3, after three cycles of dry-cleaning as specified in 8.1.4.

13. Delete existing subsection 8.4.8.2 and renumber 8.4.8.3 to 8.4.8.2 to read as follows:

8.4.8.2 Measurements of cold weather insulation material thermal shrinkage shall be made on the side of the fabric facing the wearer as used in the construction of the garment.

8.4.8.3 8.4.8.2 Testing shall be performed in accordance with 8.4.2 through 8.4.7.

14. Add new subsection 8.4.11 to read as follows:

8.4.11 Specific Requirements for Testing Cold Weather Insulation Materials.

8.4.11.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 50-cm × 20-cm (20-in. × 8-in.) panel of the cold weather insulation material. A similar-sized cloth piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0-oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric .

8.4.11.2 Following wash or dry-clean conditioning, 3 specimens measuring 152 mm × 152 mm (6 in. × 6 in.) shall be removed from the cold weather insulation material layer of the conditioned panel.

8.4.11.3 Testing shall be performed in accordance with 8.4.2 through 8.4.7, and thermal shrinkage shall not be measured.

Submitter’s Substantiation: The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out)

representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

 A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

 Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

 Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

 Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

 A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

 Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

 Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes

criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

Public Input No. 71-NFPA 2112-2014 [ Chapter 6 ]

Chapter 6 Design Requirements 6.1 Garments. 6.1.1 Hardware Finishes. All flame-resistant hardware finishes shall be free of rough spots, burrs, or sharp edges. 6.1. 2 Metal Components. Any metallic closure systems or metal components of the flame-resistant garments shall not come in direct contact with the body. 6.1. 3 Slide Fastener Tape Requirements. All slide fastener tape utilized in the construction of flame-resistant garments shall be made of an inherently flame-resistant fiber. 6.2 Balaclavas/Hoods. 6.2.1 Adopt requirements for hoods from NFPA 1971-2013 including 6.13.2, 6.13.3, 6.13.4, 6.13.5, and 6.13.6 (not 6.13.6.1 through 6.13.6.4) 6.3 Gloves. 6.3.1 Adopt requirements for gloves from NFPA 1977-2011 including 6.3.2 and 6.3.3. 6.3.2 Gloves shall be required to be classified according to ANSI/ISEA 105, American National Standard for Hand Protection Selection Criteria, for mechanical protection including cut resistance, puncture resistance, and abrasion resistance, and for dexterity. 6.4 Footwear. 6.4.1 Adopt requirements for footwear from NFPA 1977-2011 including paragraphs 6.4.2 through 6.4.9 (including subparagraphs). 6.4.2 Footwear shall meet the performance requirements as specified in ASTM F2413, Performance Requirements for Protective (Safety) Toe Cap Footwear for impact, compression, and puncture resistance. 6.5 Rainwear. 6.5.1 Rainwear shall meet the requirements for ASTM F2733, Standard Specification for Flame Resistant Rainwear for Protection Against Flame Hazards.

Statement of Problem and Substantiation for Public Input

The proposed design requirements address base requirements for proposed clothing elements to be added to the scope of the standard.

Submitter Information Verification

Submitter Full Name: Jeffrey Stull Organization: International Personnel Protection, Inc. Street Address: City: State: Zip: Submittal Date: Mon Jul 07 15:58:10 EDT 2014

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Public Input No. 66-NFPA 2112-2014 [ New Section after 6.1 ]

6.x Garment design Shirts and coveralls shall have long sleeves.

Statement of Problem and Substantiation for Public Input

This is an attempt to reconcile 2112 requirements with language that already exists in NFPA 2113 which states: 4.3.2 Garments shall be selected that cover both the upper and lower body and flammable layers as completely as possible.

Submitter Information Verification

Submitter Full Name: DENISE STATHAM Organization: BULWARK PROTECTIVE APPAREL Street Address: City: State: Zip: Submittal Date: Mon Jul 07 14:13:00 EDT 2014

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Public Input No. 12-NFPA 2112-2013 [ New Section after 6.3 ]

6.4 Use of a Liner for Cold Weather Insulation. Garments shall be permitted to include liners in their construction including cold weather insulation materials where the liner is either integral to the garment or removable. 6.4.1* Where garments incorporate a cold weather insulation material as part of a removable lining system, the garment shall be designed such that the removable liner consisting of the cold weather insulation material cannot be independently worn.

Additional Proposed Changes

File Name Description Approved Proposed_TIA_1105_2112_.docx Balloted TIA

Statement of Problem and Substantiation for Public Input

Note: This Public Input originates from Tentative Interim Amendment 2112-12-2 (TIA 1105) issued by the Standards Council on August 1, 2013.

The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out) representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes

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to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

• A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

• Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

• Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

• Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

• A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

• Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

• Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

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Submitter Information Verification

Submitter Full Name: TC on FLG-AAA Organization: TC on Flash Fire Protective Garments Street Address: City: State: Zip: Submittal Date: Fri Sep 06 14:18:48 EDT 2013

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NFPA 2112®-2012 Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire TIA Log No. 1105 Reference: Various Comment Closing Date: June 14, 2013 Submitter: Jeffrey O. Stull, International Personnel Protection, Inc.

1. Revise 3.3.6, A.3.3.6, and 3.3.20, and add a new A.3.3.20 to read as follows:

3.3.6* Cold Weather Insulation Material. A fabric that consists of one or more nonseparable layers that is used for protection in a low-temperature environment. A cold weather insulation material is not an interlining (see interlining).

A.3.3.6 Cold Weather Insulation Material. Examples of insulation materials are include textile battings(s) alone or batting(s) that are attached to a face cloth. For example, an insulation material consisting of two layers are considered nonseparable by the attachment that combines the two layers. The insulation material may or may not have a face cloth. Cold weather insulation materials generally are provided within the garment such that their area of coverage coincides with the majority of garment area covering the wearer’s body. Cold weather insulation material as defined in this standard does not preclude the use of intermediate layers for additional protection against thermal hazards.

3.3.20* Interlining. Any textile that is incorporated into any garment as a layer between outer and inner layers that only covers a small portion of the overall garment. [1975, 2009]

A.3.3.20 Interlining. The outer and inner layers are compliant to the fabric requirements of this standard. Examples of an interlining are a fabric layer used to stiffen the waist band in a pair of pants or a facing fabric used inside the closure flap of a coverall. Interlining materials do not come in contact with the wearer’s skin or underclothing.

2. Revise subsections 5.1.2, 5.1.9(7), and 5.1.12, and add a new 5.1.13 to read as follows:

5.1.2 At least one product label shall be conspicuously located inside each flame-resistant garment. when the item is properly assembled with all layers and components in place.

5.1.9(7) Fiber content for each primary fabric layer including cold weather insulation materials, but excluding interlinings and labels.

5.1.12 Garments with multiple layers, including an outer layer and removable cold weather insulation layer, shall specify the certified wearable configurations on the label configuration and include a warning on the label stating that all layers must be properly secured and worn in accordance with the manufacturer’s instructions.

5.1.13 For garments with multiple layers that include an outer layer and a removable cold weather insulation layer, a label shall be conspicuously attached to the removable insulation layer that states “DO NOT WEAR THIS LINER BY ITSELF. FOR COMPLIANCE WITH THE FLASH FIRE REQUIREMENTS OF NFPA 2112, THE COMPLETE GARMENT MUST BE WORN. FOR COMPLIANCE INFORMATION, SEE THE PRODUCT LABEL ON OUTER GARMENT.”

3. Add new Section 6.4 and subsections 6.4.1, and A.6.4.1 to read as follows:

6.4 Use of a Liner for Cold Weather Insulation. Garments shall be permitted to include liners in their construction including cold weather insulation materials where the liner is either integral to the garment or removable.

6.4.1* Where garments incorporate a cold weather insulation material as part of a removable lining system, the garment shall be designed such that the removable liner consisting of the cold weather insulation material cannot be independently worn.

A.6.4.1 Removable liners are permitted to be worn separately if the liner material(s) independently meets the appropriate fabric requirements in Chapter 7 including 7.1.1 for heat transfer performance and 7.1.5 for overall flash fire performance. If the liner contains cold weather insulation materials that are not evaluated to 7.1.1 and 7.1.5 and do not pass the thermal shrinkage resistance requirement in 7.1.3, then the manufacturer must label the liner as specified in 5.1.13 and provide a design that does not allow separate wearing of the liner without the outer layer. This may be demonstrated by the absence of a means of closure for the closure area of shirts, pants, and coveralls.

4. Add new subsections 7.1.1.1 and 7.1.1.2 to read as follows:

7.1.1.1 Where the flame-resistant garment consists of multiple and separable layers intended to be worn separately, the outer layer and the inner layer or layers shall be separately tested.

7.1.1.2 Where the flame-resistant garment consists of multiple layers intended only to be worn together, only the outer layer shall be tested.

5. Revise subsections 7.1.2 and 7.1.3 to read as follows:

7.1.2 Fabric, cold weather insulation material, and reflective striping utilized in the construction of flame-resistant garments shall be tested for flame resistance as specified in Section 8.3, and shall have a char length of not more than 100 mm (4 in.) and an after-flame of not more than 2 seconds, and shall not melt and drip.

7.1.3 Fabric utilized in the construction of flame-resistant garments, excluding manufacturer’s labels, interlinings, and cold weather insulation materials, shall be individually tested for thermal shrinkage resistance as specified in Section 8.4, and shall not shrink more than 10 percent in any direction.

6. Delete existing subsection 7.1.3.1 as follows:

7.1.3.1 Cold weather insulation materials utilized in the construction of flame-resistant garments shall be tested in accordance with Section 8.4 and shall not shrink more than 20 percent in any direction.

7. Revise subsection 7.1.4 to read as follows:

7.1.4 Fabric, cold weather insulation materials, other textile materials, and reflective striping other than those items described in 7.1.4.1 and 7.1.4.2, used in the construction of flame-resistant garments shall be individually tested for heat resistance in their original form as specified in Section 8.4, and shall not melt and drip, separate, or ignite.

8. Add a new subsection 8.3.1.7 to read as follows:

8.3.1.7 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.3.13.

9. Revise subsections 8.3.3.1, 8.3.3.2, and 8.3.3.3 to read as follows

8.3.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3.

8.3.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after 100 cycles of dry cleaning as specified in 8.1.4.

8.3.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3, or after 100 cycles of dry cleaning as specified in 8.1.4.

10. Add new subsections to 8.3.13 to read as follows:

8.3.13 Specific Requirements for Testing Cold Weather Insulation Materials.

8.3.13.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 66-cm × 66-cm (26-in. × 26-in.) panel of the cold weather insulation material. A similar-sized piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0- oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric.

8.3.13.2 Following wash or dry-clean conditioning, 5 specimens measuring 75 mm × 300 mm (3 in. × 12 in.) from each of the warp and filling direction shall be removed from the cold weather insulation material layer of the conditioned panels.

8.3.13.3 If applicable, all specimens shall be prepared for testing by trimming the scrim material, batting, or other layer(s) away from the face cloth by 50 mm ± 3 mm (2.0 in. ± 1/8 in.) such that the face cloth can be folded back covering the scrim, batting, or other layer(s) by 50 mm ± 3 mm (2.0 in. ± 1/8 in.); the folded specimen shall be secured in the specimen holder.

8.3.13.4 Testing shall be performed as described in 8.3.2 through 8.3.7.

11. Revise subsection 8.4.1 and add new subsections 8.4.1.1 through 8.4.1.5 to read as follows:

8.4.1 Application. The heat and thermal shrinkage resistance test method shall apply to flame resistant garment fabrics, components, and hardware.

8.4.1.1 This test method shall apply to flame-resistant garment fabrics, components, hardware, and cold weather insulation materials.

8.4.1.2 Modifications to this test method for testing flame-resistant garment textile materials shall be as specified in 8.4.8.

8.4.1.3 Modifications to this test method for testing other flame-resistant garment materials, including reflective striping, shall be as specified in 8.4.9.

8.4.1.4 Modifications to this test method for testing hardware shall be as specified in 8.4.10.

8.4.1.5 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.4.11.

12. Revise subsections 8.4.2.1 and 8.4.3.1 through 8.4.3.3 to read as follows:

8.4.2.1 Only heat resistance testing shall be conducted on not fewer than three specimens for each hardware item, label material, and other flame-resistant garment fabrics, and cold weather insulation materials not listed in 8.4.2.2 and 8.4.2.3.

8.4.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3.

8.4.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after three cycles of dry-cleaning as specified in 8.1.4.

8.4.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3, after three cycles of dry-cleaning as specified in 8.1.4.

13. Delete existing subsection 8.4.8.2 and renumber 8.4.8.3 to 8.4.8.2 to read as follows:

8.4.8.2 Measurements of cold weather insulation material thermal shrinkage shall be made on the side of the fabric facing the wearer as used in the construction of the garment.

8.4.8.3 8.4.8.2 Testing shall be performed in accordance with 8.4.2 through 8.4.7.

14. Add new subsection 8.4.11 to read as follows:

8.4.11 Specific Requirements for Testing Cold Weather Insulation Materials.

8.4.11.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 50-cm × 20-cm (20-in. × 8-in.) panel of the cold weather insulation material. A similar-sized cloth piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0-oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric .

8.4.11.2 Following wash or dry-clean conditioning, 3 specimens measuring 152 mm × 152 mm (6 in. × 6 in.) shall be removed from the cold weather insulation material layer of the conditioned panel.

8.4.11.3 Testing shall be performed in accordance with 8.4.2 through 8.4.7, and thermal shrinkage shall not be measured.

Submitter’s Substantiation: The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out)

representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

 A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

 Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

 Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

 Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

 A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

 Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

 Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes

criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

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Public Input No. 61-NFPA 2112-2014 [ New Section after 6.3 ]

6.4. Non-FR heraldry. When non-FR heraldry is attached to the exterior of a garment, the maximum number of emblems shall be 5 with no individual emblem covering an area greater than 16 square inches.

Statement of Problem and Substantiation for Public Input

Stating the maximum allowances for the number and size of non-FR emblems would answer the persistent question about the use of heraldry on FR garments. Clearly, there are safety implications when too much area of an FR garment is covered with anything that is non-FR. This new design requirement provides the necessary guidelines to keep wearers safe.

Submitter Information Verification

Submitter Full Name: DENISE STATHAM Organization: BULWARK PROTECTIVE APPAREL Street Address: City: State: Zip: Submittal Date: Sun Jul 06 23:23:04 EDT 2014

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Public Input No. 64-NFPA 2112-2014 [ New Section after 6.3 ]

6.x Garment Closure System Hook and loop shall not be used as a primary front closure system.

Statement of Problem and Substantiation for Public Input

For FR garments to be fully effective, they must be worn correctly by, among other things, engaging all closure systems. Hook and loop can become less effective/dependable over the life of the garment.

Submitter Information Verification

Submitter Full Name: DENISE STATHAM Organization: BULWARK PROTECTIVE APPAREL Street Address: City: State: Zip: Submittal Date: Mon Jul 07 11:00:17 EDT 2014

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Public Input No. 74-NFPA 2112-2014 [ New Section after 6.3 ]

6.2.1 In the case where an outerwear piece has a removable liner, the shell shall be exempt from the requirements of 6.2.

Statement of Problem and Substantiation for Public Input

Outerwear is intended to be worn over other NFPA 2112 certified clothing which has already met the requirements of not having metal that touches the wearer's skin.

Submitter Information Verification

Submitter Full Name: DENISE STATHAM Organization: BULWARK PROTECTIVE APPAREL Street Address: City: State: Zip: Submittal Date: Mon Jul 07 16:50:52 EDT 2014

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Public Input No. 72-NFPA 2112-2014 [ Chapter 7 ]

Chapter 7 Performance Requirements 7.1 Garment and Fabric Requirements. 7.1.1 Fabric utilized in the construction of flame-resistant garments shall be tested for heat transfer performance 2 (HTP) as specified in Section 8.2 and shall have a “spaced” HTP rating of not less than 25 J/cm (6.0 2 2 2 cal/cm ) and a “contact” HTP rating of not less than 12.6 J/cm (3.0 cal/cm ). 7.1.2 Fabric and reflective striping utilized in the construction of flame-resistant garments shall be tested for flame resistance as specified in Section 8.3, and shall have a char length of not more than 100 mm (4 in.) and an after-flame of not more than 2 seconds, and shall not melt and drip. 7.1.3 Fabric utilized in the construction of flame-resistant garments, excluding manufacturers' labels, shall be individually tested for thermal shrinkage resistance as specified in Section 8.4, and shall not shrink more than 10 percent in any direction. 7.1.3.1 Cold weather insulation materials utilized in the construction of flame-resistant garments shall be tested in accordance with Section 8.4 and shall not shrink more than 20 percent in any direction. 7.1.4 Fabric, other textile materials, and reflective striping, other than those items described in 7.1.4.1 and 7.1.4.2, used in the construction of flame-resistant garments shall be individually tested for heat resistance in their original form as specified in Section 8.4, and shall not melt and drip, separate, or ignite. 7.1.4.1 Labels and emblems shall not be required to be tested for heat resistance. 7.1.4.2 Interlinings, collar stays, elastics, closures, and hook and pile fasteners, when not in direct contact with the skin, shall not be required to be tested for heat resistance. 7.1.5 Specimen garments shall be tested for overall flash fire exposure as specified in Section 8.5 as a qualification test for the material and shall have an average predicted body burn of not more than 50 percent based on the total surface area covered by sensors, excluding hands and feet. 7.1.5.1 Garments consisting of separable layers, such as a removable cold weather insulation material layer, that are intended to be worn together or separately shall be tested in all wearable configurations identified by the manufacturer. 7.2 1.6 Thread Requirements. Specimens of all sewing thread utilized in the construction of flame-resistant garments, excluding embroidery, shall be made of an inherently flame-resistant fiber, shall be tested for heat resistance as specified in Section 8.6, and shall not melt. 7.3 1.7 Hardware Requirement. Specimens of hardware used in the construction of flame-resistant garments, including but not limited to buttons, fasteners, and closures, shall be individually tested for heat resistance in their original form as specified in Section 8.4; shall not melt and drip, separate, or ignite; and shall remain functional.

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7.4 1.8 Label Requirement. Specimen labels used in the construction of flame-resistant garments shall be tested for printing durability as specified in Section 8.7 and shall remain legible. 7.2 Balaclava/Hood Requirements. 7.2.1 Fabric utilized in the construction of flame-resistant balaclavas/hoods shall be tested for heat transfer protective performance (HTP) as specified in Section 8.2, and shall have a “spaced” HTP rating of not less than 25 J/cm2 (6.0 cal/cm2) and a “contact” TPP rating of not less than 12.6 J/cm2 (3.0 cal/cm2). 7.2.2 Fabric utilized in the construction of flame-resistant balaclavas/hoods shall be tested for flame resistance as specified in Section 8.3, and shall have a char length of not more than 100 mm (4 in.) and an afterflame of not more than 2 seconds, and shall not melt and drip. 7.2.3 Fabric utilized in the construction of flame-resistant garments, excluding manufacturers’ labels, shall be individually tested for thermal shrinkage resistance as specified in Section 8.4, and shall not shrink more than 10 percent in any direction. 7.2.4 Fabric, and other textile materials other than those items described in 7.1.4.1 and 7.1.4.2, used in the construction of flame-resistant balaclavas/hoods shall be individually tested for heat resistance in their original form as specified in Section 8.4, and shall not melt and drip, separate, or ignite. 7.2.4.1 Labels and emblems shall not be required to be tested for heat resistance. 7.2.4.2 Interlinings, elastics, closures, and hook and pile fasteners, when not in direct contact with the skin, shall not be required to be tested for heat resistance. 7.2.5 Specimens of all sewing thread utilized in the construction of flame-resistant balaclavas/hoods, excluding embroidery, shall be made of an inherently flame-resistant fiber, shall be tested for heat resistance as specified in Section 8.6, and shall not melt. 7.2.6 Specimens of hardware used in the construction of flame-resistant balaclavas/hoods, including but not limited to buttons, fasteners, and closures, shall be individually tested for heat resistance in their original form as specified in Section 8.4; shall not melt and drip, separate, or ignite; and shall remain functional. 7.2.7 Specimen labels used in the construction of flame-resistant garments shall be tested for printing durability as specified in Section 8.7 and shall remain legible. 7.3 Glove Requirements. 7.3.1 Adopt requiements from NFPA 1977-2011, including 7.3.1, 7.3.2, 7.3.3, 7.3.4, 7.3.9, and 7.3.10. 7.4 Footwear Requirements. 7.4.1 Adopt requirements from NFPA 1971-2011, including 7.4.1, 7.4.2, 7.4.6, 7.4.9, 7.4.10, and 7.4.11. 7.5 Rainwear Requirements. 7.5.1 Rainwear shall meet the requirements of ASTM F2733, Standard Specification for Protection Against Flame Hazards.

Statement of Problem and Substantiation for Public Input

Proposed performance requirements address flame, heat and thermal insulation performance for recommended new clothing elements to be added to scope of NFPA 2112.

Submitter Information Verification

Submitter Full Name: Jeffrey Stull Organization: International Personnel Protection, Inc. Street Address: City: State: Zip: Submittal Date: Mon Jul 07 16:22:15 EDT 2014

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Public Input No. 14-NFPA 2112-2013 [ New Section after 7.1.1 ]

7.1.1.1 Where the flame-resistant garment consists of multiple and separable layers intended to be worn separately, the outer layer and the inner layer or layers shall be separately tested. 7.1.1.2 Where the flame-resistant garment consists of multiple layers intended only to be worn together, only the outer layer shall be tested.

Additional Proposed Changes

File Name Description Approved Proposed_TIA_1105_2112_.docx Balloted TIA

Statement of Problem and Substantiation for Public Input

Note: This Public Input originates from Tentative Interim Amendment 2112-12-2 (TIA 1105) issued by the Standards Council on August 1, 2013.

The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out) representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

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It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

• A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

• Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

• Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

• Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

• A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

• Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

• Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

Submitter Information Verification

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Submitter Full Name: TC on FLG-AAA Organization: TC on Flash Fire Protective Garments Street Address: City: State: Zip: Submittal Date: Fri Sep 06 14:29:58 EDT 2013

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NFPA 2112®-2012 Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire TIA Log No. 1105 Reference: Various Comment Closing Date: June 14, 2013 Submitter: Jeffrey O. Stull, International Personnel Protection, Inc.

1. Revise 3.3.6, A.3.3.6, and 3.3.20, and add a new A.3.3.20 to read as follows:

3.3.6* Cold Weather Insulation Material. A fabric that consists of one or more nonseparable layers that is used for protection in a low-temperature environment. A cold weather insulation material is not an interlining (see interlining).

A.3.3.6 Cold Weather Insulation Material. Examples of insulation materials are include textile battings(s) alone or batting(s) that are attached to a face cloth. For example, an insulation material consisting of two layers are considered nonseparable by the attachment that combines the two layers. The insulation material may or may not have a face cloth. Cold weather insulation materials generally are provided within the garment such that their area of coverage coincides with the majority of garment area covering the wearer’s body. Cold weather insulation material as defined in this standard does not preclude the use of intermediate layers for additional protection against thermal hazards.

3.3.20* Interlining. Any textile that is incorporated into any garment as a layer between outer and inner layers that only covers a small portion of the overall garment. [1975, 2009]

A.3.3.20 Interlining. The outer and inner layers are compliant to the fabric requirements of this standard. Examples of an interlining are a fabric layer used to stiffen the waist band in a pair of pants or a facing fabric used inside the closure flap of a coverall. Interlining materials do not come in contact with the wearer’s skin or underclothing.

2. Revise subsections 5.1.2, 5.1.9(7), and 5.1.12, and add a new 5.1.13 to read as follows:

5.1.2 At least one product label shall be conspicuously located inside each flame-resistant garment. when the item is properly assembled with all layers and components in place.

5.1.9(7) Fiber content for each primary fabric layer including cold weather insulation materials, but excluding interlinings and labels.

5.1.12 Garments with multiple layers, including an outer layer and removable cold weather insulation layer, shall specify the certified wearable configurations on the label configuration and include a warning on the label stating that all layers must be properly secured and worn in accordance with the manufacturer’s instructions.

5.1.13 For garments with multiple layers that include an outer layer and a removable cold weather insulation layer, a label shall be conspicuously attached to the removable insulation layer that states “DO NOT WEAR THIS LINER BY ITSELF. FOR COMPLIANCE WITH THE FLASH FIRE REQUIREMENTS OF NFPA 2112, THE COMPLETE GARMENT MUST BE WORN. FOR COMPLIANCE INFORMATION, SEE THE PRODUCT LABEL ON OUTER GARMENT.”

3. Add new Section 6.4 and subsections 6.4.1, and A.6.4.1 to read as follows:

6.4 Use of a Liner for Cold Weather Insulation. Garments shall be permitted to include liners in their construction including cold weather insulation materials where the liner is either integral to the garment or removable.

6.4.1* Where garments incorporate a cold weather insulation material as part of a removable lining system, the garment shall be designed such that the removable liner consisting of the cold weather insulation material cannot be independently worn.

A.6.4.1 Removable liners are permitted to be worn separately if the liner material(s) independently meets the appropriate fabric requirements in Chapter 7 including 7.1.1 for heat transfer performance and 7.1.5 for overall flash fire performance. If the liner contains cold weather insulation materials that are not evaluated to 7.1.1 and 7.1.5 and do not pass the thermal shrinkage resistance requirement in 7.1.3, then the manufacturer must label the liner as specified in 5.1.13 and provide a design that does not allow separate wearing of the liner without the outer layer. This may be demonstrated by the absence of a means of closure for the closure area of shirts, pants, and coveralls.

4. Add new subsections 7.1.1.1 and 7.1.1.2 to read as follows:

7.1.1.1 Where the flame-resistant garment consists of multiple and separable layers intended to be worn separately, the outer layer and the inner layer or layers shall be separately tested.

7.1.1.2 Where the flame-resistant garment consists of multiple layers intended only to be worn together, only the outer layer shall be tested.

5. Revise subsections 7.1.2 and 7.1.3 to read as follows:

7.1.2 Fabric, cold weather insulation material, and reflective striping utilized in the construction of flame-resistant garments shall be tested for flame resistance as specified in Section 8.3, and shall have a char length of not more than 100 mm (4 in.) and an after-flame of not more than 2 seconds, and shall not melt and drip.

7.1.3 Fabric utilized in the construction of flame-resistant garments, excluding manufacturer’s labels, interlinings, and cold weather insulation materials, shall be individually tested for thermal shrinkage resistance as specified in Section 8.4, and shall not shrink more than 10 percent in any direction.

6. Delete existing subsection 7.1.3.1 as follows:

7.1.3.1 Cold weather insulation materials utilized in the construction of flame-resistant garments shall be tested in accordance with Section 8.4 and shall not shrink more than 20 percent in any direction.

7. Revise subsection 7.1.4 to read as follows:

7.1.4 Fabric, cold weather insulation materials, other textile materials, and reflective striping other than those items described in 7.1.4.1 and 7.1.4.2, used in the construction of flame-resistant garments shall be individually tested for heat resistance in their original form as specified in Section 8.4, and shall not melt and drip, separate, or ignite.

8. Add a new subsection 8.3.1.7 to read as follows:

8.3.1.7 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.3.13.

9. Revise subsections 8.3.3.1, 8.3.3.2, and 8.3.3.3 to read as follows

8.3.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3.

8.3.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after 100 cycles of dry cleaning as specified in 8.1.4.

8.3.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3, or after 100 cycles of dry cleaning as specified in 8.1.4.

10. Add new subsections to 8.3.13 to read as follows:

8.3.13 Specific Requirements for Testing Cold Weather Insulation Materials.

8.3.13.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 66-cm × 66-cm (26-in. × 26-in.) panel of the cold weather insulation material. A similar-sized piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0- oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric.

8.3.13.2 Following wash or dry-clean conditioning, 5 specimens measuring 75 mm × 300 mm (3 in. × 12 in.) from each of the warp and filling direction shall be removed from the cold weather insulation material layer of the conditioned panels.

8.3.13.3 If applicable, all specimens shall be prepared for testing by trimming the scrim material, batting, or other layer(s) away from the face cloth by 50 mm ± 3 mm (2.0 in. ± 1/8 in.) such that the face cloth can be folded back covering the scrim, batting, or other layer(s) by 50 mm ± 3 mm (2.0 in. ± 1/8 in.); the folded specimen shall be secured in the specimen holder.

8.3.13.4 Testing shall be performed as described in 8.3.2 through 8.3.7.

11. Revise subsection 8.4.1 and add new subsections 8.4.1.1 through 8.4.1.5 to read as follows:

8.4.1 Application. The heat and thermal shrinkage resistance test method shall apply to flame resistant garment fabrics, components, and hardware.

8.4.1.1 This test method shall apply to flame-resistant garment fabrics, components, hardware, and cold weather insulation materials.

8.4.1.2 Modifications to this test method for testing flame-resistant garment textile materials shall be as specified in 8.4.8.

8.4.1.3 Modifications to this test method for testing other flame-resistant garment materials, including reflective striping, shall be as specified in 8.4.9.

8.4.1.4 Modifications to this test method for testing hardware shall be as specified in 8.4.10.

8.4.1.5 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.4.11.

12. Revise subsections 8.4.2.1 and 8.4.3.1 through 8.4.3.3 to read as follows:

8.4.2.1 Only heat resistance testing shall be conducted on not fewer than three specimens for each hardware item, label material, and other flame-resistant garment fabrics, and cold weather insulation materials not listed in 8.4.2.2 and 8.4.2.3.

8.4.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3.

8.4.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after three cycles of dry-cleaning as specified in 8.1.4.

8.4.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3, after three cycles of dry-cleaning as specified in 8.1.4.

13. Delete existing subsection 8.4.8.2 and renumber 8.4.8.3 to 8.4.8.2 to read as follows:

8.4.8.2 Measurements of cold weather insulation material thermal shrinkage shall be made on the side of the fabric facing the wearer as used in the construction of the garment.

8.4.8.3 8.4.8.2 Testing shall be performed in accordance with 8.4.2 through 8.4.7.

14. Add new subsection 8.4.11 to read as follows:

8.4.11 Specific Requirements for Testing Cold Weather Insulation Materials.

8.4.11.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 50-cm × 20-cm (20-in. × 8-in.) panel of the cold weather insulation material. A similar-sized cloth piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0-oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric .

8.4.11.2 Following wash or dry-clean conditioning, 3 specimens measuring 152 mm × 152 mm (6 in. × 6 in.) shall be removed from the cold weather insulation material layer of the conditioned panel.

8.4.11.3 Testing shall be performed in accordance with 8.4.2 through 8.4.7, and thermal shrinkage shall not be measured.

Submitter’s Substantiation: The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out)

representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

 A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

 Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

 Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

 Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

 A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

 Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

 Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes

criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

Public Input No. 25-NFPA 2112-2013 [ Section No. 7.1.1 ]

7.1.1 Fabric utilized in the construction of flame-resistant garments shall be tested for heat transfer performance 2 (HTP) as specified in Section 8.2 and shall have a “spaced” HTP rating of not less than 25 J/cm (6.0 2 2 2 cal/cm ) and a “contact” HTP rating of not less than 12.6 J/cm (3.0 cal/cm ). Question: It seems that this test sets a similar performance standard to ASTM F1930, 3 seconds at 2 cal/second, manikin test. To my understanding, this measures the heatflux to second degree burn, with a minimum performance of 6 cal. The manikin test exposes the fabic (in coverall form) to 6 cal, and measures if there is burn or not. Both are evaluating burn at a 6 cal exposure. Both are expensive tests, costing as much as $3000 per fabric. Why don't we specify only one 6 cal burn test? If both tests are necessary, it would be helpful to include a note explaining the different real world phenomena requiring both tests to qualify a fabric as providing protection at a 6 cal exposure.

Statement of Problem and Substantiation for Public Input

If the HTP performance specification were removed, and the Technical Committee settled on a the manikin 6-cal burn test, tens of thousands of dollars would be saved. Every new 2112-rated fabric would only need to undergo one test to evaluate it's performance with a 6-cal exposure. This would reduce the cost and time of certification substantially, making 2112-certified garments more competitive with their non-certified FR counterparts.

Submitter Information Verification

Submitter Full Name: ROBERT WHITTENBERGER Organization: TYNDALE COMPANY, INC. Street Address: City: State: Zip: Submittal Date: Mon Dec 16 14:03:35 EST 2013

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Public Input No. 15-NFPA 2112-2013 [ Sections 7.1.2, 7.1.3 ]

Sections 7.1.2, 7.1.3 7.1.2 Fabric and , cold weather insulation material, and reflective striping utilized in the construction of flame- resistant garments shall be tested for flame resistance as specified in Section 8.3, and shall have a char length of not more than 100 mm (4 in.) and an after-flame of not more than 2 seconds, and shall not melt and drip. 7.1.3 Fabric utilized in the construction of flame-resistant garments, excluding manufacturers' labels, interlinings, and cold weather insulation materials, shall be individually tested for thermal shrinkage resistance as specified in Section 8.4, and shall not shrink more than 10 percent in any direction. 7.1.3.1 Cold weather insulation materials utilized in the construction of flame-resistant garments shall be tested in accordance with Section 8.4 and shall not shrink more than 20 percent in any direction.

Additional Proposed Changes

File Name Description Approved Proposed_TIA_1105_2112_.docx Balloted TIA

Statement of Problem and Substantiation for Public Input

Note: This Public Input originates from Tentative Interim Amendment 2112-12-2 (TIA 1105) issued by the Standards Council on August 1, 2013.

The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

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2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out) representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

• A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

• Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

• Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

• Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

• A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

• Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

• Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes criteria that create a bias against cold weather insulation materials that is inconsistent with their use and

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in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

Submitter Information Verification

Submitter Full Name: TC on FLG-AAA Organization: TC on Flash Fire Protective Garments Street Address: City: State: Zip: Submittal Date: Fri Sep 06 14:32:14 EDT 2013

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NFPA 2112®-2012 Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire TIA Log No. 1105 Reference: Various Comment Closing Date: June 14, 2013 Submitter: Jeffrey O. Stull, International Personnel Protection, Inc.

1. Revise 3.3.6, A.3.3.6, and 3.3.20, and add a new A.3.3.20 to read as follows:

3.3.6* Cold Weather Insulation Material. A fabric that consists of one or more nonseparable layers that is used for protection in a low-temperature environment. A cold weather insulation material is not an interlining (see interlining).

A.3.3.6 Cold Weather Insulation Material. Examples of insulation materials are include textile battings(s) alone or batting(s) that are attached to a face cloth. For example, an insulation material consisting of two layers are considered nonseparable by the attachment that combines the two layers. The insulation material may or may not have a face cloth. Cold weather insulation materials generally are provided within the garment such that their area of coverage coincides with the majority of garment area covering the wearer’s body. Cold weather insulation material as defined in this standard does not preclude the use of intermediate layers for additional protection against thermal hazards.

3.3.20* Interlining. Any textile that is incorporated into any garment as a layer between outer and inner layers that only covers a small portion of the overall garment. [1975, 2009]

A.3.3.20 Interlining. The outer and inner layers are compliant to the fabric requirements of this standard. Examples of an interlining are a fabric layer used to stiffen the waist band in a pair of pants or a facing fabric used inside the closure flap of a coverall. Interlining materials do not come in contact with the wearer’s skin or underclothing.

2. Revise subsections 5.1.2, 5.1.9(7), and 5.1.12, and add a new 5.1.13 to read as follows:

5.1.2 At least one product label shall be conspicuously located inside each flame-resistant garment. when the item is properly assembled with all layers and components in place.

5.1.9(7) Fiber content for each primary fabric layer including cold weather insulation materials, but excluding interlinings and labels.

5.1.12 Garments with multiple layers, including an outer layer and removable cold weather insulation layer, shall specify the certified wearable configurations on the label configuration and include a warning on the label stating that all layers must be properly secured and worn in accordance with the manufacturer’s instructions.

5.1.13 For garments with multiple layers that include an outer layer and a removable cold weather insulation layer, a label shall be conspicuously attached to the removable insulation layer that states “DO NOT WEAR THIS LINER BY ITSELF. FOR COMPLIANCE WITH THE FLASH FIRE REQUIREMENTS OF NFPA 2112, THE COMPLETE GARMENT MUST BE WORN. FOR COMPLIANCE INFORMATION, SEE THE PRODUCT LABEL ON OUTER GARMENT.”

3. Add new Section 6.4 and subsections 6.4.1, and A.6.4.1 to read as follows:

6.4 Use of a Liner for Cold Weather Insulation. Garments shall be permitted to include liners in their construction including cold weather insulation materials where the liner is either integral to the garment or removable.

6.4.1* Where garments incorporate a cold weather insulation material as part of a removable lining system, the garment shall be designed such that the removable liner consisting of the cold weather insulation material cannot be independently worn.

A.6.4.1 Removable liners are permitted to be worn separately if the liner material(s) independently meets the appropriate fabric requirements in Chapter 7 including 7.1.1 for heat transfer performance and 7.1.5 for overall flash fire performance. If the liner contains cold weather insulation materials that are not evaluated to 7.1.1 and 7.1.5 and do not pass the thermal shrinkage resistance requirement in 7.1.3, then the manufacturer must label the liner as specified in 5.1.13 and provide a design that does not allow separate wearing of the liner without the outer layer. This may be demonstrated by the absence of a means of closure for the closure area of shirts, pants, and coveralls.

4. Add new subsections 7.1.1.1 and 7.1.1.2 to read as follows:

7.1.1.1 Where the flame-resistant garment consists of multiple and separable layers intended to be worn separately, the outer layer and the inner layer or layers shall be separately tested.

7.1.1.2 Where the flame-resistant garment consists of multiple layers intended only to be worn together, only the outer layer shall be tested.

5. Revise subsections 7.1.2 and 7.1.3 to read as follows:

7.1.2 Fabric, cold weather insulation material, and reflective striping utilized in the construction of flame-resistant garments shall be tested for flame resistance as specified in Section 8.3, and shall have a char length of not more than 100 mm (4 in.) and an after-flame of not more than 2 seconds, and shall not melt and drip.

7.1.3 Fabric utilized in the construction of flame-resistant garments, excluding manufacturer’s labels, interlinings, and cold weather insulation materials, shall be individually tested for thermal shrinkage resistance as specified in Section 8.4, and shall not shrink more than 10 percent in any direction.

6. Delete existing subsection 7.1.3.1 as follows:

7.1.3.1 Cold weather insulation materials utilized in the construction of flame-resistant garments shall be tested in accordance with Section 8.4 and shall not shrink more than 20 percent in any direction.

7. Revise subsection 7.1.4 to read as follows:

7.1.4 Fabric, cold weather insulation materials, other textile materials, and reflective striping other than those items described in 7.1.4.1 and 7.1.4.2, used in the construction of flame-resistant garments shall be individually tested for heat resistance in their original form as specified in Section 8.4, and shall not melt and drip, separate, or ignite.

8. Add a new subsection 8.3.1.7 to read as follows:

8.3.1.7 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.3.13.

9. Revise subsections 8.3.3.1, 8.3.3.2, and 8.3.3.3 to read as follows

8.3.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3.

8.3.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after 100 cycles of dry cleaning as specified in 8.1.4.

8.3.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3, or after 100 cycles of dry cleaning as specified in 8.1.4.

10. Add new subsections to 8.3.13 to read as follows:

8.3.13 Specific Requirements for Testing Cold Weather Insulation Materials.

8.3.13.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 66-cm × 66-cm (26-in. × 26-in.) panel of the cold weather insulation material. A similar-sized piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0- oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric.

8.3.13.2 Following wash or dry-clean conditioning, 5 specimens measuring 75 mm × 300 mm (3 in. × 12 in.) from each of the warp and filling direction shall be removed from the cold weather insulation material layer of the conditioned panels.

8.3.13.3 If applicable, all specimens shall be prepared for testing by trimming the scrim material, batting, or other layer(s) away from the face cloth by 50 mm ± 3 mm (2.0 in. ± 1/8 in.) such that the face cloth can be folded back covering the scrim, batting, or other layer(s) by 50 mm ± 3 mm (2.0 in. ± 1/8 in.); the folded specimen shall be secured in the specimen holder.

8.3.13.4 Testing shall be performed as described in 8.3.2 through 8.3.7.

11. Revise subsection 8.4.1 and add new subsections 8.4.1.1 through 8.4.1.5 to read as follows:

8.4.1 Application. The heat and thermal shrinkage resistance test method shall apply to flame resistant garment fabrics, components, and hardware.

8.4.1.1 This test method shall apply to flame-resistant garment fabrics, components, hardware, and cold weather insulation materials.

8.4.1.2 Modifications to this test method for testing flame-resistant garment textile materials shall be as specified in 8.4.8.

8.4.1.3 Modifications to this test method for testing other flame-resistant garment materials, including reflective striping, shall be as specified in 8.4.9.

8.4.1.4 Modifications to this test method for testing hardware shall be as specified in 8.4.10.

8.4.1.5 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.4.11.

12. Revise subsections 8.4.2.1 and 8.4.3.1 through 8.4.3.3 to read as follows:

8.4.2.1 Only heat resistance testing shall be conducted on not fewer than three specimens for each hardware item, label material, and other flame-resistant garment fabrics, and cold weather insulation materials not listed in 8.4.2.2 and 8.4.2.3.

8.4.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3.

8.4.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after three cycles of dry-cleaning as specified in 8.1.4.

8.4.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3, after three cycles of dry-cleaning as specified in 8.1.4.

13. Delete existing subsection 8.4.8.2 and renumber 8.4.8.3 to 8.4.8.2 to read as follows:

8.4.8.2 Measurements of cold weather insulation material thermal shrinkage shall be made on the side of the fabric facing the wearer as used in the construction of the garment.

8.4.8.3 8.4.8.2 Testing shall be performed in accordance with 8.4.2 through 8.4.7.

14. Add new subsection 8.4.11 to read as follows:

8.4.11 Specific Requirements for Testing Cold Weather Insulation Materials.

8.4.11.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 50-cm × 20-cm (20-in. × 8-in.) panel of the cold weather insulation material. A similar-sized cloth piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0-oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric .

8.4.11.2 Following wash or dry-clean conditioning, 3 specimens measuring 152 mm × 152 mm (6 in. × 6 in.) shall be removed from the cold weather insulation material layer of the conditioned panel.

8.4.11.3 Testing shall be performed in accordance with 8.4.2 through 8.4.7, and thermal shrinkage shall not be measured.

Submitter’s Substantiation: The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out)

representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

 A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

 Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

 Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

 Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

 A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

 Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

 Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes

criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

Public Input No. 16-NFPA 2112-2013 [ Section No. 7.1.4 [Excluding any Sub-Sections] ]

Fabric, cold weather insulation materials, other textile materials, and reflective striping, other than those items described in 7.1.4.1 and 7.1.4.2, used in the construction of flame-resistant garments shall be individually tested for heat resistance in their original form as specified in Section 8.4, and shall not melt and drip, separate, or ignite.

Additional Proposed Changes

File Name Description Approved Proposed_TIA_1105_2112_.docx Balloted TIA

Statement of Problem and Substantiation for Public Input

Note: This Public Input originates from Tentative Interim Amendment 2112-12-2 (TIA 1105) issued by the Standards Council on August 1, 2013.

The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out) representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

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It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

• A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

• Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

• Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

• Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

• A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

• Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

• Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

Submitter Information Verification

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Submitter Full Name: TC on FLG-AAA Organization: TC on Flash Fire Protective Garments Street Address: City: State: Zip: Submittal Date: Fri Sep 06 14:35:20 EDT 2013

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NFPA 2112®-2012 Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire TIA Log No. 1105 Reference: Various Comment Closing Date: June 14, 2013 Submitter: Jeffrey O. Stull, International Personnel Protection, Inc.

1. Revise 3.3.6, A.3.3.6, and 3.3.20, and add a new A.3.3.20 to read as follows:

3.3.6* Cold Weather Insulation Material. A fabric that consists of one or more nonseparable layers that is used for protection in a low-temperature environment. A cold weather insulation material is not an interlining (see interlining).

A.3.3.6 Cold Weather Insulation Material. Examples of insulation materials are include textile battings(s) alone or batting(s) that are attached to a face cloth. For example, an insulation material consisting of two layers are considered nonseparable by the attachment that combines the two layers. The insulation material may or may not have a face cloth. Cold weather insulation materials generally are provided within the garment such that their area of coverage coincides with the majority of garment area covering the wearer’s body. Cold weather insulation material as defined in this standard does not preclude the use of intermediate layers for additional protection against thermal hazards.

3.3.20* Interlining. Any textile that is incorporated into any garment as a layer between outer and inner layers that only covers a small portion of the overall garment. [1975, 2009]

A.3.3.20 Interlining. The outer and inner layers are compliant to the fabric requirements of this standard. Examples of an interlining are a fabric layer used to stiffen the waist band in a pair of pants or a facing fabric used inside the closure flap of a coverall. Interlining materials do not come in contact with the wearer’s skin or underclothing.

2. Revise subsections 5.1.2, 5.1.9(7), and 5.1.12, and add a new 5.1.13 to read as follows:

5.1.2 At least one product label shall be conspicuously located inside each flame-resistant garment. when the item is properly assembled with all layers and components in place.

5.1.9(7) Fiber content for each primary fabric layer including cold weather insulation materials, but excluding interlinings and labels.

5.1.12 Garments with multiple layers, including an outer layer and removable cold weather insulation layer, shall specify the certified wearable configurations on the label configuration and include a warning on the label stating that all layers must be properly secured and worn in accordance with the manufacturer’s instructions.

5.1.13 For garments with multiple layers that include an outer layer and a removable cold weather insulation layer, a label shall be conspicuously attached to the removable insulation layer that states “DO NOT WEAR THIS LINER BY ITSELF. FOR COMPLIANCE WITH THE FLASH FIRE REQUIREMENTS OF NFPA 2112, THE COMPLETE GARMENT MUST BE WORN. FOR COMPLIANCE INFORMATION, SEE THE PRODUCT LABEL ON OUTER GARMENT.”

3. Add new Section 6.4 and subsections 6.4.1, and A.6.4.1 to read as follows:

6.4 Use of a Liner for Cold Weather Insulation. Garments shall be permitted to include liners in their construction including cold weather insulation materials where the liner is either integral to the garment or removable.

6.4.1* Where garments incorporate a cold weather insulation material as part of a removable lining system, the garment shall be designed such that the removable liner consisting of the cold weather insulation material cannot be independently worn.

A.6.4.1 Removable liners are permitted to be worn separately if the liner material(s) independently meets the appropriate fabric requirements in Chapter 7 including 7.1.1 for heat transfer performance and 7.1.5 for overall flash fire performance. If the liner contains cold weather insulation materials that are not evaluated to 7.1.1 and 7.1.5 and do not pass the thermal shrinkage resistance requirement in 7.1.3, then the manufacturer must label the liner as specified in 5.1.13 and provide a design that does not allow separate wearing of the liner without the outer layer. This may be demonstrated by the absence of a means of closure for the closure area of shirts, pants, and coveralls.

4. Add new subsections 7.1.1.1 and 7.1.1.2 to read as follows:

7.1.1.1 Where the flame-resistant garment consists of multiple and separable layers intended to be worn separately, the outer layer and the inner layer or layers shall be separately tested.

7.1.1.2 Where the flame-resistant garment consists of multiple layers intended only to be worn together, only the outer layer shall be tested.

5. Revise subsections 7.1.2 and 7.1.3 to read as follows:

7.1.2 Fabric, cold weather insulation material, and reflective striping utilized in the construction of flame-resistant garments shall be tested for flame resistance as specified in Section 8.3, and shall have a char length of not more than 100 mm (4 in.) and an after-flame of not more than 2 seconds, and shall not melt and drip.

7.1.3 Fabric utilized in the construction of flame-resistant garments, excluding manufacturer’s labels, interlinings, and cold weather insulation materials, shall be individually tested for thermal shrinkage resistance as specified in Section 8.4, and shall not shrink more than 10 percent in any direction.

6. Delete existing subsection 7.1.3.1 as follows:

7.1.3.1 Cold weather insulation materials utilized in the construction of flame-resistant garments shall be tested in accordance with Section 8.4 and shall not shrink more than 20 percent in any direction.

7. Revise subsection 7.1.4 to read as follows:

7.1.4 Fabric, cold weather insulation materials, other textile materials, and reflective striping other than those items described in 7.1.4.1 and 7.1.4.2, used in the construction of flame-resistant garments shall be individually tested for heat resistance in their original form as specified in Section 8.4, and shall not melt and drip, separate, or ignite.

8. Add a new subsection 8.3.1.7 to read as follows:

8.3.1.7 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.3.13.

9. Revise subsections 8.3.3.1, 8.3.3.2, and 8.3.3.3 to read as follows

8.3.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3.

8.3.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after 100 cycles of dry cleaning as specified in 8.1.4.

8.3.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3, or after 100 cycles of dry cleaning as specified in 8.1.4.

10. Add new subsections to 8.3.13 to read as follows:

8.3.13 Specific Requirements for Testing Cold Weather Insulation Materials.

8.3.13.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 66-cm × 66-cm (26-in. × 26-in.) panel of the cold weather insulation material. A similar-sized piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0- oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric.

8.3.13.2 Following wash or dry-clean conditioning, 5 specimens measuring 75 mm × 300 mm (3 in. × 12 in.) from each of the warp and filling direction shall be removed from the cold weather insulation material layer of the conditioned panels.

8.3.13.3 If applicable, all specimens shall be prepared for testing by trimming the scrim material, batting, or other layer(s) away from the face cloth by 50 mm ± 3 mm (2.0 in. ± 1/8 in.) such that the face cloth can be folded back covering the scrim, batting, or other layer(s) by 50 mm ± 3 mm (2.0 in. ± 1/8 in.); the folded specimen shall be secured in the specimen holder.

8.3.13.4 Testing shall be performed as described in 8.3.2 through 8.3.7.

11. Revise subsection 8.4.1 and add new subsections 8.4.1.1 through 8.4.1.5 to read as follows:

8.4.1 Application. The heat and thermal shrinkage resistance test method shall apply to flame resistant garment fabrics, components, and hardware.

8.4.1.1 This test method shall apply to flame-resistant garment fabrics, components, hardware, and cold weather insulation materials.

8.4.1.2 Modifications to this test method for testing flame-resistant garment textile materials shall be as specified in 8.4.8.

8.4.1.3 Modifications to this test method for testing other flame-resistant garment materials, including reflective striping, shall be as specified in 8.4.9.

8.4.1.4 Modifications to this test method for testing hardware shall be as specified in 8.4.10.

8.4.1.5 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.4.11.

12. Revise subsections 8.4.2.1 and 8.4.3.1 through 8.4.3.3 to read as follows:

8.4.2.1 Only heat resistance testing shall be conducted on not fewer than three specimens for each hardware item, label material, and other flame-resistant garment fabrics, and cold weather insulation materials not listed in 8.4.2.2 and 8.4.2.3.

8.4.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3.

8.4.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after three cycles of dry-cleaning as specified in 8.1.4.

8.4.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3, after three cycles of dry-cleaning as specified in 8.1.4.

13. Delete existing subsection 8.4.8.2 and renumber 8.4.8.3 to 8.4.8.2 to read as follows:

8.4.8.2 Measurements of cold weather insulation material thermal shrinkage shall be made on the side of the fabric facing the wearer as used in the construction of the garment.

8.4.8.3 8.4.8.2 Testing shall be performed in accordance with 8.4.2 through 8.4.7.

14. Add new subsection 8.4.11 to read as follows:

8.4.11 Specific Requirements for Testing Cold Weather Insulation Materials.

8.4.11.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 50-cm × 20-cm (20-in. × 8-in.) panel of the cold weather insulation material. A similar-sized cloth piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0-oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric .

8.4.11.2 Following wash or dry-clean conditioning, 3 specimens measuring 152 mm × 152 mm (6 in. × 6 in.) shall be removed from the cold weather insulation material layer of the conditioned panel.

8.4.11.3 Testing shall be performed in accordance with 8.4.2 through 8.4.7, and thermal shrinkage shall not be measured.

Submitter’s Substantiation: The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out)

representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

 A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

 Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

 Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

 Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

 A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

 Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

 Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes

criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

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Public Input No. 30-NFPA 2112-2014 [ Section No. 7.1.4.1 ]

7.1.4.1 Labels and emblems shall not be required to be tested for heat resistance. . Emblems or labels affixed to 2 2 the exterior of garments should not be larger than 45 cm (7 inch ) unless the emblem is manufactured from flame resistant materials.

Statement of Problem and Substantiation for Public Input

Problem to be resolved While flammable small emblems are unlikely to have significant impact on the performance of an FR garment in terms of body burn, the possibility of burning emblems may still present a safety risk. It is not uncommon for larger emblems to be placed on the back of a garment. Ignition of a larger emblem on the back of a garment where it is not readily visible to the wearer could present a significant risk.

Substantiation Garment manufacturers, rental companies, and end users would benefit from additional guidance as to size of exterior emblems. At least one major manufacturer of FR garments has suggested limiting emblems to the size of a business card. The exact size limitation is not as important as the introduction of language to establish some upper limit in size. Larger emblems could still be employed if manufactured with flame resistant materials. This flame resistance could be demonstrated by ASTM D6413 afterflame time limited to 2 seconds.

Submitter Information Verification

Submitter Full Name: CRAIG TUTTEROW Organization: Mount Vernon Mills, Inc. Street Address: City: State: Zip: Submittal Date: Fri Jun 27 10:46:26 EDT 2014

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Public Input No. 3-NFPA 2112-2013 [ Section No. 7.1.5 ]

NOTE: This proposal appeared as Comment 2112-27 (Log #18) which was held from the A11 ROC on Proposal 2112-21. 7.1.5 Specimen garments shall be tested for overall flash fire exposure as specified in Section 8.5 as a qualification test for the material and shall have an average predicted body burn rating of not more than 50 percent based on the total surface area covered by sensors, excluding hands and feet 40 . 7.1.5.1 Garments consisting of separable layers, such as a removable cold weather insulation material layer, that are intended to be worn together or separately shall be tested in all wearable configurations identified by the manufacturer.

Additional Proposed Changes

File Name Description Approved Open 2112_PI3_Table_to_Held_Comment_2112-27_Stull_.docx Table from Held Comment 2112-27

Statement of Problem and Substantiation for Public Input

The table below represents the survivability for an average individual given the range of burn injury (combined 2nd and 3rd degree burn).1 The rate of survival changes with the age of the individual. For the purpose of this standard, the ages ranges of 5-34, 35-49, and 50-59 are relevant since these age ranges would encompass the ages for the majority of workers. At the current criteria of permitting up to 50% body burn, survivability for each of the respective age ranges is 80%, 60% and 40%. I submit that these levels are unacceptable for workers who should have the expectation for a better than average chance of survival when accidentally exposed to flash fire. The recommendation for a total body burn of not more than 40% would yield survivability rates of 90%, 80%, and 70%, respectively. These rates would provide a greater level of safety for workers without significantly decreasing the range of available clothing material choices.

****Insert Table 2112 Here****

Submitter Information Verification

Submitter Full Name: Grace Stull Organization: International Personnel Protection, Inc. Street Address: City: State: Zip: Submittal Date: Fri May 24 10:42:36 EDT 2013

73 of 142 7/10/2014 8:54 AM Burn Size 0-1 2-4 5-34 35-49 50-59 60-74 >75 (%) of total skin 0-10 >95 >95 >95 >95 >95 >95 90 10-20 >95 >90 >95 >90 >90 >70 >60 20-30 >90 >90 >90 >90 >75 50 35 30-40 75 80 90 80 70 40 <20 40-50 50 65 80 60 40 10 <10 50-60 50 60 70 60 40 <25 <10 60-70 40 50 60 40 25 <10 0 70-80 35 40 45 30 25 0 0 80-90 30 35 30 30 <20 0 0 90-100 20 20 20 15 0 0 0 * The body surface burn, combined second and third degree

1 NFPA 2112 Log #18 Sub A2011 ROC

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Public Input No. 42-NFPA 2112-2014 [ Section No. 7.1.5 [Excluding any Sub-Sections] ]

Specimen garments shall be tested for overall flash engulfment fire exposure as specified in Section 8.5 as a qualification test for the material and shall have an average predicted body burn of not more than 50 percent based on the total surface area covered by sensors, excluding hands and feet.

Statement of Problem and Substantiation for Public Input

The referenced ASTM standard (F 1930) for this performance specification is not a flash fire test. It is a standardized diffusion fire (excess fuel) test utilizing multiple burners producing an engulfing jet fire from propane.

Submitter Information Verification

Submitter Full Name: Roger Parry Organization: The DuPont Company, Inc. Street Address: City: State: Zip: Submittal Date: Tue Jul 01 15:55:03 EDT 2014

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Public Input No. 2-NFPA 2112-2013 [ Section No. 7.1.5.1 ]

7.1.5.1

Garments consisting of separable layers, such as a removable cold weather insulation material layer, that are intended to be worn together or separately shall be tested in all wearable configurations identified by the manufacturer Where the flame-resistant garment consists of multiple and separable layers intended to be worn separately, both of the following shall apply:

(a) Specimen garments consisting of the outer layer only shall be tested. (b) Specimen garments consisting of the inner layer or layers only shall be tested. 7.1.5.2 Where the flame-resistant garment consists of multiple layers intended only to be worn together, specimen garments consisting of the outer layer only shall be tested .

Statement of Problem and Substantiation for Public Input

Note: This Proposal originates from Tentative Interim Amendment 1124-12-1 (TIA 1093) issued by the Standards Council on March 7, 2013.

The current language does not provide requirements for all perceived wearable configurations of garments that consist of multiple layers. This leaves room for interpretation of testing requirements where a garment's finished application was not identified by the standard. The new wording adds this necessary clarification.

Where garments do have removable lining materials, but those lining materials are never intended to be worn without the outer protective layer, the current standard requires redundant testing with little to no benefit of the user. NFPA 2112 has identified TPP, Heat and Thermal Shrinkage and Flame Resistance requirements for fabric materials to identify the minimum testing that would demonstrate a contribution to burn injuries in a flash fire exposure. If the outer layer has been tested and complies with the full scale, manikin test, and the inner layer has been tested and complies with all the fabric tests that have been chosen to identify materials that would contribute to burn injuries, then adding those two layers together should not negatively impact the performance of that composite on the manikin test. By requiring this redundant testing, manufacturers have chosen to not certify these products and therefore they are encouraging users to wear non-certified configurations of these garments.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised document has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process. Products consisting of multiple and separable layers are not being submitted for certification because there is confusion regarding the application of this section which mandates redundant evaluation of each layer of material. This leads to the wearing of non-compliant garments by the users and lessens the influence and credibility of NFPA 2112 in the field.

Submitter Information Verification

Submitter Full Name: TC on FLG-AAA Organization: TC on Flash Fire Protective Garments Street Address: City: State: Zip: Submittal Date: Tue Apr 30 10:15:42 EDT 2013

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Public Input No. 60-NFPA 2112-2014 [ Section No. 7.2 ]

7.2 Thread Requirements. Specimens of all sewing thread utilized in the construction of flame-resistant garments, excluding embroidery, shall be made of an inherently flame-resistant fiber, shall be tested for heat resistance as specified in Section 8.6, and shall not melt. Submitter proposes the following action related to Sections 7.2 and Section 8.6: Sewing thread used in the construction of flame resistant garments shall be made of inherently flame resistant aramid staple sewing threads that comply to Commercial Item Description (CID) A-A-55217, either classification Type I, Normal Performance or Type II, High Performance.

Statement of Problem and Substantiation for Public Input

1. As discussed earlier in section 2.3.3, the CID's were developed as performance based standards that measured sewing thread performance in several other areas other than only melting. The CID uses ASTM Test Method 204 to measure yarn size, break strength, and yardage. A review of the CID shows that both classifications Type I and Type II have a range of several tex sizes, and break strengths, both of which contribute to the strength of major seams and minor seams. 2. When a garment has a structural integrity performance requirement that includes a major seam of 70 lbf (325N) and a minor seam of 50 lbf(225N), the performance measurements of the sewing thread needs to include more than just the current requirement for data from the D7138 melting test. 3. While the compliance of the current requirements in Sections 7.2 and 8.6 are easily resolved by the purchase of fiber, the other changes proposed in the submitter's public inputs will require revisions to Section 8.6.

Submitter Information Verification

Submitter Full Name: Vincent Diaz Organization: Atlantic Thread & Supply Compa Street Address: City: State: Zip: Submittal Date: Fri Jul 04 12:18:16 EDT 2014

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Public Input No. 62-NFPA 2112-2014 [ New Section after 7.4 ]

7.4.1 When labels are heat sealed to the garment, in addition to remaining legible, they will be required to remain adhesed to the garment following the pre-conditioning described in Section 8.7.

Statement of Problem and Substantiation for Public Input

Labels are either sewn on or heat sealed to a garment. If a label becomes detached from the garment during the laundering pre-conditioning process, the fact that it remains legible is of little meaning.

Submitter Information Verification

Submitter Full Name: DENISE STATHAM Organization: BULWARK PROTECTIVE APPAREL Street Address: City: State: Zip: Submittal Date: Sun Jul 06 23:55:37 EDT 2014

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Public Input No. 73-NFPA 2112-2014 [ Chapter 8 ]

Chapter 8 Test Methods 8.1 Sample Preparation Procedures. 8.1.1 Application. 8.1.1.1 The sample preparation procedures contained in Section 8.1 shall apply to each test method in Chapter 8, as specifically referenced in the sample preparation section of each test method. 8.1.1.2 Only the specific sample preparation procedure or procedures referenced in the sample preparation section of each test method shall be applied to that test method. 8.1.2 Room Temperature Conditioning Procedure. 8.1.2.1 Specimens shall be conditioned at a temperature of 21°C ± 3°C (70°F ± 5°F) and a relative humidity of 65 percent ± 5 percent for at least 4 hours. 8.1.2.2 Specimens shall be tested within 5 minutes of removal from conditioning.

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8.1.3* Washing and Drying Procedure.

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Where required, specimens shall be subjected to the specified number of cycles of washing and drying in accordance with the following procedure:

(1) Each washing procedure shall be as specified in Table 8.1.3. (2)* When testing in accordance with 8.3.3.1, the final two cycles shall be run without adding any detergent or chemicals. (3) No bleach or softener shall be used during any portion of the laundry cycle. (4) The machine shall be filled with water to the specified level prior to adding chemicals. (5) The water level shall be determined by measuring inside the washing machine from the bottommost portion of the basket to the water surface. (6) The water level measurement shall be 12.7 cm (5.0 in.) for the low setting and 25.4 cm (10 in.) for the high setting. (7) Water hardness shall not exceed 25 ppm. (8) The extraction cycle shall continue as specified in Table 8.1.3 or until water is no longer flowing to the drain. (9) The load shall be removed immediately after the extraction cycle concludes. (10) A full load of 9 kg (20 lb) shall be laundered. (11) 2 2 Fabric samples for washing shall be at least 1 m (1 yd ) of each material. (12) A dummy load, if needed to make a full load, shall be of similar material as the test material. (13) The machine type shall be a front-loading, 16 kg (35 lb) capacity, industrial washer capable of performing the operations specified in Table 8.1.3. (14) Sample specimens shall be tumble dried. (15) The dryer temperature shall be preset to provide a dryer exhaust temperature of 68°C ± 3°C (155°F ± 5°F) without a load. (16) Wash water temperature shall be within ±3°C (±5°F) of the value in Table 8.1.3.

Table 8.1.3 Washing Cycle Procedure

Temperature Quantity per Wash Load Time Water Operations (min) °C °F Level g oz Break 10 66 150 Low Sodium metasilicate (or equivalent) 17 0.6 Sodium tripolyphosphate 11 0.4 Tergitol 15.S.9 or equivalent 22 0.8 Drain 1 Carryover* 5 66 150 Low Drain 1 Rinse 2 57 135 High Drain 1 Rinse 2 48 118 High Drain 1 Rinse 2 38 100 High Drain 1 Sour 5 38 100 Low Sodium silicofluoride 6 0.2 Drain 1 Extract 5

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* Carryover shall be accomplished with agitation. 8.1.4 Dry Cleaning Procedure. 8.1.4.1 Where required, specimens shall be subjected to the required number of cycles of dry cleaning in accordance with the procedures of Sections 9.2 and 9.3 of AATCC 158, Dimensional Changes on Dry-Cleaning in Perchloroethylene: Machine Method. 8.1.4.2 2 2 Fabric samples for dry cleaning shall be at least 1 m (1 yd ) of each material. 8.2 Heat Transfer Performance (HTP) Test.

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8.2.1 Application. This test method shall apply to flame-resistant garment fabrics, balaclava/hood fabrics, and glove materials or composites . 8.2.2 Specimens. 8.2.2.1 1 HTP testing shall be conducted on six specimens measuring 150 mm ± 5 mm × 150 mm ± 5 mm (6 in. ± ⁄4 1 in. × 6 in. ± ⁄4 in.) and shall consist of all layers representative of the garment to be tested. Three specimens shall be tested in the spaced configuration and three specimens shall be tested in the contact configuration. 8.2.2.2 Specimens shall consist of all layers used in the construction of the flame-resistant garment, excluding any areas with special reinforcements. 8.2.2.3 Specimens shall not include seams. 8.2.2.4 Specimens shall not be stitched to hold individual layers together. 8.2.3 Sample Preparation. 8.2.3.1 For fabrics that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3. 8.2.3.2 For fabrics that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after three cycles of dry cleaning as specified in 8.1.4. 8.2.3.3 For fabrics that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3, or after three cycles of dry cleaning as specified in 8.1.4. 8.2.4 Apparatus. The test apparatus shall be that specified in ASTM F 2700, Standard Test Method for Unsteady-State Heat Transfer Evaluation of Flame Resistant Materials for Clothing with Continuous Heating. 8.2.5 Procedure. 8.2.5.1 Heat transfer performance testing shall be performed in accordance with ASTM F 2700, Standard Test Method for Unsteady State Heat Transfer Evaluation of Flame Resistant Materials for Clothing with Continuous Heating. 8.2.5.2 Single layer specimen heat transfer performance testing shall use the Relaxed Single Layer configuration in ASTM F 2700 for testing in spaced and contact orientation. 8.2.5.3 Multilayer specimen HTP testing shall use the Multiple Layer Samples configuration in ASTM F 2700 for testing in spaced and contact orientation. 8.2.6 Report. 8.2.6.1 The individual test HTP rating of each specimen shall be reported separately for both “spaced” and “contact” tests. 8.2.6.2 The individual average HTP ratings for both “spaced” and “contact” tests shall also be reported. 8.2.6.3 If an HTP rating is greater than 60, then the HTP rating shall be reported as “>60.” 8.2.7 Interpretation. 8.2.7.1 Pass or fail determinations shall be separately based on the individual average HTP ratings for both “spaced” and “contact” tests.

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8.2.7.2 If an individual result from any test set varies more than ±10 percent from the average result, the results from the test set shall be discarded and another set of specimens shall be tested. 8.3 Flame Resistance Test. 8.3.1 Application. 8.3.1.1 This test method shall apply to each flame-resistant garment or balaclava/hood fabric layer. 8.3.1.2 Modifications to this test method for testing woven textile materials shall be as specified in 8.3.8. 8.3.1.3 Modifications to this test method for testing knit textile materials shall be as specified in 8.3.9. 8.3.1.4 Modifications to this test method for testing nonwoven textile materials shall be as specified in 8.3.10. 8.3.1.5 Modifications to this test method for testing small specimens not meeting the specimen size requirements of 8.3.2 shall be as specified in 8.3.11. 8.3.1.6 Modifications to this test method for testing reflective striping shall be as specified in 8.3.12. 8.3. 1.7 Modifications to this test method for testing balaclava/hood fabrics shall be as specified in 8.3.13. 8.3. 2 Specimens. 8.3.2.1 Each specimen shall consist of a 76 mm × 305 mm (3 in. × 12 in.) rectangle with the long dimension parallel to either the warp or filling, the wale or course, or machine or cross-machine direction of the material. 8.3.2.2 Each individual layer of multilayer material systems or composites shall be separately tested. 8.3.3 Sample Preparation. 8.3.3.1 For fabrics that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3. 8.3.3.2 For fabrics that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after 100 cycles of dry cleaning as specified in 8.1.4. 8.3.3.3 For fabrics that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3, or after 100 cycles of dry cleaning as specified in 8.1.4. 8.3.4 Apparatus. The test apparatus shall be that specified in ASTM D 6413, Standard Test Method for Flame Resistance of Textiles (Vertical Test). 8.3.5 Procedure. 8.3.5.1 Flame resistance testing shall be performed in accordance with ASTM D 6413, Standard Test Method for Flame Resistance of Textiles (Vertical Test). 8.3.5.2 Each specimen shall be examined for evidence of melting and dripping. 8.3.6 Report. 8.3.6.1 After-flame time and char length shall be reported for each specimen. 8.3.6.2 The average after-flame time and char length for each material shall be calculated and reported.

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8.3.6.3 The after-flame time shall be reported to the nearest 0.2 second, and the char length to the nearest 3.2 mm 1 ( ⁄8 in.). 8.3.6.4 Observations of melting and dripping for each specimen shall be reported. 8.3.7 Interpretation. 8.3.7.1 Pass/fail performance shall be based on any observed melting and dripping, the average after-flame time, and average char length. 8.3.7.2 Failure in either direction shall constitute failure of the material. 8.3.8 Specific Requirements for Testing Woven Textile Materials. 8.3.8.1 Five specimens from each of the warp and filling directions shall be tested. 8.3.8.2 No two warp specimens shall contain the same warp yarns, and no two filling specimens shall contain the same filling yarns. 8.3.8.3 Testing shall be performed as described in 8.3.2 through 8.3.7. 8.3.9 Specific Requirements for Testing Knit Textile Materials. 8.3.9.1 Five specimens from each of the two directions shall be tested. 8.3.9.2 Samples for conditioning shall include material that is a minimum of 76 mm × 305 mm (3 in. × 12 in.). 8.3.9.3 Testing shall be performed as described in 8.3.2 through 8.3.7. 8.3.10 Specific Requirements for Testing Nonwoven Textile Materials. 8.3.10.1 Five specimens from each of the machine and cross-machine directions shall be tested. 8.3.10.2 Testing shall be performed as described in 8.3.2 through 8.3.7. 8.3.11 Specific Requirements for Testing Small Materials. 8.3.11.1 Five specimens attached to the textile layer as used in the protective garment shall be tested. 8.3.11.2 The specimens shall be attached to the textile layer such that the bottom (exposure) edge of the item coincides with the bottom (exposure) edge of the textile support layer. 8.3.11.3 Testing shall be performed as described in 8.3.2 through 8.3.7, except char length shall not be measured. 8.3.12 Specific Requirements for Testing Reflective Striping. 8.3.12.1 Five reflective striping specimens for flammability testing shall be prepared by attaching the reflective striping to 76 mm × 305 mm (3 in. × 12 in.) pieces of fabric utilized in the construction of the garment, in the manner that it is normally attached to the fabric. 8.3.12.2 The reflective striping shall be oriented parallel to the long axis and in the center of the fabric. 8.3.12.3 Testing shall be performed as described in 8.3.2 through 8.3.7, except char length shall not be measured. 8. 3.13 Specific Requirements for Testing Balaclava/Hood Fabrics. 8.3.13.1 [to be developed] 8. 4 Heat and Thermal Shrinkage Resistance Test.

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8.4.1 Application. The heat and thermal shrinkage resistance test method shall apply to flame-resistant garment fabrics, components, and hardware. 8.4.2 Specimens. 8.4.2.1 Only heat resistance testing shall be conducted on not fewer than three specimens for each hardware item, label material, and other flame-resistant garment fabrics not listed in 8.4.2.2 and 8.4.2.3. 8.4.2.2 Both heat and thermal shrinkage resistance testing shall be conducted on a minimum of three specimens for each flame-resistant garment fabric. 8.4.2.3 Each separable layer of multilayer material systems or composites shall be tested as an individual layer. 8.4.3 Sample Preparation. 8.4.3.1 For fabrics that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3. 8.4.3.2 For fabrics that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after three cycles of dry cleaning as specified in 8.1.4. 8.4.3.3 For fabrics that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3, or after three cycles of dry cleaning as specified in 8.1.4. 8.4.4 Apparatus. 8.4.4.1 The test oven shall be a horizontal flow circulating oven with minimum interior dimensions to permit the specimens to be suspended and be not less than 51 mm (2 in.) from any interior oven surface or other test specimens. 8.4.4.2 The test oven shall have an airflow rate of 38 m/min to 76 m/min (125 ft/min to 250 ft/min) at the standard temperature and pressure of 21°C (70°F) at 1 atm, measured at the center point of the oven. 8.4.4.3 A test thermocouple shall be positioned so that it is level with the horizontal centerline of a mounted sample specimen. 8.4.4.3.1 The thermocouple shall be equidistant between the vertical centerline of a mounted specimen placed in the middle of the oven and the oven wall where the airflow enters the test chamber. 8.4.4.3.2 The thermocouple shall be an exposed bead, Type J or Type K, No. 30 AWG thermocouple. 8.4.4.3.3 The test oven shall be heated and the test thermocouple stabilized at 260°C + 6/-0°C (500°F + 10/-0°F) for a period of not less than 30 minutes. 8.4.5 Procedure. 8.4.5.1 Specimen marking and measurements shall be in accordance with the procedure specified in AATCC 135, Dimensional Changes of Fabrics after Home Laundering. 8.4.5.2 The specimen shall be suspended by metal hooks at the top and centered in the oven so that the entire specimen is not less than 51 mm (2 in.) from any oven surface or other specimen and airflow is parallel to the plane of the material. 8.4.5.3 The oven door shall not remain open more than 15 seconds. 8.4.5.3.1 The air circulation shall be shut off while the door is open and turned on when the door is closed.

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8.4.5.3.2 The total oven recovery time after the door is closed shall not exceed 30 seconds. 8.4.5.4 The specimen, mounted as specified, shall be exposed in the test oven for 5 minutes + 0.15/-0 minutes. 8.4.5.5 The test exposure time shall begin when the test thermocouple recovers to a temperature of 260°C + 6/-0°C (500°F + 10/-0°F). 8.4.5.6 Immediately after the exposure specified in 8.4.5.4, the specimen shall be removed and examined for evidence of ignition, melting and dripping, or separation. 8.4.5.7 Determination of “pass” or “fail” shall be made within 5 minutes of removal from the oven. 8.4.5.8 Knit fabric shall be pulled to original dimensions and shall be allowed to relax for 1 minute prior to measurement to determine “pass” or “fail.” 8.4.6 Report. 8.4.6.1 Observations of ignition, melting and dripping, or separation shall be reported for each specimen. 8.4.6.2 The percent change in the width and length dimensions of each specimen shall be calculated, and the results shall be reported as the average of all three specimens in each dimension. 8.4.7 Interpretation. 8.4.7.1 Any evidence of ignition, melting and dripping, or separation on any specimen shall constitute failing performance. 8.4.7.2 The average percent change in both dimensions shall be used to determine pass/fail performance. 8.4.7.3 Failure in any one dimension shall constitute failure for the entire sample. 8.4.8 Specific Requirements for Testing Flame-Resistant Garment Textile Materials. 8.4.8.1 Each specimen shall be 381 mm ± 13 mm × 381 mm ± 13 mm (15 in. ± 0.5 in. × 15 in. ± 0.5 in.) and shall be cut from the fabric to be utilized in the construction of the clothing item. 8.4.8.2 Measurements of cold weather insulation material thermal shrinkage shall be made on the side of the fabric facing the wearer as used in the construction of the garment. 8.4.8.3 Testing shall be performed in accordance with 8.4.2 through 8.4.7. 8.4.9 Specific Requirements for Testing Other Flame-Resistant Garment Materials (Including Reflective Striping). 8.4.9.1 Specimen length shall be 152 mm (6 in.), except for textiles utilized in the clothing item in lengths less than 152 mm (6 in.), where lengths shall be the same as utilized in the clothing item. 8.4.9.2 Specimen width shall be 152 mm (6 in.), except for textiles or reflective striping utilized in the clothing item in widths less than 152 mm (6 in.), where widths shall be the same as utilized in the clothing item. 8.4.9.3 2 2 2 Samples for conditioning shall include material sewn onto a 0.84 m (1 yd ), of navy 200 g/m (6.0 2 oz/yd ), 100 percent aramid material no closer than 51 mm (2 in.) apart in parallel strips. 8.4.9.3.1 Specimens, except reflective striping, shall be removed from the ballast material prior to testing. 8.4.9.3.2 Specimens shall be placed in the oven with the long dimension of the specimen parallel to the oven sides.

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8.4.9.3.3 Reflective striping specimens shall be placed in the oven with the striping parallel to the oven sides. 8.4.9.4 Testing shall be performed in accordance with 8.4.2 through 8.4.7, and thermal shrinkage shall not be measured. 8.4.10 Specific Requirements for Testing Hardware. 8.4.10.1 A minimum of three complete hardware items shall be tested. 8.4.10.2 Hardware shall not be conditioned. 8.4.10.3 Observations of hardware condition following heat exposure shall be limited to ignition. 8.4.10.4 Hardware shall be evaluated for functionality within 10 minutes following removal from the oven. 8.4.10.5 Testing shall be performed in accordance with 8.4.2 through 8.4.7, and thermal shrinkage shall not be measured. 8.5 Manikin Test. 8.5.1 Application. The manikin test shall apply to flame-resistant garment fabrics. 8.5.2 Specimens. 8.5.2.1 Three specimens shall be tested. 8.5.2.2 Fabrics to be tested shall be used to construct the standard garment design specified in 8.3.2 of ASTM F 1930, Standard Test Method for Evaluation of Flame Resistant Clothing for Protection Against Flash Fire Simulations Using an Instrumented Manikin. 8.5.3 Sample Preparation. 8.5.3.1 For garments that are designated on the flame-resistant garment label to be washed, specimens shall be tested after one cycle of washing and drying as specified in 8.1.3. 8.5.3.2 For garments that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested after one cycle of dry cleaning as specified in 8.1.4. 8.5.3.3 For garments that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested after one cycle of washing and drying as specified in 8.1.3, or after one cycle of dry cleaning as specified in 8.1.4. 8.5.3.4 Samples for conditioning shall be full garments. 8.5.4 Procedure. 8.5.4.1 Specimens shall be tested in accordance with ASTM F 1930, Standard Test Method for Evaluation of Flame Resistant Clothing for Protection Against Flash Fire Simulations Using an Instrumented Manikin, 2 2 using an exposure heat flux of 84 kW/m (2.02 cal/cm ·sec) with an exposure time of 3 seconds. 8.5.4.2 2 2 The manikin shall be dressed in 170 g/m (5.0 oz/yd ) (± 5 percent), jersey knit, 100 percent cotton 2 2 underwear briefs and 140 g/m (4.2 oz/yd ) (±5 percent) jersey knit, 100 percent cotton short-sleeve crew-neck T-shirts before the garment specimen is placed on the manikin. 8.5.5 Report. 8.5.5.1 The predicted percent body burn based on the total surface area covered by sensors, excluding hands and feet, for each specimen shall be reported.

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8.5.5.2 The average predicted body burn of all specimens shall be calculated and reported. 8.5.6 Interpretation. The average predicted body burn shall be used to determine pass/fail performance for garment fabrics. 8.6 Thread Heat Resistance Test. 8.6.1 Application. The thread heat resistance test method shall apply to each type of thread used in the construction of the flame-resistant garment, balaclava/hood, gloves, or footwear, other than embroidery. 8.6.2 Specimens. A total of three different determinations shall be made. 8.6.3 Sample Preparation. 8.6.3.1 Specimens shall be tested after conditioning as specified in 8.1.2. 8.6.3.2 Samples for conditioning shall be at least 10 cm (4 in.) long. 8.6.4 Procedure. Specimens shall be tested to a temperature of 260°C (500°F) in accordance with Method 1534, Melting Point of Synthetic Fibers, of Federal Test Method Standard 191A, Textile Test Methods. 8.6.5 Report. The pass/fail results for each specimen tested shall be reported. 8.6.6 Interpretation. One or more thread specimens failing this test shall constitute failing performance for the thread type. 8.7 Label Print Durability Test. 8.7.1 Application. This test method shall apply to flame-resistant garment product labels. 8.7.2 Specimens. A total of three different specimen labels shall be evaluated. 8.7.3 Sample Preparation. 8.7.3.1 For fabrics that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3. 8.7.3.2 For fabrics that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after 100 cycles of dry cleaning as specified in 8.1.4. 8.7.3.3 For fabrics that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3, or after 100 cycles of dry cleaning as specified in 8.1.4. 8.7.3.4 Samples for conditioning by laundering or dry cleaning shall include labels sewn onto a square sample of 2 2 fabric measuring 0.84 m (1 yd ), meeting the requirements of Section 7.1. The labels shall be no closer than 51 mm (2 in.) apart in parallel strips. 8.7.4 Procedure. Specimens shall be examined at a distance of 30.5 cm (12 in.) by the unaided eye with 20/20 vision, or vision corrected to 20/20, for legibility to determine pass/fail. 8.7.5 Report. The pass/fail results for each specimen tested shall be reported.

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8.7.6 Interpretation. One or more label specimens failing this test shall constitute failing performance. 8.8 [Add new test for glove flame resistance, Section 8.20 from NFPA 1977-2011]. 8.9 [Add new test for footwear flame resistance, Section 8.14 from NFPA 1977-2011]. 8.10 [Add new test for balaclava/hood heat resistance, based on modified Section 8.4 from NFPA 1977-2011]. 8.11 [Add new test for glove heat resistance, based on modified Section 8.4 from NFPA 1977-2011]. 8.12 [Add new test for footwear heat resistance, based on modified Section 8.4 from NFPA 1977-2011].

Statement of Problem and Substantiation for Public Input

The proposed test method changes and new tests are intended to address performance requirements that address recommended new clothing elements to be added to the scope of NFPA 2112.

Submitter Information Verification

Submitter Full Name: Jeffrey Stull Organization: International Personnel Protection, Inc. Street Address: City: State: Zip: Submittal Date: Mon Jul 07 16:44:44 EDT 2014

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Public Input No. 17-NFPA 2112-2013 [ New Section after 8.3.1.6 ]

8.3.1.7 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.3.1.3.

Additional Proposed Changes

File Name Description Approved Proposed_TIA_1105_2112_.docx Balloted TIA

Statement of Problem and Substantiation for Public Input

Note: This Public Input originates from Tentative Interim Amendment 2112-12-2 (TIA 1105) issued by the Standards Council on August 1, 2013.

The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out) representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as

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a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

• A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

• Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

• Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

• Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

• A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

• Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

• Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

Submitter Information Verification

Submitter Full Name: TC on FLG-AAA Organization: TC on Flash Fire Protective Garments

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Street Address: City: State: Zip: Submittal Date: Fri Sep 06 14:37:38 EDT 2013

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NFPA 2112®-2012 Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire TIA Log No. 1105 Reference: Various Comment Closing Date: June 14, 2013 Submitter: Jeffrey O. Stull, International Personnel Protection, Inc.

1. Revise 3.3.6, A.3.3.6, and 3.3.20, and add a new A.3.3.20 to read as follows:

3.3.6* Cold Weather Insulation Material. A fabric that consists of one or more nonseparable layers that is used for protection in a low-temperature environment. A cold weather insulation material is not an interlining (see interlining).

A.3.3.6 Cold Weather Insulation Material. Examples of insulation materials are include textile battings(s) alone or batting(s) that are attached to a face cloth. For example, an insulation material consisting of two layers are considered nonseparable by the attachment that combines the two layers. The insulation material may or may not have a face cloth. Cold weather insulation materials generally are provided within the garment such that their area of coverage coincides with the majority of garment area covering the wearer’s body. Cold weather insulation material as defined in this standard does not preclude the use of intermediate layers for additional protection against thermal hazards.

3.3.20* Interlining. Any textile that is incorporated into any garment as a layer between outer and inner layers that only covers a small portion of the overall garment. [1975, 2009]

A.3.3.20 Interlining. The outer and inner layers are compliant to the fabric requirements of this standard. Examples of an interlining are a fabric layer used to stiffen the waist band in a pair of pants or a facing fabric used inside the closure flap of a coverall. Interlining materials do not come in contact with the wearer’s skin or underclothing.

2. Revise subsections 5.1.2, 5.1.9(7), and 5.1.12, and add a new 5.1.13 to read as follows:

5.1.2 At least one product label shall be conspicuously located inside each flame-resistant garment. when the item is properly assembled with all layers and components in place.

5.1.9(7) Fiber content for each primary fabric layer including cold weather insulation materials, but excluding interlinings and labels.

5.1.12 Garments with multiple layers, including an outer layer and removable cold weather insulation layer, shall specify the certified wearable configurations on the label configuration and include a warning on the label stating that all layers must be properly secured and worn in accordance with the manufacturer’s instructions.

5.1.13 For garments with multiple layers that include an outer layer and a removable cold weather insulation layer, a label shall be conspicuously attached to the removable insulation layer that states “DO NOT WEAR THIS LINER BY ITSELF. FOR COMPLIANCE WITH THE FLASH FIRE REQUIREMENTS OF NFPA 2112, THE COMPLETE GARMENT MUST BE WORN. FOR COMPLIANCE INFORMATION, SEE THE PRODUCT LABEL ON OUTER GARMENT.”

3. Add new Section 6.4 and subsections 6.4.1, and A.6.4.1 to read as follows:

6.4 Use of a Liner for Cold Weather Insulation. Garments shall be permitted to include liners in their construction including cold weather insulation materials where the liner is either integral to the garment or removable.

6.4.1* Where garments incorporate a cold weather insulation material as part of a removable lining system, the garment shall be designed such that the removable liner consisting of the cold weather insulation material cannot be independently worn.

A.6.4.1 Removable liners are permitted to be worn separately if the liner material(s) independently meets the appropriate fabric requirements in Chapter 7 including 7.1.1 for heat transfer performance and 7.1.5 for overall flash fire performance. If the liner contains cold weather insulation materials that are not evaluated to 7.1.1 and 7.1.5 and do not pass the thermal shrinkage resistance requirement in 7.1.3, then the manufacturer must label the liner as specified in 5.1.13 and provide a design that does not allow separate wearing of the liner without the outer layer. This may be demonstrated by the absence of a means of closure for the closure area of shirts, pants, and coveralls.

4. Add new subsections 7.1.1.1 and 7.1.1.2 to read as follows:

7.1.1.1 Where the flame-resistant garment consists of multiple and separable layers intended to be worn separately, the outer layer and the inner layer or layers shall be separately tested.

7.1.1.2 Where the flame-resistant garment consists of multiple layers intended only to be worn together, only the outer layer shall be tested.

5. Revise subsections 7.1.2 and 7.1.3 to read as follows:

7.1.2 Fabric, cold weather insulation material, and reflective striping utilized in the construction of flame-resistant garments shall be tested for flame resistance as specified in Section 8.3, and shall have a char length of not more than 100 mm (4 in.) and an after-flame of not more than 2 seconds, and shall not melt and drip.

7.1.3 Fabric utilized in the construction of flame-resistant garments, excluding manufacturer’s labels, interlinings, and cold weather insulation materials, shall be individually tested for thermal shrinkage resistance as specified in Section 8.4, and shall not shrink more than 10 percent in any direction.

6. Delete existing subsection 7.1.3.1 as follows:

7.1.3.1 Cold weather insulation materials utilized in the construction of flame-resistant garments shall be tested in accordance with Section 8.4 and shall not shrink more than 20 percent in any direction.

7. Revise subsection 7.1.4 to read as follows:

7.1.4 Fabric, cold weather insulation materials, other textile materials, and reflective striping other than those items described in 7.1.4.1 and 7.1.4.2, used in the construction of flame-resistant garments shall be individually tested for heat resistance in their original form as specified in Section 8.4, and shall not melt and drip, separate, or ignite.

8. Add a new subsection 8.3.1.7 to read as follows:

8.3.1.7 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.3.13.

9. Revise subsections 8.3.3.1, 8.3.3.2, and 8.3.3.3 to read as follows

8.3.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3.

8.3.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after 100 cycles of dry cleaning as specified in 8.1.4.

8.3.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3, or after 100 cycles of dry cleaning as specified in 8.1.4.

10. Add new subsections to 8.3.13 to read as follows:

8.3.13 Specific Requirements for Testing Cold Weather Insulation Materials.

8.3.13.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 66-cm × 66-cm (26-in. × 26-in.) panel of the cold weather insulation material. A similar-sized piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0- oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric.

8.3.13.2 Following wash or dry-clean conditioning, 5 specimens measuring 75 mm × 300 mm (3 in. × 12 in.) from each of the warp and filling direction shall be removed from the cold weather insulation material layer of the conditioned panels.

8.3.13.3 If applicable, all specimens shall be prepared for testing by trimming the scrim material, batting, or other layer(s) away from the face cloth by 50 mm ± 3 mm (2.0 in. ± 1/8 in.) such that the face cloth can be folded back covering the scrim, batting, or other layer(s) by 50 mm ± 3 mm (2.0 in. ± 1/8 in.); the folded specimen shall be secured in the specimen holder.

8.3.13.4 Testing shall be performed as described in 8.3.2 through 8.3.7.

11. Revise subsection 8.4.1 and add new subsections 8.4.1.1 through 8.4.1.5 to read as follows:

8.4.1 Application. The heat and thermal shrinkage resistance test method shall apply to flame resistant garment fabrics, components, and hardware.

8.4.1.1 This test method shall apply to flame-resistant garment fabrics, components, hardware, and cold weather insulation materials.

8.4.1.2 Modifications to this test method for testing flame-resistant garment textile materials shall be as specified in 8.4.8.

8.4.1.3 Modifications to this test method for testing other flame-resistant garment materials, including reflective striping, shall be as specified in 8.4.9.

8.4.1.4 Modifications to this test method for testing hardware shall be as specified in 8.4.10.

8.4.1.5 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.4.11.

12. Revise subsections 8.4.2.1 and 8.4.3.1 through 8.4.3.3 to read as follows:

8.4.2.1 Only heat resistance testing shall be conducted on not fewer than three specimens for each hardware item, label material, and other flame-resistant garment fabrics, and cold weather insulation materials not listed in 8.4.2.2 and 8.4.2.3.

8.4.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3.

8.4.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after three cycles of dry-cleaning as specified in 8.1.4.

8.4.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3, after three cycles of dry-cleaning as specified in 8.1.4.

13. Delete existing subsection 8.4.8.2 and renumber 8.4.8.3 to 8.4.8.2 to read as follows:

8.4.8.2 Measurements of cold weather insulation material thermal shrinkage shall be made on the side of the fabric facing the wearer as used in the construction of the garment.

8.4.8.3 8.4.8.2 Testing shall be performed in accordance with 8.4.2 through 8.4.7.

14. Add new subsection 8.4.11 to read as follows:

8.4.11 Specific Requirements for Testing Cold Weather Insulation Materials.

8.4.11.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 50-cm × 20-cm (20-in. × 8-in.) panel of the cold weather insulation material. A similar-sized cloth piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0-oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric .

8.4.11.2 Following wash or dry-clean conditioning, 3 specimens measuring 152 mm × 152 mm (6 in. × 6 in.) shall be removed from the cold weather insulation material layer of the conditioned panel.

8.4.11.3 Testing shall be performed in accordance with 8.4.2 through 8.4.7, and thermal shrinkage shall not be measured.

Submitter’s Substantiation: The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out)

representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

 A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

 Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

 Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

 Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

 A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

 Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

 Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes

criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

Public Input No. 18-NFPA 2112-2013 [ Section No. 8.3.3 ]

8.3.3 Sample Preparation. 8.3.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3. 8.3.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after 100 cycles of dry cleaning as specified in 8.1.4. 8.3.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3, or after 100 cycles of dry cleaning as specified in 8.1.4.

Additional Proposed Changes

File Name Description Approved Proposed_TIA_1105_2112_.docx Balloted TIA

Statement of Problem and Substantiation for Public Input

Note: This Public Input originates from Tentative Interim Amendment 2112-12-2 (TIA 1105) issued by the Standards Council on August 1, 2013.

The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

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2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out) representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

• A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

• Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

• Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

• Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

• A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

• Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

• Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes criteria that create a bias against cold weather insulation materials that is inconsistent with their use and

94 of 142 7/10/2014 8:54 AM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

Submitter Information Verification

Submitter Full Name: TC on FLG-AAA Organization: TC on Flash Fire Protective Garments Street Address: City: State: Zip: Submittal Date: Fri Sep 06 14:39:49 EDT 2013

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NFPA 2112®-2012 Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire TIA Log No. 1105 Reference: Various Comment Closing Date: June 14, 2013 Submitter: Jeffrey O. Stull, International Personnel Protection, Inc.

1. Revise 3.3.6, A.3.3.6, and 3.3.20, and add a new A.3.3.20 to read as follows:

3.3.6* Cold Weather Insulation Material. A fabric that consists of one or more nonseparable layers that is used for protection in a low-temperature environment. A cold weather insulation material is not an interlining (see interlining).

A.3.3.6 Cold Weather Insulation Material. Examples of insulation materials are include textile battings(s) alone or batting(s) that are attached to a face cloth. For example, an insulation material consisting of two layers are considered nonseparable by the attachment that combines the two layers. The insulation material may or may not have a face cloth. Cold weather insulation materials generally are provided within the garment such that their area of coverage coincides with the majority of garment area covering the wearer’s body. Cold weather insulation material as defined in this standard does not preclude the use of intermediate layers for additional protection against thermal hazards.

3.3.20* Interlining. Any textile that is incorporated into any garment as a layer between outer and inner layers that only covers a small portion of the overall garment. [1975, 2009]

A.3.3.20 Interlining. The outer and inner layers are compliant to the fabric requirements of this standard. Examples of an interlining are a fabric layer used to stiffen the waist band in a pair of pants or a facing fabric used inside the closure flap of a coverall. Interlining materials do not come in contact with the wearer’s skin or underclothing.

2. Revise subsections 5.1.2, 5.1.9(7), and 5.1.12, and add a new 5.1.13 to read as follows:

5.1.2 At least one product label shall be conspicuously located inside each flame-resistant garment. when the item is properly assembled with all layers and components in place.

5.1.9(7) Fiber content for each primary fabric layer including cold weather insulation materials, but excluding interlinings and labels.

5.1.12 Garments with multiple layers, including an outer layer and removable cold weather insulation layer, shall specify the certified wearable configurations on the label configuration and include a warning on the label stating that all layers must be properly secured and worn in accordance with the manufacturer’s instructions.

5.1.13 For garments with multiple layers that include an outer layer and a removable cold weather insulation layer, a label shall be conspicuously attached to the removable insulation layer that states “DO NOT WEAR THIS LINER BY ITSELF. FOR COMPLIANCE WITH THE FLASH FIRE REQUIREMENTS OF NFPA 2112, THE COMPLETE GARMENT MUST BE WORN. FOR COMPLIANCE INFORMATION, SEE THE PRODUCT LABEL ON OUTER GARMENT.”

3. Add new Section 6.4 and subsections 6.4.1, and A.6.4.1 to read as follows:

6.4 Use of a Liner for Cold Weather Insulation. Garments shall be permitted to include liners in their construction including cold weather insulation materials where the liner is either integral to the garment or removable.

6.4.1* Where garments incorporate a cold weather insulation material as part of a removable lining system, the garment shall be designed such that the removable liner consisting of the cold weather insulation material cannot be independently worn.

A.6.4.1 Removable liners are permitted to be worn separately if the liner material(s) independently meets the appropriate fabric requirements in Chapter 7 including 7.1.1 for heat transfer performance and 7.1.5 for overall flash fire performance. If the liner contains cold weather insulation materials that are not evaluated to 7.1.1 and 7.1.5 and do not pass the thermal shrinkage resistance requirement in 7.1.3, then the manufacturer must label the liner as specified in 5.1.13 and provide a design that does not allow separate wearing of the liner without the outer layer. This may be demonstrated by the absence of a means of closure for the closure area of shirts, pants, and coveralls.

4. Add new subsections 7.1.1.1 and 7.1.1.2 to read as follows:

7.1.1.1 Where the flame-resistant garment consists of multiple and separable layers intended to be worn separately, the outer layer and the inner layer or layers shall be separately tested.

7.1.1.2 Where the flame-resistant garment consists of multiple layers intended only to be worn together, only the outer layer shall be tested.

5. Revise subsections 7.1.2 and 7.1.3 to read as follows:

7.1.2 Fabric, cold weather insulation material, and reflective striping utilized in the construction of flame-resistant garments shall be tested for flame resistance as specified in Section 8.3, and shall have a char length of not more than 100 mm (4 in.) and an after-flame of not more than 2 seconds, and shall not melt and drip.

7.1.3 Fabric utilized in the construction of flame-resistant garments, excluding manufacturer’s labels, interlinings, and cold weather insulation materials, shall be individually tested for thermal shrinkage resistance as specified in Section 8.4, and shall not shrink more than 10 percent in any direction.

6. Delete existing subsection 7.1.3.1 as follows:

7.1.3.1 Cold weather insulation materials utilized in the construction of flame-resistant garments shall be tested in accordance with Section 8.4 and shall not shrink more than 20 percent in any direction.

7. Revise subsection 7.1.4 to read as follows:

7.1.4 Fabric, cold weather insulation materials, other textile materials, and reflective striping other than those items described in 7.1.4.1 and 7.1.4.2, used in the construction of flame-resistant garments shall be individually tested for heat resistance in their original form as specified in Section 8.4, and shall not melt and drip, separate, or ignite.

8. Add a new subsection 8.3.1.7 to read as follows:

8.3.1.7 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.3.13.

9. Revise subsections 8.3.3.1, 8.3.3.2, and 8.3.3.3 to read as follows

8.3.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3.

8.3.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after 100 cycles of dry cleaning as specified in 8.1.4.

8.3.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3, or after 100 cycles of dry cleaning as specified in 8.1.4.

10. Add new subsections to 8.3.13 to read as follows:

8.3.13 Specific Requirements for Testing Cold Weather Insulation Materials.

8.3.13.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 66-cm × 66-cm (26-in. × 26-in.) panel of the cold weather insulation material. A similar-sized piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0- oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric.

8.3.13.2 Following wash or dry-clean conditioning, 5 specimens measuring 75 mm × 300 mm (3 in. × 12 in.) from each of the warp and filling direction shall be removed from the cold weather insulation material layer of the conditioned panels.

8.3.13.3 If applicable, all specimens shall be prepared for testing by trimming the scrim material, batting, or other layer(s) away from the face cloth by 50 mm ± 3 mm (2.0 in. ± 1/8 in.) such that the face cloth can be folded back covering the scrim, batting, or other layer(s) by 50 mm ± 3 mm (2.0 in. ± 1/8 in.); the folded specimen shall be secured in the specimen holder.

8.3.13.4 Testing shall be performed as described in 8.3.2 through 8.3.7.

11. Revise subsection 8.4.1 and add new subsections 8.4.1.1 through 8.4.1.5 to read as follows:

8.4.1 Application. The heat and thermal shrinkage resistance test method shall apply to flame resistant garment fabrics, components, and hardware.

8.4.1.1 This test method shall apply to flame-resistant garment fabrics, components, hardware, and cold weather insulation materials.

8.4.1.2 Modifications to this test method for testing flame-resistant garment textile materials shall be as specified in 8.4.8.

8.4.1.3 Modifications to this test method for testing other flame-resistant garment materials, including reflective striping, shall be as specified in 8.4.9.

8.4.1.4 Modifications to this test method for testing hardware shall be as specified in 8.4.10.

8.4.1.5 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.4.11.

12. Revise subsections 8.4.2.1 and 8.4.3.1 through 8.4.3.3 to read as follows:

8.4.2.1 Only heat resistance testing shall be conducted on not fewer than three specimens for each hardware item, label material, and other flame-resistant garment fabrics, and cold weather insulation materials not listed in 8.4.2.2 and 8.4.2.3.

8.4.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3.

8.4.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after three cycles of dry-cleaning as specified in 8.1.4.

8.4.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3, after three cycles of dry-cleaning as specified in 8.1.4.

13. Delete existing subsection 8.4.8.2 and renumber 8.4.8.3 to 8.4.8.2 to read as follows:

8.4.8.2 Measurements of cold weather insulation material thermal shrinkage shall be made on the side of the fabric facing the wearer as used in the construction of the garment.

8.4.8.3 8.4.8.2 Testing shall be performed in accordance with 8.4.2 through 8.4.7.

14. Add new subsection 8.4.11 to read as follows:

8.4.11 Specific Requirements for Testing Cold Weather Insulation Materials.

8.4.11.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 50-cm × 20-cm (20-in. × 8-in.) panel of the cold weather insulation material. A similar-sized cloth piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0-oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric .

8.4.11.2 Following wash or dry-clean conditioning, 3 specimens measuring 152 mm × 152 mm (6 in. × 6 in.) shall be removed from the cold weather insulation material layer of the conditioned panel.

8.4.11.3 Testing shall be performed in accordance with 8.4.2 through 8.4.7, and thermal shrinkage shall not be measured.

Submitter’s Substantiation: The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out)

representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

 A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

 Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

 Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

 Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

 A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

 Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

 Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes

criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

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Public Input No. 19-NFPA 2112-2013 [ New Section after 8.3.12 ]

8.3.13 Specific Requirements for Testing Cold Weather Insulation Materials. 8.3.13.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 66-cm × 66-cm 2 (26-in. × 26-in.) panel of the cold weather insulation material. A similar-sized piece of 200-g/m to 2 2 2 270-g/m (6.0-oz/yd to 8.0-oz/yd ) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric.

8.3.13.2 Following wash or dry-clean conditioning, 5 specimens measuring 75 mm × 300 mm (3 in. × 12 in.) from each of the warp and filling direction shall be removed from the cold weather insulation material layer of the conditioned panels. 8.3.13.3 If applicable, all specimens shall be prepared for testing by trimming the scrim material, batting, or other layer(s) away from the face cloth by 50 mm ± 3 mm (2.0 in. ± 1/8 in.) such that the face cloth can be folded back covering the scrim, batting, or other layer(s) by 50 mm ± 3 mm (2.0 in. ± 1/8 in.); the folded specimen shall be secured in the specimen holder. 8.3.13.4 Testing shall be performed as described in 8.3.2 through 8.3.7.

Additional Proposed Changes

File Name Description Approved Proposed_TIA_1105_2112_.docx Balloted TIA

Statement of Problem and Substantiation for Public Input

Note: This Public Input originates from Tentative Interim Amendment 2112-12-2 (TIA 1105) issued by the Standards Council on August 1, 2013.

The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame

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resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out) representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

• A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

• Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

• Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

• Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

• A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

• Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

• Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

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Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

Submitter Information Verification

Submitter Full Name: TC on FLG-AAA Organization: TC on Flash Fire Protective Garments Street Address: City: State: Zip: Submittal Date: Mon Sep 09 08:14:34 EDT 2013

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NFPA 2112®-2012 Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire TIA Log No. 1105 Reference: Various Comment Closing Date: June 14, 2013 Submitter: Jeffrey O. Stull, International Personnel Protection, Inc.

1. Revise 3.3.6, A.3.3.6, and 3.3.20, and add a new A.3.3.20 to read as follows:

3.3.6* Cold Weather Insulation Material. A fabric that consists of one or more nonseparable layers that is used for protection in a low-temperature environment. A cold weather insulation material is not an interlining (see interlining).

A.3.3.6 Cold Weather Insulation Material. Examples of insulation materials are include textile battings(s) alone or batting(s) that are attached to a face cloth. For example, an insulation material consisting of two layers are considered nonseparable by the attachment that combines the two layers. The insulation material may or may not have a face cloth. Cold weather insulation materials generally are provided within the garment such that their area of coverage coincides with the majority of garment area covering the wearer’s body. Cold weather insulation material as defined in this standard does not preclude the use of intermediate layers for additional protection against thermal hazards.

3.3.20* Interlining. Any textile that is incorporated into any garment as a layer between outer and inner layers that only covers a small portion of the overall garment. [1975, 2009]

A.3.3.20 Interlining. The outer and inner layers are compliant to the fabric requirements of this standard. Examples of an interlining are a fabric layer used to stiffen the waist band in a pair of pants or a facing fabric used inside the closure flap of a coverall. Interlining materials do not come in contact with the wearer’s skin or underclothing.

2. Revise subsections 5.1.2, 5.1.9(7), and 5.1.12, and add a new 5.1.13 to read as follows:

5.1.2 At least one product label shall be conspicuously located inside each flame-resistant garment. when the item is properly assembled with all layers and components in place.

5.1.9(7) Fiber content for each primary fabric layer including cold weather insulation materials, but excluding interlinings and labels.

5.1.12 Garments with multiple layers, including an outer layer and removable cold weather insulation layer, shall specify the certified wearable configurations on the label configuration and include a warning on the label stating that all layers must be properly secured and worn in accordance with the manufacturer’s instructions.

5.1.13 For garments with multiple layers that include an outer layer and a removable cold weather insulation layer, a label shall be conspicuously attached to the removable insulation layer that states “DO NOT WEAR THIS LINER BY ITSELF. FOR COMPLIANCE WITH THE FLASH FIRE REQUIREMENTS OF NFPA 2112, THE COMPLETE GARMENT MUST BE WORN. FOR COMPLIANCE INFORMATION, SEE THE PRODUCT LABEL ON OUTER GARMENT.”

3. Add new Section 6.4 and subsections 6.4.1, and A.6.4.1 to read as follows:

6.4 Use of a Liner for Cold Weather Insulation. Garments shall be permitted to include liners in their construction including cold weather insulation materials where the liner is either integral to the garment or removable.

6.4.1* Where garments incorporate a cold weather insulation material as part of a removable lining system, the garment shall be designed such that the removable liner consisting of the cold weather insulation material cannot be independently worn.

A.6.4.1 Removable liners are permitted to be worn separately if the liner material(s) independently meets the appropriate fabric requirements in Chapter 7 including 7.1.1 for heat transfer performance and 7.1.5 for overall flash fire performance. If the liner contains cold weather insulation materials that are not evaluated to 7.1.1 and 7.1.5 and do not pass the thermal shrinkage resistance requirement in 7.1.3, then the manufacturer must label the liner as specified in 5.1.13 and provide a design that does not allow separate wearing of the liner without the outer layer. This may be demonstrated by the absence of a means of closure for the closure area of shirts, pants, and coveralls.

4. Add new subsections 7.1.1.1 and 7.1.1.2 to read as follows:

7.1.1.1 Where the flame-resistant garment consists of multiple and separable layers intended to be worn separately, the outer layer and the inner layer or layers shall be separately tested.

7.1.1.2 Where the flame-resistant garment consists of multiple layers intended only to be worn together, only the outer layer shall be tested.

5. Revise subsections 7.1.2 and 7.1.3 to read as follows:

7.1.2 Fabric, cold weather insulation material, and reflective striping utilized in the construction of flame-resistant garments shall be tested for flame resistance as specified in Section 8.3, and shall have a char length of not more than 100 mm (4 in.) and an after-flame of not more than 2 seconds, and shall not melt and drip.

7.1.3 Fabric utilized in the construction of flame-resistant garments, excluding manufacturer’s labels, interlinings, and cold weather insulation materials, shall be individually tested for thermal shrinkage resistance as specified in Section 8.4, and shall not shrink more than 10 percent in any direction.

6. Delete existing subsection 7.1.3.1 as follows:

7.1.3.1 Cold weather insulation materials utilized in the construction of flame-resistant garments shall be tested in accordance with Section 8.4 and shall not shrink more than 20 percent in any direction.

7. Revise subsection 7.1.4 to read as follows:

7.1.4 Fabric, cold weather insulation materials, other textile materials, and reflective striping other than those items described in 7.1.4.1 and 7.1.4.2, used in the construction of flame-resistant garments shall be individually tested for heat resistance in their original form as specified in Section 8.4, and shall not melt and drip, separate, or ignite.

8. Add a new subsection 8.3.1.7 to read as follows:

8.3.1.7 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.3.13.

9. Revise subsections 8.3.3.1, 8.3.3.2, and 8.3.3.3 to read as follows

8.3.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3.

8.3.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after 100 cycles of dry cleaning as specified in 8.1.4.

8.3.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3, or after 100 cycles of dry cleaning as specified in 8.1.4.

10. Add new subsections to 8.3.13 to read as follows:

8.3.13 Specific Requirements for Testing Cold Weather Insulation Materials.

8.3.13.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 66-cm × 66-cm (26-in. × 26-in.) panel of the cold weather insulation material. A similar-sized piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0- oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric.

8.3.13.2 Following wash or dry-clean conditioning, 5 specimens measuring 75 mm × 300 mm (3 in. × 12 in.) from each of the warp and filling direction shall be removed from the cold weather insulation material layer of the conditioned panels.

8.3.13.3 If applicable, all specimens shall be prepared for testing by trimming the scrim material, batting, or other layer(s) away from the face cloth by 50 mm ± 3 mm (2.0 in. ± 1/8 in.) such that the face cloth can be folded back covering the scrim, batting, or other layer(s) by 50 mm ± 3 mm (2.0 in. ± 1/8 in.); the folded specimen shall be secured in the specimen holder.

8.3.13.4 Testing shall be performed as described in 8.3.2 through 8.3.7.

11. Revise subsection 8.4.1 and add new subsections 8.4.1.1 through 8.4.1.5 to read as follows:

8.4.1 Application. The heat and thermal shrinkage resistance test method shall apply to flame resistant garment fabrics, components, and hardware.

8.4.1.1 This test method shall apply to flame-resistant garment fabrics, components, hardware, and cold weather insulation materials.

8.4.1.2 Modifications to this test method for testing flame-resistant garment textile materials shall be as specified in 8.4.8.

8.4.1.3 Modifications to this test method for testing other flame-resistant garment materials, including reflective striping, shall be as specified in 8.4.9.

8.4.1.4 Modifications to this test method for testing hardware shall be as specified in 8.4.10.

8.4.1.5 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.4.11.

12. Revise subsections 8.4.2.1 and 8.4.3.1 through 8.4.3.3 to read as follows:

8.4.2.1 Only heat resistance testing shall be conducted on not fewer than three specimens for each hardware item, label material, and other flame-resistant garment fabrics, and cold weather insulation materials not listed in 8.4.2.2 and 8.4.2.3.

8.4.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3.

8.4.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after three cycles of dry-cleaning as specified in 8.1.4.

8.4.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3, after three cycles of dry-cleaning as specified in 8.1.4.

13. Delete existing subsection 8.4.8.2 and renumber 8.4.8.3 to 8.4.8.2 to read as follows:

8.4.8.2 Measurements of cold weather insulation material thermal shrinkage shall be made on the side of the fabric facing the wearer as used in the construction of the garment.

8.4.8.3 8.4.8.2 Testing shall be performed in accordance with 8.4.2 through 8.4.7.

14. Add new subsection 8.4.11 to read as follows:

8.4.11 Specific Requirements for Testing Cold Weather Insulation Materials.

8.4.11.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 50-cm × 20-cm (20-in. × 8-in.) panel of the cold weather insulation material. A similar-sized cloth piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0-oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric .

8.4.11.2 Following wash or dry-clean conditioning, 3 specimens measuring 152 mm × 152 mm (6 in. × 6 in.) shall be removed from the cold weather insulation material layer of the conditioned panel.

8.4.11.3 Testing shall be performed in accordance with 8.4.2 through 8.4.7, and thermal shrinkage shall not be measured.

Submitter’s Substantiation: The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out)

representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

 A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

 Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

 Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

 Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

 A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

 Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

 Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes

criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

Public Input No. 20-NFPA 2112-2013 [ Section No. 8.4.1 ]

8.4.1 Application. The heat and thermal shrinkage resistance 8.4.1.1 This test method shall apply to flame-resistant garment fabrics, components, hardware, and cold weather insulation materials. 8.4.1.2 Modifications to this test method for testing flame-resistant garment textile materials shall be as specified in 8.4.8. 8.4.1.3 Modifications to this test method for testing other flame-resistant garment materials, including reflective striping, shall be as specified in 8.4.9. 8.4.1.4 Modifications to this test method for testing hardware shall be as specified in 8 . 4.10. 8.4.1.5 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.4.11.

Additional Proposed Changes

File Name Description Approved Proposed_TIA_1105_2112_.docx Balloted TIA

Statement of Problem and Substantiation for Public Input

Note: This Public Input originates from Tentative Interim Amendment 2112-12-2 (TIA 1105) issued by the Standards Council on August 1, 2013.

The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance

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testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out) representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

• A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

• Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

• Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

• Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

• A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

• Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

• Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

100 of 142 7/10/2014 8:54 AM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

Submitter Information Verification

Submitter Full Name: TC on FLG-AAA Organization: TC on Flash Fire Protective Garments Street Address: City: State: Zip: Submittal Date: Mon Sep 09 08:17:43 EDT 2013

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NFPA 2112®-2012 Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire TIA Log No. 1105 Reference: Various Comment Closing Date: June 14, 2013 Submitter: Jeffrey O. Stull, International Personnel Protection, Inc.

1. Revise 3.3.6, A.3.3.6, and 3.3.20, and add a new A.3.3.20 to read as follows:

3.3.6* Cold Weather Insulation Material. A fabric that consists of one or more nonseparable layers that is used for protection in a low-temperature environment. A cold weather insulation material is not an interlining (see interlining).

A.3.3.6 Cold Weather Insulation Material. Examples of insulation materials are include textile battings(s) alone or batting(s) that are attached to a face cloth. For example, an insulation material consisting of two layers are considered nonseparable by the attachment that combines the two layers. The insulation material may or may not have a face cloth. Cold weather insulation materials generally are provided within the garment such that their area of coverage coincides with the majority of garment area covering the wearer’s body. Cold weather insulation material as defined in this standard does not preclude the use of intermediate layers for additional protection against thermal hazards.

3.3.20* Interlining. Any textile that is incorporated into any garment as a layer between outer and inner layers that only covers a small portion of the overall garment. [1975, 2009]

A.3.3.20 Interlining. The outer and inner layers are compliant to the fabric requirements of this standard. Examples of an interlining are a fabric layer used to stiffen the waist band in a pair of pants or a facing fabric used inside the closure flap of a coverall. Interlining materials do not come in contact with the wearer’s skin or underclothing.

2. Revise subsections 5.1.2, 5.1.9(7), and 5.1.12, and add a new 5.1.13 to read as follows:

5.1.2 At least one product label shall be conspicuously located inside each flame-resistant garment. when the item is properly assembled with all layers and components in place.

5.1.9(7) Fiber content for each primary fabric layer including cold weather insulation materials, but excluding interlinings and labels.

5.1.12 Garments with multiple layers, including an outer layer and removable cold weather insulation layer, shall specify the certified wearable configurations on the label configuration and include a warning on the label stating that all layers must be properly secured and worn in accordance with the manufacturer’s instructions.

5.1.13 For garments with multiple layers that include an outer layer and a removable cold weather insulation layer, a label shall be conspicuously attached to the removable insulation layer that states “DO NOT WEAR THIS LINER BY ITSELF. FOR COMPLIANCE WITH THE FLASH FIRE REQUIREMENTS OF NFPA 2112, THE COMPLETE GARMENT MUST BE WORN. FOR COMPLIANCE INFORMATION, SEE THE PRODUCT LABEL ON OUTER GARMENT.”

3. Add new Section 6.4 and subsections 6.4.1, and A.6.4.1 to read as follows:

6.4 Use of a Liner for Cold Weather Insulation. Garments shall be permitted to include liners in their construction including cold weather insulation materials where the liner is either integral to the garment or removable.

6.4.1* Where garments incorporate a cold weather insulation material as part of a removable lining system, the garment shall be designed such that the removable liner consisting of the cold weather insulation material cannot be independently worn.

A.6.4.1 Removable liners are permitted to be worn separately if the liner material(s) independently meets the appropriate fabric requirements in Chapter 7 including 7.1.1 for heat transfer performance and 7.1.5 for overall flash fire performance. If the liner contains cold weather insulation materials that are not evaluated to 7.1.1 and 7.1.5 and do not pass the thermal shrinkage resistance requirement in 7.1.3, then the manufacturer must label the liner as specified in 5.1.13 and provide a design that does not allow separate wearing of the liner without the outer layer. This may be demonstrated by the absence of a means of closure for the closure area of shirts, pants, and coveralls.

4. Add new subsections 7.1.1.1 and 7.1.1.2 to read as follows:

7.1.1.1 Where the flame-resistant garment consists of multiple and separable layers intended to be worn separately, the outer layer and the inner layer or layers shall be separately tested.

7.1.1.2 Where the flame-resistant garment consists of multiple layers intended only to be worn together, only the outer layer shall be tested.

5. Revise subsections 7.1.2 and 7.1.3 to read as follows:

7.1.2 Fabric, cold weather insulation material, and reflective striping utilized in the construction of flame-resistant garments shall be tested for flame resistance as specified in Section 8.3, and shall have a char length of not more than 100 mm (4 in.) and an after-flame of not more than 2 seconds, and shall not melt and drip.

7.1.3 Fabric utilized in the construction of flame-resistant garments, excluding manufacturer’s labels, interlinings, and cold weather insulation materials, shall be individually tested for thermal shrinkage resistance as specified in Section 8.4, and shall not shrink more than 10 percent in any direction.

6. Delete existing subsection 7.1.3.1 as follows:

7.1.3.1 Cold weather insulation materials utilized in the construction of flame-resistant garments shall be tested in accordance with Section 8.4 and shall not shrink more than 20 percent in any direction.

7. Revise subsection 7.1.4 to read as follows:

7.1.4 Fabric, cold weather insulation materials, other textile materials, and reflective striping other than those items described in 7.1.4.1 and 7.1.4.2, used in the construction of flame-resistant garments shall be individually tested for heat resistance in their original form as specified in Section 8.4, and shall not melt and drip, separate, or ignite.

8. Add a new subsection 8.3.1.7 to read as follows:

8.3.1.7 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.3.13.

9. Revise subsections 8.3.3.1, 8.3.3.2, and 8.3.3.3 to read as follows

8.3.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3.

8.3.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after 100 cycles of dry cleaning as specified in 8.1.4.

8.3.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3, or after 100 cycles of dry cleaning as specified in 8.1.4.

10. Add new subsections to 8.3.13 to read as follows:

8.3.13 Specific Requirements for Testing Cold Weather Insulation Materials.

8.3.13.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 66-cm × 66-cm (26-in. × 26-in.) panel of the cold weather insulation material. A similar-sized piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0- oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric.

8.3.13.2 Following wash or dry-clean conditioning, 5 specimens measuring 75 mm × 300 mm (3 in. × 12 in.) from each of the warp and filling direction shall be removed from the cold weather insulation material layer of the conditioned panels.

8.3.13.3 If applicable, all specimens shall be prepared for testing by trimming the scrim material, batting, or other layer(s) away from the face cloth by 50 mm ± 3 mm (2.0 in. ± 1/8 in.) such that the face cloth can be folded back covering the scrim, batting, or other layer(s) by 50 mm ± 3 mm (2.0 in. ± 1/8 in.); the folded specimen shall be secured in the specimen holder.

8.3.13.4 Testing shall be performed as described in 8.3.2 through 8.3.7.

11. Revise subsection 8.4.1 and add new subsections 8.4.1.1 through 8.4.1.5 to read as follows:

8.4.1 Application. The heat and thermal shrinkage resistance test method shall apply to flame resistant garment fabrics, components, and hardware.

8.4.1.1 This test method shall apply to flame-resistant garment fabrics, components, hardware, and cold weather insulation materials.

8.4.1.2 Modifications to this test method for testing flame-resistant garment textile materials shall be as specified in 8.4.8.

8.4.1.3 Modifications to this test method for testing other flame-resistant garment materials, including reflective striping, shall be as specified in 8.4.9.

8.4.1.4 Modifications to this test method for testing hardware shall be as specified in 8.4.10.

8.4.1.5 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.4.11.

12. Revise subsections 8.4.2.1 and 8.4.3.1 through 8.4.3.3 to read as follows:

8.4.2.1 Only heat resistance testing shall be conducted on not fewer than three specimens for each hardware item, label material, and other flame-resistant garment fabrics, and cold weather insulation materials not listed in 8.4.2.2 and 8.4.2.3.

8.4.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3.

8.4.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after three cycles of dry-cleaning as specified in 8.1.4.

8.4.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3, after three cycles of dry-cleaning as specified in 8.1.4.

13. Delete existing subsection 8.4.8.2 and renumber 8.4.8.3 to 8.4.8.2 to read as follows:

8.4.8.2 Measurements of cold weather insulation material thermal shrinkage shall be made on the side of the fabric facing the wearer as used in the construction of the garment.

8.4.8.3 8.4.8.2 Testing shall be performed in accordance with 8.4.2 through 8.4.7.

14. Add new subsection 8.4.11 to read as follows:

8.4.11 Specific Requirements for Testing Cold Weather Insulation Materials.

8.4.11.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 50-cm × 20-cm (20-in. × 8-in.) panel of the cold weather insulation material. A similar-sized cloth piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0-oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric .

8.4.11.2 Following wash or dry-clean conditioning, 3 specimens measuring 152 mm × 152 mm (6 in. × 6 in.) shall be removed from the cold weather insulation material layer of the conditioned panel.

8.4.11.3 Testing shall be performed in accordance with 8.4.2 through 8.4.7, and thermal shrinkage shall not be measured.

Submitter’s Substantiation: The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out)

representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

 A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

 Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

 Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

 Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

 A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

 Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

 Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes

criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

Public Input No. 21-NFPA 2112-2013 [ Section No. 8.4.2.1 ]

8.4.2.1 Only heat resistance testing shall be conducted on not fewer than three specimens for each hardware item, label material, and other flame-resistant garment fabrics not , and cold weather insulation materials not listed in 8.4.2.2 and 8.4.2.3.

Additional Proposed Changes

File Name Description Approved Proposed_TIA_1105_2112_.docx Balloted TIA

Statement of Problem and Substantiation for Public Input

Note: This Public Input originates from Tentative Interim Amendment 2112-12-2 (TIA 1105) issued by the Standards Council on August 1, 2013.

The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out) representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

102 of 142 7/10/2014 8:54 AM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

• A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

• Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

• Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

• Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

• A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

• Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

• Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

Submitter Information Verification

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Submitter Full Name: TC on FLG-AAA Organization: TC on Flash Fire Protective Garments Street Address: City: State: Zip: Submittal Date: Mon Sep 09 08:20:36 EDT 2013

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NFPA 2112®-2012 Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire TIA Log No. 1105 Reference: Various Comment Closing Date: June 14, 2013 Submitter: Jeffrey O. Stull, International Personnel Protection, Inc.

1. Revise 3.3.6, A.3.3.6, and 3.3.20, and add a new A.3.3.20 to read as follows:

3.3.6* Cold Weather Insulation Material. A fabric that consists of one or more nonseparable layers that is used for protection in a low-temperature environment. A cold weather insulation material is not an interlining (see interlining).

A.3.3.6 Cold Weather Insulation Material. Examples of insulation materials are include textile battings(s) alone or batting(s) that are attached to a face cloth. For example, an insulation material consisting of two layers are considered nonseparable by the attachment that combines the two layers. The insulation material may or may not have a face cloth. Cold weather insulation materials generally are provided within the garment such that their area of coverage coincides with the majority of garment area covering the wearer’s body. Cold weather insulation material as defined in this standard does not preclude the use of intermediate layers for additional protection against thermal hazards.

3.3.20* Interlining. Any textile that is incorporated into any garment as a layer between outer and inner layers that only covers a small portion of the overall garment. [1975, 2009]

A.3.3.20 Interlining. The outer and inner layers are compliant to the fabric requirements of this standard. Examples of an interlining are a fabric layer used to stiffen the waist band in a pair of pants or a facing fabric used inside the closure flap of a coverall. Interlining materials do not come in contact with the wearer’s skin or underclothing.

2. Revise subsections 5.1.2, 5.1.9(7), and 5.1.12, and add a new 5.1.13 to read as follows:

5.1.2 At least one product label shall be conspicuously located inside each flame-resistant garment. when the item is properly assembled with all layers and components in place.

5.1.9(7) Fiber content for each primary fabric layer including cold weather insulation materials, but excluding interlinings and labels.

5.1.12 Garments with multiple layers, including an outer layer and removable cold weather insulation layer, shall specify the certified wearable configurations on the label configuration and include a warning on the label stating that all layers must be properly secured and worn in accordance with the manufacturer’s instructions.

5.1.13 For garments with multiple layers that include an outer layer and a removable cold weather insulation layer, a label shall be conspicuously attached to the removable insulation layer that states “DO NOT WEAR THIS LINER BY ITSELF. FOR COMPLIANCE WITH THE FLASH FIRE REQUIREMENTS OF NFPA 2112, THE COMPLETE GARMENT MUST BE WORN. FOR COMPLIANCE INFORMATION, SEE THE PRODUCT LABEL ON OUTER GARMENT.”

3. Add new Section 6.4 and subsections 6.4.1, and A.6.4.1 to read as follows:

6.4 Use of a Liner for Cold Weather Insulation. Garments shall be permitted to include liners in their construction including cold weather insulation materials where the liner is either integral to the garment or removable.

6.4.1* Where garments incorporate a cold weather insulation material as part of a removable lining system, the garment shall be designed such that the removable liner consisting of the cold weather insulation material cannot be independently worn.

A.6.4.1 Removable liners are permitted to be worn separately if the liner material(s) independently meets the appropriate fabric requirements in Chapter 7 including 7.1.1 for heat transfer performance and 7.1.5 for overall flash fire performance. If the liner contains cold weather insulation materials that are not evaluated to 7.1.1 and 7.1.5 and do not pass the thermal shrinkage resistance requirement in 7.1.3, then the manufacturer must label the liner as specified in 5.1.13 and provide a design that does not allow separate wearing of the liner without the outer layer. This may be demonstrated by the absence of a means of closure for the closure area of shirts, pants, and coveralls.

4. Add new subsections 7.1.1.1 and 7.1.1.2 to read as follows:

7.1.1.1 Where the flame-resistant garment consists of multiple and separable layers intended to be worn separately, the outer layer and the inner layer or layers shall be separately tested.

7.1.1.2 Where the flame-resistant garment consists of multiple layers intended only to be worn together, only the outer layer shall be tested.

5. Revise subsections 7.1.2 and 7.1.3 to read as follows:

7.1.2 Fabric, cold weather insulation material, and reflective striping utilized in the construction of flame-resistant garments shall be tested for flame resistance as specified in Section 8.3, and shall have a char length of not more than 100 mm (4 in.) and an after-flame of not more than 2 seconds, and shall not melt and drip.

7.1.3 Fabric utilized in the construction of flame-resistant garments, excluding manufacturer’s labels, interlinings, and cold weather insulation materials, shall be individually tested for thermal shrinkage resistance as specified in Section 8.4, and shall not shrink more than 10 percent in any direction.

6. Delete existing subsection 7.1.3.1 as follows:

7.1.3.1 Cold weather insulation materials utilized in the construction of flame-resistant garments shall be tested in accordance with Section 8.4 and shall not shrink more than 20 percent in any direction.

7. Revise subsection 7.1.4 to read as follows:

7.1.4 Fabric, cold weather insulation materials, other textile materials, and reflective striping other than those items described in 7.1.4.1 and 7.1.4.2, used in the construction of flame-resistant garments shall be individually tested for heat resistance in their original form as specified in Section 8.4, and shall not melt and drip, separate, or ignite.

8. Add a new subsection 8.3.1.7 to read as follows:

8.3.1.7 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.3.13.

9. Revise subsections 8.3.3.1, 8.3.3.2, and 8.3.3.3 to read as follows

8.3.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3.

8.3.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after 100 cycles of dry cleaning as specified in 8.1.4.

8.3.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3, or after 100 cycles of dry cleaning as specified in 8.1.4.

10. Add new subsections to 8.3.13 to read as follows:

8.3.13 Specific Requirements for Testing Cold Weather Insulation Materials.

8.3.13.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 66-cm × 66-cm (26-in. × 26-in.) panel of the cold weather insulation material. A similar-sized piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0- oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric.

8.3.13.2 Following wash or dry-clean conditioning, 5 specimens measuring 75 mm × 300 mm (3 in. × 12 in.) from each of the warp and filling direction shall be removed from the cold weather insulation material layer of the conditioned panels.

8.3.13.3 If applicable, all specimens shall be prepared for testing by trimming the scrim material, batting, or other layer(s) away from the face cloth by 50 mm ± 3 mm (2.0 in. ± 1/8 in.) such that the face cloth can be folded back covering the scrim, batting, or other layer(s) by 50 mm ± 3 mm (2.0 in. ± 1/8 in.); the folded specimen shall be secured in the specimen holder.

8.3.13.4 Testing shall be performed as described in 8.3.2 through 8.3.7.

11. Revise subsection 8.4.1 and add new subsections 8.4.1.1 through 8.4.1.5 to read as follows:

8.4.1 Application. The heat and thermal shrinkage resistance test method shall apply to flame resistant garment fabrics, components, and hardware.

8.4.1.1 This test method shall apply to flame-resistant garment fabrics, components, hardware, and cold weather insulation materials.

8.4.1.2 Modifications to this test method for testing flame-resistant garment textile materials shall be as specified in 8.4.8.

8.4.1.3 Modifications to this test method for testing other flame-resistant garment materials, including reflective striping, shall be as specified in 8.4.9.

8.4.1.4 Modifications to this test method for testing hardware shall be as specified in 8.4.10.

8.4.1.5 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.4.11.

12. Revise subsections 8.4.2.1 and 8.4.3.1 through 8.4.3.3 to read as follows:

8.4.2.1 Only heat resistance testing shall be conducted on not fewer than three specimens for each hardware item, label material, and other flame-resistant garment fabrics, and cold weather insulation materials not listed in 8.4.2.2 and 8.4.2.3.

8.4.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3.

8.4.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after three cycles of dry-cleaning as specified in 8.1.4.

8.4.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3, after three cycles of dry-cleaning as specified in 8.1.4.

13. Delete existing subsection 8.4.8.2 and renumber 8.4.8.3 to 8.4.8.2 to read as follows:

8.4.8.2 Measurements of cold weather insulation material thermal shrinkage shall be made on the side of the fabric facing the wearer as used in the construction of the garment.

8.4.8.3 8.4.8.2 Testing shall be performed in accordance with 8.4.2 through 8.4.7.

14. Add new subsection 8.4.11 to read as follows:

8.4.11 Specific Requirements for Testing Cold Weather Insulation Materials.

8.4.11.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 50-cm × 20-cm (20-in. × 8-in.) panel of the cold weather insulation material. A similar-sized cloth piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0-oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric .

8.4.11.2 Following wash or dry-clean conditioning, 3 specimens measuring 152 mm × 152 mm (6 in. × 6 in.) shall be removed from the cold weather insulation material layer of the conditioned panel.

8.4.11.3 Testing shall be performed in accordance with 8.4.2 through 8.4.7, and thermal shrinkage shall not be measured.

Submitter’s Substantiation: The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out)

representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

 A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

 Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

 Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

 Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

 A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

 Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

 Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes

criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

Public Input No. 22-NFPA 2112-2013 [ Sections 8.4.3.1, 8.4.3.2, 8.4.3.3 ]

Sections 8.4.3.1, 8.4.3.2, 8.4.3.3 8.4.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3. 8.4.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after three cycles of dry cleaning as specified in 8.1.4. 8.4.3.3 For fabrics that and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3, or after three cycles of dry cleaning as specified in 8.1.4.

Additional Proposed Changes

File Name Description Approved Proposed_TIA_1105_2112_.docx Balloted TIA

Statement of Problem and Substantiation for Public Input

Note: This Public Input originates from Tentative Interim Amendment 2112-12-2 (TIA 1105) issued by the Standards Council on August 1, 2013.

The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

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2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out) representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

• A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

• Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

• Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

• Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

• A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

• Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

• Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes criteria that create a bias against cold weather insulation materials that is inconsistent with their use and

106 of 142 7/10/2014 8:54 AM National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

Submitter Information Verification

Submitter Full Name: TC on FLG-AAA Organization: TC on Flash Fire Protective Garments Street Address: City: State: Zip: Submittal Date: Mon Sep 09 08:23:13 EDT 2013

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NFPA 2112®-2012 Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire TIA Log No. 1105 Reference: Various Comment Closing Date: June 14, 2013 Submitter: Jeffrey O. Stull, International Personnel Protection, Inc.

1. Revise 3.3.6, A.3.3.6, and 3.3.20, and add a new A.3.3.20 to read as follows:

3.3.6* Cold Weather Insulation Material. A fabric that consists of one or more nonseparable layers that is used for protection in a low-temperature environment. A cold weather insulation material is not an interlining (see interlining).

A.3.3.6 Cold Weather Insulation Material. Examples of insulation materials are include textile battings(s) alone or batting(s) that are attached to a face cloth. For example, an insulation material consisting of two layers are considered nonseparable by the attachment that combines the two layers. The insulation material may or may not have a face cloth. Cold weather insulation materials generally are provided within the garment such that their area of coverage coincides with the majority of garment area covering the wearer’s body. Cold weather insulation material as defined in this standard does not preclude the use of intermediate layers for additional protection against thermal hazards.

3.3.20* Interlining. Any textile that is incorporated into any garment as a layer between outer and inner layers that only covers a small portion of the overall garment. [1975, 2009]

A.3.3.20 Interlining. The outer and inner layers are compliant to the fabric requirements of this standard. Examples of an interlining are a fabric layer used to stiffen the waist band in a pair of pants or a facing fabric used inside the closure flap of a coverall. Interlining materials do not come in contact with the wearer’s skin or underclothing.

2. Revise subsections 5.1.2, 5.1.9(7), and 5.1.12, and add a new 5.1.13 to read as follows:

5.1.2 At least one product label shall be conspicuously located inside each flame-resistant garment. when the item is properly assembled with all layers and components in place.

5.1.9(7) Fiber content for each primary fabric layer including cold weather insulation materials, but excluding interlinings and labels.

5.1.12 Garments with multiple layers, including an outer layer and removable cold weather insulation layer, shall specify the certified wearable configurations on the label configuration and include a warning on the label stating that all layers must be properly secured and worn in accordance with the manufacturer’s instructions.

5.1.13 For garments with multiple layers that include an outer layer and a removable cold weather insulation layer, a label shall be conspicuously attached to the removable insulation layer that states “DO NOT WEAR THIS LINER BY ITSELF. FOR COMPLIANCE WITH THE FLASH FIRE REQUIREMENTS OF NFPA 2112, THE COMPLETE GARMENT MUST BE WORN. FOR COMPLIANCE INFORMATION, SEE THE PRODUCT LABEL ON OUTER GARMENT.”

3. Add new Section 6.4 and subsections 6.4.1, and A.6.4.1 to read as follows:

6.4 Use of a Liner for Cold Weather Insulation. Garments shall be permitted to include liners in their construction including cold weather insulation materials where the liner is either integral to the garment or removable.

6.4.1* Where garments incorporate a cold weather insulation material as part of a removable lining system, the garment shall be designed such that the removable liner consisting of the cold weather insulation material cannot be independently worn.

A.6.4.1 Removable liners are permitted to be worn separately if the liner material(s) independently meets the appropriate fabric requirements in Chapter 7 including 7.1.1 for heat transfer performance and 7.1.5 for overall flash fire performance. If the liner contains cold weather insulation materials that are not evaluated to 7.1.1 and 7.1.5 and do not pass the thermal shrinkage resistance requirement in 7.1.3, then the manufacturer must label the liner as specified in 5.1.13 and provide a design that does not allow separate wearing of the liner without the outer layer. This may be demonstrated by the absence of a means of closure for the closure area of shirts, pants, and coveralls.

4. Add new subsections 7.1.1.1 and 7.1.1.2 to read as follows:

7.1.1.1 Where the flame-resistant garment consists of multiple and separable layers intended to be worn separately, the outer layer and the inner layer or layers shall be separately tested.

7.1.1.2 Where the flame-resistant garment consists of multiple layers intended only to be worn together, only the outer layer shall be tested.

5. Revise subsections 7.1.2 and 7.1.3 to read as follows:

7.1.2 Fabric, cold weather insulation material, and reflective striping utilized in the construction of flame-resistant garments shall be tested for flame resistance as specified in Section 8.3, and shall have a char length of not more than 100 mm (4 in.) and an after-flame of not more than 2 seconds, and shall not melt and drip.

7.1.3 Fabric utilized in the construction of flame-resistant garments, excluding manufacturer’s labels, interlinings, and cold weather insulation materials, shall be individually tested for thermal shrinkage resistance as specified in Section 8.4, and shall not shrink more than 10 percent in any direction.

6. Delete existing subsection 7.1.3.1 as follows:

7.1.3.1 Cold weather insulation materials utilized in the construction of flame-resistant garments shall be tested in accordance with Section 8.4 and shall not shrink more than 20 percent in any direction.

7. Revise subsection 7.1.4 to read as follows:

7.1.4 Fabric, cold weather insulation materials, other textile materials, and reflective striping other than those items described in 7.1.4.1 and 7.1.4.2, used in the construction of flame-resistant garments shall be individually tested for heat resistance in their original form as specified in Section 8.4, and shall not melt and drip, separate, or ignite.

8. Add a new subsection 8.3.1.7 to read as follows:

8.3.1.7 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.3.13.

9. Revise subsections 8.3.3.1, 8.3.3.2, and 8.3.3.3 to read as follows

8.3.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3.

8.3.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after 100 cycles of dry cleaning as specified in 8.1.4.

8.3.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3, or after 100 cycles of dry cleaning as specified in 8.1.4.

10. Add new subsections to 8.3.13 to read as follows:

8.3.13 Specific Requirements for Testing Cold Weather Insulation Materials.

8.3.13.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 66-cm × 66-cm (26-in. × 26-in.) panel of the cold weather insulation material. A similar-sized piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0- oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric.

8.3.13.2 Following wash or dry-clean conditioning, 5 specimens measuring 75 mm × 300 mm (3 in. × 12 in.) from each of the warp and filling direction shall be removed from the cold weather insulation material layer of the conditioned panels.

8.3.13.3 If applicable, all specimens shall be prepared for testing by trimming the scrim material, batting, or other layer(s) away from the face cloth by 50 mm ± 3 mm (2.0 in. ± 1/8 in.) such that the face cloth can be folded back covering the scrim, batting, or other layer(s) by 50 mm ± 3 mm (2.0 in. ± 1/8 in.); the folded specimen shall be secured in the specimen holder.

8.3.13.4 Testing shall be performed as described in 8.3.2 through 8.3.7.

11. Revise subsection 8.4.1 and add new subsections 8.4.1.1 through 8.4.1.5 to read as follows:

8.4.1 Application. The heat and thermal shrinkage resistance test method shall apply to flame resistant garment fabrics, components, and hardware.

8.4.1.1 This test method shall apply to flame-resistant garment fabrics, components, hardware, and cold weather insulation materials.

8.4.1.2 Modifications to this test method for testing flame-resistant garment textile materials shall be as specified in 8.4.8.

8.4.1.3 Modifications to this test method for testing other flame-resistant garment materials, including reflective striping, shall be as specified in 8.4.9.

8.4.1.4 Modifications to this test method for testing hardware shall be as specified in 8.4.10.

8.4.1.5 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.4.11.

12. Revise subsections 8.4.2.1 and 8.4.3.1 through 8.4.3.3 to read as follows:

8.4.2.1 Only heat resistance testing shall be conducted on not fewer than three specimens for each hardware item, label material, and other flame-resistant garment fabrics, and cold weather insulation materials not listed in 8.4.2.2 and 8.4.2.3.

8.4.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3.

8.4.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after three cycles of dry-cleaning as specified in 8.1.4.

8.4.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3, after three cycles of dry-cleaning as specified in 8.1.4.

13. Delete existing subsection 8.4.8.2 and renumber 8.4.8.3 to 8.4.8.2 to read as follows:

8.4.8.2 Measurements of cold weather insulation material thermal shrinkage shall be made on the side of the fabric facing the wearer as used in the construction of the garment.

8.4.8.3 8.4.8.2 Testing shall be performed in accordance with 8.4.2 through 8.4.7.

14. Add new subsection 8.4.11 to read as follows:

8.4.11 Specific Requirements for Testing Cold Weather Insulation Materials.

8.4.11.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 50-cm × 20-cm (20-in. × 8-in.) panel of the cold weather insulation material. A similar-sized cloth piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0-oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric .

8.4.11.2 Following wash or dry-clean conditioning, 3 specimens measuring 152 mm × 152 mm (6 in. × 6 in.) shall be removed from the cold weather insulation material layer of the conditioned panel.

8.4.11.3 Testing shall be performed in accordance with 8.4.2 through 8.4.7, and thermal shrinkage shall not be measured.

Submitter’s Substantiation: The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out)

representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

 A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

 Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

 Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

 Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

 A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

 Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

 Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes

criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

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Public Input No. 23-NFPA 2112-2013 [ Sections 8.4.8.2, 8.4.8.3 ]

Sections 8.4.8.2, 8.4.8.3 8.4.8.2 Measurements of cold weather insulation material thermal shrinkage shall be made on the side of the fabric facing the wearer as used in the construction of the garment. 8.4.8.3 Testing shall be performed in accordance with 8.4.2 through 8.4.7.

Additional Proposed Changes

File Name Description Approved Proposed_TIA_1105_2112_.docx Balloted TIA

Statement of Problem and Substantiation for Public Input

Note: This Public Input originates from Tentative Interim Amendment 2112-12-2 (TIA 1105) issued by the Standards Council on August 1, 2013.

The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out) representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes

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to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

• A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

• Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

• Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

• Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

• A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

• Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

• Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

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Submitter Information Verification

Submitter Full Name: TC on FLG-AAA Organization: TC on Flash Fire Protective Garments Street Address: City: State: Zip: Submittal Date: Mon Sep 09 08:25:35 EDT 2013

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NFPA 2112®-2012 Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire TIA Log No. 1105 Reference: Various Comment Closing Date: June 14, 2013 Submitter: Jeffrey O. Stull, International Personnel Protection, Inc.

1. Revise 3.3.6, A.3.3.6, and 3.3.20, and add a new A.3.3.20 to read as follows:

3.3.6* Cold Weather Insulation Material. A fabric that consists of one or more nonseparable layers that is used for protection in a low-temperature environment. A cold weather insulation material is not an interlining (see interlining).

A.3.3.6 Cold Weather Insulation Material. Examples of insulation materials are include textile battings(s) alone or batting(s) that are attached to a face cloth. For example, an insulation material consisting of two layers are considered nonseparable by the attachment that combines the two layers. The insulation material may or may not have a face cloth. Cold weather insulation materials generally are provided within the garment such that their area of coverage coincides with the majority of garment area covering the wearer’s body. Cold weather insulation material as defined in this standard does not preclude the use of intermediate layers for additional protection against thermal hazards.

3.3.20* Interlining. Any textile that is incorporated into any garment as a layer between outer and inner layers that only covers a small portion of the overall garment. [1975, 2009]

A.3.3.20 Interlining. The outer and inner layers are compliant to the fabric requirements of this standard. Examples of an interlining are a fabric layer used to stiffen the waist band in a pair of pants or a facing fabric used inside the closure flap of a coverall. Interlining materials do not come in contact with the wearer’s skin or underclothing.

2. Revise subsections 5.1.2, 5.1.9(7), and 5.1.12, and add a new 5.1.13 to read as follows:

5.1.2 At least one product label shall be conspicuously located inside each flame-resistant garment. when the item is properly assembled with all layers and components in place.

5.1.9(7) Fiber content for each primary fabric layer including cold weather insulation materials, but excluding interlinings and labels.

5.1.12 Garments with multiple layers, including an outer layer and removable cold weather insulation layer, shall specify the certified wearable configurations on the label configuration and include a warning on the label stating that all layers must be properly secured and worn in accordance with the manufacturer’s instructions.

5.1.13 For garments with multiple layers that include an outer layer and a removable cold weather insulation layer, a label shall be conspicuously attached to the removable insulation layer that states “DO NOT WEAR THIS LINER BY ITSELF. FOR COMPLIANCE WITH THE FLASH FIRE REQUIREMENTS OF NFPA 2112, THE COMPLETE GARMENT MUST BE WORN. FOR COMPLIANCE INFORMATION, SEE THE PRODUCT LABEL ON OUTER GARMENT.”

3. Add new Section 6.4 and subsections 6.4.1, and A.6.4.1 to read as follows:

6.4 Use of a Liner for Cold Weather Insulation. Garments shall be permitted to include liners in their construction including cold weather insulation materials where the liner is either integral to the garment or removable.

6.4.1* Where garments incorporate a cold weather insulation material as part of a removable lining system, the garment shall be designed such that the removable liner consisting of the cold weather insulation material cannot be independently worn.

A.6.4.1 Removable liners are permitted to be worn separately if the liner material(s) independently meets the appropriate fabric requirements in Chapter 7 including 7.1.1 for heat transfer performance and 7.1.5 for overall flash fire performance. If the liner contains cold weather insulation materials that are not evaluated to 7.1.1 and 7.1.5 and do not pass the thermal shrinkage resistance requirement in 7.1.3, then the manufacturer must label the liner as specified in 5.1.13 and provide a design that does not allow separate wearing of the liner without the outer layer. This may be demonstrated by the absence of a means of closure for the closure area of shirts, pants, and coveralls.

4. Add new subsections 7.1.1.1 and 7.1.1.2 to read as follows:

7.1.1.1 Where the flame-resistant garment consists of multiple and separable layers intended to be worn separately, the outer layer and the inner layer or layers shall be separately tested.

7.1.1.2 Where the flame-resistant garment consists of multiple layers intended only to be worn together, only the outer layer shall be tested.

5. Revise subsections 7.1.2 and 7.1.3 to read as follows:

7.1.2 Fabric, cold weather insulation material, and reflective striping utilized in the construction of flame-resistant garments shall be tested for flame resistance as specified in Section 8.3, and shall have a char length of not more than 100 mm (4 in.) and an after-flame of not more than 2 seconds, and shall not melt and drip.

7.1.3 Fabric utilized in the construction of flame-resistant garments, excluding manufacturer’s labels, interlinings, and cold weather insulation materials, shall be individually tested for thermal shrinkage resistance as specified in Section 8.4, and shall not shrink more than 10 percent in any direction.

6. Delete existing subsection 7.1.3.1 as follows:

7.1.3.1 Cold weather insulation materials utilized in the construction of flame-resistant garments shall be tested in accordance with Section 8.4 and shall not shrink more than 20 percent in any direction.

7. Revise subsection 7.1.4 to read as follows:

7.1.4 Fabric, cold weather insulation materials, other textile materials, and reflective striping other than those items described in 7.1.4.1 and 7.1.4.2, used in the construction of flame-resistant garments shall be individually tested for heat resistance in their original form as specified in Section 8.4, and shall not melt and drip, separate, or ignite.

8. Add a new subsection 8.3.1.7 to read as follows:

8.3.1.7 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.3.13.

9. Revise subsections 8.3.3.1, 8.3.3.2, and 8.3.3.3 to read as follows

8.3.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3.

8.3.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after 100 cycles of dry cleaning as specified in 8.1.4.

8.3.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3, or after 100 cycles of dry cleaning as specified in 8.1.4.

10. Add new subsections to 8.3.13 to read as follows:

8.3.13 Specific Requirements for Testing Cold Weather Insulation Materials.

8.3.13.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 66-cm × 66-cm (26-in. × 26-in.) panel of the cold weather insulation material. A similar-sized piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0- oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric.

8.3.13.2 Following wash or dry-clean conditioning, 5 specimens measuring 75 mm × 300 mm (3 in. × 12 in.) from each of the warp and filling direction shall be removed from the cold weather insulation material layer of the conditioned panels.

8.3.13.3 If applicable, all specimens shall be prepared for testing by trimming the scrim material, batting, or other layer(s) away from the face cloth by 50 mm ± 3 mm (2.0 in. ± 1/8 in.) such that the face cloth can be folded back covering the scrim, batting, or other layer(s) by 50 mm ± 3 mm (2.0 in. ± 1/8 in.); the folded specimen shall be secured in the specimen holder.

8.3.13.4 Testing shall be performed as described in 8.3.2 through 8.3.7.

11. Revise subsection 8.4.1 and add new subsections 8.4.1.1 through 8.4.1.5 to read as follows:

8.4.1 Application. The heat and thermal shrinkage resistance test method shall apply to flame resistant garment fabrics, components, and hardware.

8.4.1.1 This test method shall apply to flame-resistant garment fabrics, components, hardware, and cold weather insulation materials.

8.4.1.2 Modifications to this test method for testing flame-resistant garment textile materials shall be as specified in 8.4.8.

8.4.1.3 Modifications to this test method for testing other flame-resistant garment materials, including reflective striping, shall be as specified in 8.4.9.

8.4.1.4 Modifications to this test method for testing hardware shall be as specified in 8.4.10.

8.4.1.5 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.4.11.

12. Revise subsections 8.4.2.1 and 8.4.3.1 through 8.4.3.3 to read as follows:

8.4.2.1 Only heat resistance testing shall be conducted on not fewer than three specimens for each hardware item, label material, and other flame-resistant garment fabrics, and cold weather insulation materials not listed in 8.4.2.2 and 8.4.2.3.

8.4.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3.

8.4.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after three cycles of dry-cleaning as specified in 8.1.4.

8.4.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3, after three cycles of dry-cleaning as specified in 8.1.4.

13. Delete existing subsection 8.4.8.2 and renumber 8.4.8.3 to 8.4.8.2 to read as follows:

8.4.8.2 Measurements of cold weather insulation material thermal shrinkage shall be made on the side of the fabric facing the wearer as used in the construction of the garment.

8.4.8.3 8.4.8.2 Testing shall be performed in accordance with 8.4.2 through 8.4.7.

14. Add new subsection 8.4.11 to read as follows:

8.4.11 Specific Requirements for Testing Cold Weather Insulation Materials.

8.4.11.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 50-cm × 20-cm (20-in. × 8-in.) panel of the cold weather insulation material. A similar-sized cloth piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0-oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric .

8.4.11.2 Following wash or dry-clean conditioning, 3 specimens measuring 152 mm × 152 mm (6 in. × 6 in.) shall be removed from the cold weather insulation material layer of the conditioned panel.

8.4.11.3 Testing shall be performed in accordance with 8.4.2 through 8.4.7, and thermal shrinkage shall not be measured.

Submitter’s Substantiation: The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out)

representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

 A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

 Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

 Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

 Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

 A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

 Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

 Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes

criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

Public Input No. 24-NFPA 2112-2013 [ New Section after 8.4.10.5 ]

8.4.11 Specific Requirements for Testing Cold Weather Insulation Materials. 8.4.11.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 50-cm × 20-cm 2 (20-in. × 8-in.) panel of the cold weather insulation material. A similar-sized cloth piece of 200-g/m 2 2 2 to 270-g/m (6.0-oz/yd to 8.0-oz/yd ) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric . 8.4.11.2 Following wash or dry-clean conditioning, 3 specimens measuring 152 mm × 152 mm (6 in. × 6 in.) shall be removed from the cold weather insulation material layer of the conditioned panel. 8.4.11.3 Testing shall be performed in accordance with 8.4.2 through 8.4.7, and thermal shrinkage shall not be measured.

Additional Proposed Changes

File Name Description Approved Proposed_TIA_1105_2112_.docx Balloted TIA

Statement of Problem and Substantiation for Public Input

Note: This Public Input originates from Tentative Interim Amendment 2112-12-2 (TIA 1105) issued by the Standards Council on August 1, 2013.

The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

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2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out) representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

• A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

• Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

• Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

• Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

• A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

• Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

• Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes criteria that create a bias against cold weather insulation materials that is inconsistent with their use and

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in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

Submitter Information Verification

Submitter Full Name: TC on FLG-AAA Organization: TC on Flash Fire Protective Garments Street Address: City: State: Zip: Submittal Date: Mon Sep 09 08:27:27 EDT 2013

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NFPA 2112®-2012 Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire TIA Log No. 1105 Reference: Various Comment Closing Date: June 14, 2013 Submitter: Jeffrey O. Stull, International Personnel Protection, Inc.

1. Revise 3.3.6, A.3.3.6, and 3.3.20, and add a new A.3.3.20 to read as follows:

3.3.6* Cold Weather Insulation Material. A fabric that consists of one or more nonseparable layers that is used for protection in a low-temperature environment. A cold weather insulation material is not an interlining (see interlining).

A.3.3.6 Cold Weather Insulation Material. Examples of insulation materials are include textile battings(s) alone or batting(s) that are attached to a face cloth. For example, an insulation material consisting of two layers are considered nonseparable by the attachment that combines the two layers. The insulation material may or may not have a face cloth. Cold weather insulation materials generally are provided within the garment such that their area of coverage coincides with the majority of garment area covering the wearer’s body. Cold weather insulation material as defined in this standard does not preclude the use of intermediate layers for additional protection against thermal hazards.

3.3.20* Interlining. Any textile that is incorporated into any garment as a layer between outer and inner layers that only covers a small portion of the overall garment. [1975, 2009]

A.3.3.20 Interlining. The outer and inner layers are compliant to the fabric requirements of this standard. Examples of an interlining are a fabric layer used to stiffen the waist band in a pair of pants or a facing fabric used inside the closure flap of a coverall. Interlining materials do not come in contact with the wearer’s skin or underclothing.

2. Revise subsections 5.1.2, 5.1.9(7), and 5.1.12, and add a new 5.1.13 to read as follows:

5.1.2 At least one product label shall be conspicuously located inside each flame-resistant garment. when the item is properly assembled with all layers and components in place.

5.1.9(7) Fiber content for each primary fabric layer including cold weather insulation materials, but excluding interlinings and labels.

5.1.12 Garments with multiple layers, including an outer layer and removable cold weather insulation layer, shall specify the certified wearable configurations on the label configuration and include a warning on the label stating that all layers must be properly secured and worn in accordance with the manufacturer’s instructions.

5.1.13 For garments with multiple layers that include an outer layer and a removable cold weather insulation layer, a label shall be conspicuously attached to the removable insulation layer that states “DO NOT WEAR THIS LINER BY ITSELF. FOR COMPLIANCE WITH THE FLASH FIRE REQUIREMENTS OF NFPA 2112, THE COMPLETE GARMENT MUST BE WORN. FOR COMPLIANCE INFORMATION, SEE THE PRODUCT LABEL ON OUTER GARMENT.”

3. Add new Section 6.4 and subsections 6.4.1, and A.6.4.1 to read as follows:

6.4 Use of a Liner for Cold Weather Insulation. Garments shall be permitted to include liners in their construction including cold weather insulation materials where the liner is either integral to the garment or removable.

6.4.1* Where garments incorporate a cold weather insulation material as part of a removable lining system, the garment shall be designed such that the removable liner consisting of the cold weather insulation material cannot be independently worn.

A.6.4.1 Removable liners are permitted to be worn separately if the liner material(s) independently meets the appropriate fabric requirements in Chapter 7 including 7.1.1 for heat transfer performance and 7.1.5 for overall flash fire performance. If the liner contains cold weather insulation materials that are not evaluated to 7.1.1 and 7.1.5 and do not pass the thermal shrinkage resistance requirement in 7.1.3, then the manufacturer must label the liner as specified in 5.1.13 and provide a design that does not allow separate wearing of the liner without the outer layer. This may be demonstrated by the absence of a means of closure for the closure area of shirts, pants, and coveralls.

4. Add new subsections 7.1.1.1 and 7.1.1.2 to read as follows:

7.1.1.1 Where the flame-resistant garment consists of multiple and separable layers intended to be worn separately, the outer layer and the inner layer or layers shall be separately tested.

7.1.1.2 Where the flame-resistant garment consists of multiple layers intended only to be worn together, only the outer layer shall be tested.

5. Revise subsections 7.1.2 and 7.1.3 to read as follows:

7.1.2 Fabric, cold weather insulation material, and reflective striping utilized in the construction of flame-resistant garments shall be tested for flame resistance as specified in Section 8.3, and shall have a char length of not more than 100 mm (4 in.) and an after-flame of not more than 2 seconds, and shall not melt and drip.

7.1.3 Fabric utilized in the construction of flame-resistant garments, excluding manufacturer’s labels, interlinings, and cold weather insulation materials, shall be individually tested for thermal shrinkage resistance as specified in Section 8.4, and shall not shrink more than 10 percent in any direction.

6. Delete existing subsection 7.1.3.1 as follows:

7.1.3.1 Cold weather insulation materials utilized in the construction of flame-resistant garments shall be tested in accordance with Section 8.4 and shall not shrink more than 20 percent in any direction.

7. Revise subsection 7.1.4 to read as follows:

7.1.4 Fabric, cold weather insulation materials, other textile materials, and reflective striping other than those items described in 7.1.4.1 and 7.1.4.2, used in the construction of flame-resistant garments shall be individually tested for heat resistance in their original form as specified in Section 8.4, and shall not melt and drip, separate, or ignite.

8. Add a new subsection 8.3.1.7 to read as follows:

8.3.1.7 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.3.13.

9. Revise subsections 8.3.3.1, 8.3.3.2, and 8.3.3.3 to read as follows

8.3.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3.

8.3.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after 100 cycles of dry cleaning as specified in 8.1.4.

8.3.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3, or after 100 cycles of dry cleaning as specified in 8.1.4.

10. Add new subsections to 8.3.13 to read as follows:

8.3.13 Specific Requirements for Testing Cold Weather Insulation Materials.

8.3.13.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 66-cm × 66-cm (26-in. × 26-in.) panel of the cold weather insulation material. A similar-sized piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0- oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric.

8.3.13.2 Following wash or dry-clean conditioning, 5 specimens measuring 75 mm × 300 mm (3 in. × 12 in.) from each of the warp and filling direction shall be removed from the cold weather insulation material layer of the conditioned panels.

8.3.13.3 If applicable, all specimens shall be prepared for testing by trimming the scrim material, batting, or other layer(s) away from the face cloth by 50 mm ± 3 mm (2.0 in. ± 1/8 in.) such that the face cloth can be folded back covering the scrim, batting, or other layer(s) by 50 mm ± 3 mm (2.0 in. ± 1/8 in.); the folded specimen shall be secured in the specimen holder.

8.3.13.4 Testing shall be performed as described in 8.3.2 through 8.3.7.

11. Revise subsection 8.4.1 and add new subsections 8.4.1.1 through 8.4.1.5 to read as follows:

8.4.1 Application. The heat and thermal shrinkage resistance test method shall apply to flame resistant garment fabrics, components, and hardware.

8.4.1.1 This test method shall apply to flame-resistant garment fabrics, components, hardware, and cold weather insulation materials.

8.4.1.2 Modifications to this test method for testing flame-resistant garment textile materials shall be as specified in 8.4.8.

8.4.1.3 Modifications to this test method for testing other flame-resistant garment materials, including reflective striping, shall be as specified in 8.4.9.

8.4.1.4 Modifications to this test method for testing hardware shall be as specified in 8.4.10.

8.4.1.5 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.4.11.

12. Revise subsections 8.4.2.1 and 8.4.3.1 through 8.4.3.3 to read as follows:

8.4.2.1 Only heat resistance testing shall be conducted on not fewer than three specimens for each hardware item, label material, and other flame-resistant garment fabrics, and cold weather insulation materials not listed in 8.4.2.2 and 8.4.2.3.

8.4.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3.

8.4.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after three cycles of dry-cleaning as specified in 8.1.4.

8.4.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3, after three cycles of dry-cleaning as specified in 8.1.4.

13. Delete existing subsection 8.4.8.2 and renumber 8.4.8.3 to 8.4.8.2 to read as follows:

8.4.8.2 Measurements of cold weather insulation material thermal shrinkage shall be made on the side of the fabric facing the wearer as used in the construction of the garment.

8.4.8.3 8.4.8.2 Testing shall be performed in accordance with 8.4.2 through 8.4.7.

14. Add new subsection 8.4.11 to read as follows:

8.4.11 Specific Requirements for Testing Cold Weather Insulation Materials.

8.4.11.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 50-cm × 20-cm (20-in. × 8-in.) panel of the cold weather insulation material. A similar-sized cloth piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0-oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric .

8.4.11.2 Following wash or dry-clean conditioning, 3 specimens measuring 152 mm × 152 mm (6 in. × 6 in.) shall be removed from the cold weather insulation material layer of the conditioned panel.

8.4.11.3 Testing shall be performed in accordance with 8.4.2 through 8.4.7, and thermal shrinkage shall not be measured.

Submitter’s Substantiation: The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out)

representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

 A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

 Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

 Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

 Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

 A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

 Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

 Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes

criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

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Public Input No. 43-NFPA 2112-2014 [ Section No. 8.5.2.2 ]

8.5.2.2 Fabrics to be tested shall be used to construct the standard garment design specified in 8.3.2 of ASTM F 1930, Standard Test Method for Evaluation of Flame Resistant Clothing for Protection Against Flash Fire Simulations Using an Instrumented Manikin.

Statement of Problem and Substantiation for Public Input

Corrected the title of the ASTM F 1930 standard test method noted in this section.

Submitter Information Verification

Submitter Full Name: Roger Parry Organization: The DuPont Company, Inc. Street Address: City: State: Zip: Submittal Date: Tue Jul 01 16:02:03 EDT 2014

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Public Input No. 44-NFPA 2112-2014 [ Section No. 8.5.4.1 ]

8.5.4.1 Specimens shall be tested in accordance with ASTM F 1930, Standard Test Method for Evaluation of Flame Resistant Clothing for Protection Against Flash Fire Simulations Using an Instrumented Manikin, using an 2 2 exposure heat flux of 84 kW/m (2.02 cal/cm ·sec) with an exposure time of 3 seconds.

Statement of Problem and Substantiation for Public Input

Corrected the title of the ASTM F 1930 standard test method noted in this section.

Submitter Information Verification

Submitter Full Name: Roger Parry Organization: The DuPont Company, Inc. Street Address: City: State: Zip: Submittal Date: Tue Jul 01 16:04:02 EDT 2014

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Public Input No. 45-NFPA 2112-2014 [ Section No. A.1.2.1 ]

A.1.2.1 Users are cautioned that flammable clothing can contribute to the severity of burn injuries through its ignition and continued burning after exposure to flash fire. Short-duration thermal exposures can arise from other multiple fire types in industrial environments. These include, but are not limited to, jet flames, liquid fires (pool fires or running liquid fires), solids fires (fires of solid materials or dust fires), warehouse fires, and fires associated with oxygen.

Statement of Problem and Substantiation for Public Input

"Flash" fires, or vapor cloud fires are a very small subset of actual fire types experienced in industrial environments with fire hazards. The potential fires that exist can be in the form of pressurized flammable line breaks (jet fires), flammable liquid spills (pool and running pool fires), combustible dust, and fireballs (from Boiling Liquid Expanding Vapor Explosions or flammable material container BLEVE). Actual thermal exposures can be in the form of full or partial flame contact or engulfment and/or exposure to the radiant energy from a fire's flame emissive power (e.g., when a worker is not in contact with the flames but is escaping the hazard). The standard is better served by identifying thermal exposures to fire, which encompasses all of the noted hazards and fits with the established standard's Purpose (1.2.1), rather than a specific fire type (in this case "Flash" fires).

Submitter Information Verification

Submitter Full Name: Roger Parry Organization: The DuPont Company, Inc. Street Address: City: State: Zip: Submittal Date: Tue Jul 01 16:05:43 EDT 2014

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Public Input No. 46-NFPA 2112-2014 [ Section No. A.1.2.2 ]

A.1.2.2 The testing requirements in Chapter 8 of this standard are not intended to establish the limitations of the working environment for personnel involved in situations that might be exposed to chemical flash fires, but are intended to establish material performance. Users should be advised that if unusual conditions prevail, or if there are signs of abuse or mutilation of the protective garment, or if modifications or replacements are made or accessories are added without authorization of the protective garment manufacturer, the margin of protection might be reduced. Users should be advised that the protective properties in new protective garments, as required by this standard, can change as the product is worn and ages.

Statement of Problem and Substantiation for Public Input

Chemical "flash" fires (vapor cloud fires) are a very small subset of actual chemical fire types experienced in industrial environments with fire hazards. The potential fires that exist can be in the form of pressurized flammable line breaks (jet fires), flammable liquid spills (pool and running pool fires), combustible dust, and fireballs (from Boiling Liquid Expanding Vapor Explosions or flammable material container BLEVE). Actual thermal exposures can be in the form of full or partial flame contact or engulfment and/or exposure to the radiant energy from a chemical fire's flame emissive power (e.g., when a worker is not in contact with the flames but is escaping the hazard). The standard is better served by identifying fire in the generic sense here rather than a specific fire type (in this case "Flash" fires).

Submitter Information Verification

Submitter Full Name: Roger Parry Organization: The DuPont Company, Inc. Street Address: City: State: Zip: Submittal Date: Tue Jul 01 16:08:07 EDT 2014

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Public Input No. 47-NFPA 2112-2014 [ Section No. A.1.2.3 ]

A.1.2.3 This standard is not designed to be utilized as a purchase specification. It is prepared, as far as practical, with regard to required performance, avoiding restriction of design wherever possible. Purchasers should specify departmental requirements for such items as color, markings, closures, pockets, and trim patterns. Tests specified in this standard should not be deemed as defining or establishing performance levels for protection from all flash fire environments.

Statement of Problem and Substantiation for Public Input

"Flash" fires (vapor cloud fires) are a very small subset of actual fire types experienced in industrial environments with fire hazards. The potential fires that exist can be in the form of pressurized flammable line breaks (jet fires), flammable liquid spills (pool and running pool fires), combustible dust, and fireballs (from Boiling Liquid Expanding Vapor Explosions or flammable material container BLEVE). Actual thermal exposures can be in the form of full or partial flame contact or engulfment and/or exposure to the radiant energy from a fire's flame emissive power (e.g., when a worker is not in contact with the flames but is escaping the hazard). The standard is better served by identifying fire in the generic sense here rather than a specific fire type (in this case "Flash" fires).

Submitter Information Verification

Submitter Full Name: Roger Parry Organization: The DuPont Company, Inc. Street Address: City: State: Zip: Submittal Date: Tue Jul 01 16:12:20 EDT 2014

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Public Input No. 7-NFPA 2112-2013 [ Section No. A.3.3.6 ]

A.3.3.6 Cold Weather Insulation Material. Examples of insulation materials are include textile batting(s) alone or batting(s) that are attached to a face cloth. For example, an insulation material consisting of two layers are considered nonseparable by the attachment that combines the two layers. The insulation material may or may not have a face cloth. Cold weather insulation materials generally are provided within the garment such that their area of coverage coincides with the majority of garment area covering the wearer’s body. Cold weather insulation material as defined in this standard does not preclude the use of intermediate layers for additional protection against thermal hazards.

Additional Proposed Changes

File Name Description Approved Proposed_TIA_1105_2112_.docx Balloted TIA

Statement of Problem and Substantiation for Public Input

Note: This Public Input originates from Tentative Interim Amendment 2112-12-2 (TIA 1105) issued by the Standards Council on August 1, 2013.

The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out) representing a “worst case” exposure and

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wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

• A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

• Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

• Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

• Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

• A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

• Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

• Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not

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provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

Submitter Information Verification

Submitter Full Name: TC on FLG-AAA Organization: TC on Flash Fire Protective Garments Street Address: City: State: Zip: Submittal Date: Fri Sep 06 14:09:24 EDT 2013

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NFPA 2112®-2012 Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire TIA Log No. 1105 Reference: Various Comment Closing Date: June 14, 2013 Submitter: Jeffrey O. Stull, International Personnel Protection, Inc.

1. Revise 3.3.6, A.3.3.6, and 3.3.20, and add a new A.3.3.20 to read as follows:

3.3.6* Cold Weather Insulation Material. A fabric that consists of one or more nonseparable layers that is used for protection in a low-temperature environment. A cold weather insulation material is not an interlining (see interlining).

A.3.3.6 Cold Weather Insulation Material. Examples of insulation materials are include textile battings(s) alone or batting(s) that are attached to a face cloth. For example, an insulation material consisting of two layers are considered nonseparable by the attachment that combines the two layers. The insulation material may or may not have a face cloth. Cold weather insulation materials generally are provided within the garment such that their area of coverage coincides with the majority of garment area covering the wearer’s body. Cold weather insulation material as defined in this standard does not preclude the use of intermediate layers for additional protection against thermal hazards.

3.3.20* Interlining. Any textile that is incorporated into any garment as a layer between outer and inner layers that only covers a small portion of the overall garment. [1975, 2009]

A.3.3.20 Interlining. The outer and inner layers are compliant to the fabric requirements of this standard. Examples of an interlining are a fabric layer used to stiffen the waist band in a pair of pants or a facing fabric used inside the closure flap of a coverall. Interlining materials do not come in contact with the wearer’s skin or underclothing.

2. Revise subsections 5.1.2, 5.1.9(7), and 5.1.12, and add a new 5.1.13 to read as follows:

5.1.2 At least one product label shall be conspicuously located inside each flame-resistant garment. when the item is properly assembled with all layers and components in place.

5.1.9(7) Fiber content for each primary fabric layer including cold weather insulation materials, but excluding interlinings and labels.

5.1.12 Garments with multiple layers, including an outer layer and removable cold weather insulation layer, shall specify the certified wearable configurations on the label configuration and include a warning on the label stating that all layers must be properly secured and worn in accordance with the manufacturer’s instructions.

5.1.13 For garments with multiple layers that include an outer layer and a removable cold weather insulation layer, a label shall be conspicuously attached to the removable insulation layer that states “DO NOT WEAR THIS LINER BY ITSELF. FOR COMPLIANCE WITH THE FLASH FIRE REQUIREMENTS OF NFPA 2112, THE COMPLETE GARMENT MUST BE WORN. FOR COMPLIANCE INFORMATION, SEE THE PRODUCT LABEL ON OUTER GARMENT.”

3. Add new Section 6.4 and subsections 6.4.1, and A.6.4.1 to read as follows:

6.4 Use of a Liner for Cold Weather Insulation. Garments shall be permitted to include liners in their construction including cold weather insulation materials where the liner is either integral to the garment or removable.

6.4.1* Where garments incorporate a cold weather insulation material as part of a removable lining system, the garment shall be designed such that the removable liner consisting of the cold weather insulation material cannot be independently worn.

A.6.4.1 Removable liners are permitted to be worn separately if the liner material(s) independently meets the appropriate fabric requirements in Chapter 7 including 7.1.1 for heat transfer performance and 7.1.5 for overall flash fire performance. If the liner contains cold weather insulation materials that are not evaluated to 7.1.1 and 7.1.5 and do not pass the thermal shrinkage resistance requirement in 7.1.3, then the manufacturer must label the liner as specified in 5.1.13 and provide a design that does not allow separate wearing of the liner without the outer layer. This may be demonstrated by the absence of a means of closure for the closure area of shirts, pants, and coveralls.

4. Add new subsections 7.1.1.1 and 7.1.1.2 to read as follows:

7.1.1.1 Where the flame-resistant garment consists of multiple and separable layers intended to be worn separately, the outer layer and the inner layer or layers shall be separately tested.

7.1.1.2 Where the flame-resistant garment consists of multiple layers intended only to be worn together, only the outer layer shall be tested.

5. Revise subsections 7.1.2 and 7.1.3 to read as follows:

7.1.2 Fabric, cold weather insulation material, and reflective striping utilized in the construction of flame-resistant garments shall be tested for flame resistance as specified in Section 8.3, and shall have a char length of not more than 100 mm (4 in.) and an after-flame of not more than 2 seconds, and shall not melt and drip.

7.1.3 Fabric utilized in the construction of flame-resistant garments, excluding manufacturer’s labels, interlinings, and cold weather insulation materials, shall be individually tested for thermal shrinkage resistance as specified in Section 8.4, and shall not shrink more than 10 percent in any direction.

6. Delete existing subsection 7.1.3.1 as follows:

7.1.3.1 Cold weather insulation materials utilized in the construction of flame-resistant garments shall be tested in accordance with Section 8.4 and shall not shrink more than 20 percent in any direction.

7. Revise subsection 7.1.4 to read as follows:

7.1.4 Fabric, cold weather insulation materials, other textile materials, and reflective striping other than those items described in 7.1.4.1 and 7.1.4.2, used in the construction of flame-resistant garments shall be individually tested for heat resistance in their original form as specified in Section 8.4, and shall not melt and drip, separate, or ignite.

8. Add a new subsection 8.3.1.7 to read as follows:

8.3.1.7 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.3.13.

9. Revise subsections 8.3.3.1, 8.3.3.2, and 8.3.3.3 to read as follows

8.3.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3.

8.3.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after 100 cycles of dry cleaning as specified in 8.1.4.

8.3.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3, or after 100 cycles of dry cleaning as specified in 8.1.4.

10. Add new subsections to 8.3.13 to read as follows:

8.3.13 Specific Requirements for Testing Cold Weather Insulation Materials.

8.3.13.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 66-cm × 66-cm (26-in. × 26-in.) panel of the cold weather insulation material. A similar-sized piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0- oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric.

8.3.13.2 Following wash or dry-clean conditioning, 5 specimens measuring 75 mm × 300 mm (3 in. × 12 in.) from each of the warp and filling direction shall be removed from the cold weather insulation material layer of the conditioned panels.

8.3.13.3 If applicable, all specimens shall be prepared for testing by trimming the scrim material, batting, or other layer(s) away from the face cloth by 50 mm ± 3 mm (2.0 in. ± 1/8 in.) such that the face cloth can be folded back covering the scrim, batting, or other layer(s) by 50 mm ± 3 mm (2.0 in. ± 1/8 in.); the folded specimen shall be secured in the specimen holder.

8.3.13.4 Testing shall be performed as described in 8.3.2 through 8.3.7.

11. Revise subsection 8.4.1 and add new subsections 8.4.1.1 through 8.4.1.5 to read as follows:

8.4.1 Application. The heat and thermal shrinkage resistance test method shall apply to flame resistant garment fabrics, components, and hardware.

8.4.1.1 This test method shall apply to flame-resistant garment fabrics, components, hardware, and cold weather insulation materials.

8.4.1.2 Modifications to this test method for testing flame-resistant garment textile materials shall be as specified in 8.4.8.

8.4.1.3 Modifications to this test method for testing other flame-resistant garment materials, including reflective striping, shall be as specified in 8.4.9.

8.4.1.4 Modifications to this test method for testing hardware shall be as specified in 8.4.10.

8.4.1.5 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.4.11.

12. Revise subsections 8.4.2.1 and 8.4.3.1 through 8.4.3.3 to read as follows:

8.4.2.1 Only heat resistance testing shall be conducted on not fewer than three specimens for each hardware item, label material, and other flame-resistant garment fabrics, and cold weather insulation materials not listed in 8.4.2.2 and 8.4.2.3.

8.4.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3.

8.4.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after three cycles of dry-cleaning as specified in 8.1.4.

8.4.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3, after three cycles of dry-cleaning as specified in 8.1.4.

13. Delete existing subsection 8.4.8.2 and renumber 8.4.8.3 to 8.4.8.2 to read as follows:

8.4.8.2 Measurements of cold weather insulation material thermal shrinkage shall be made on the side of the fabric facing the wearer as used in the construction of the garment.

8.4.8.3 8.4.8.2 Testing shall be performed in accordance with 8.4.2 through 8.4.7.

14. Add new subsection 8.4.11 to read as follows:

8.4.11 Specific Requirements for Testing Cold Weather Insulation Materials.

8.4.11.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 50-cm × 20-cm (20-in. × 8-in.) panel of the cold weather insulation material. A similar-sized cloth piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0-oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric .

8.4.11.2 Following wash or dry-clean conditioning, 3 specimens measuring 152 mm × 152 mm (6 in. × 6 in.) shall be removed from the cold weather insulation material layer of the conditioned panel.

8.4.11.3 Testing shall be performed in accordance with 8.4.2 through 8.4.7, and thermal shrinkage shall not be measured.

Submitter’s Substantiation: The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out)

representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

 A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

 Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

 Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

 Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

 A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

 Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

 Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes

criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

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Public Input No. 49-NFPA 2112-2014 [ New Section after A.3.3.13 ]

A.3.3.x Fire. Fire is the result of combustion, or the chemical process of rapid oxidation (burning) that requires an ignition source, a flammable substance or fuel, and oxygen (usually from air). In an industrial environment, different types of fires may result from a variety of different events. “Jet” fires typically arise from line breaks or ruptures of pressurized flammable materials. These fires can create high velocity, directed “jets”, which may project flames in any direction for considerable distances, depending on the characteristics of the source, and burn until the fuel is exhausted or the break is isolated. A pool, or running pool fire, arises from the ignition of spills and leaks of flammable liquids. The size and intensity is dependent on the amount of material involved and typically extends upward from the surface of the pool. These fires also continue until the fuel is exhausted and the source of the leak isolated. A flash, or vapor cloud fire arises from the release or presence of a hydrocarbon gas or combustible finely divided particles (e.g., coal dust or grain) that contains a concentration above the lower explosive limit of the chemical. Flash fire characteristics depend on the size of the gas or vapor cloud and local conditions. When ignited, the flame front may expand outward in the form of a fireball or be driven by external convection (wind). The resulting effect of the fireball or flame front’s energy with respect to radiant heat significantly enlarges the hazard areas around the gas released.

Statement of Problem and Substantiation for Public Input

A discussion regarding the definition of fire and various industrial fire types is missing from this standard (which defines the minimum PPE requirements for the hazard). This section introduces the general concepts involved and various fire types that may pose hazards to workers.

Submitter Information Verification

Submitter Full Name: Roger Parry Organization: The DuPont Company, Inc. Street Address: City: State: Zip: Submittal Date: Tue Jul 01 16:17:09 EDT 2014

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Public Input No. 48-NFPA 2112-2014 [ Section No. A.3.3.13 ]

A.3.3.13 Flash Fire. A flash fire requires an ignition source and a hydrocarbon atmosphere or atmosphere containing combustible finely divided particles (e.g., coal dust or grain) that contains a concentration above the lower explosive limit of the chemical. Both hydrocarbon and dust flash fires generate temperatures from 540°C to 1040°C (1000°F to 1900°F). A flash fire depends on the size of the gas or vapor cloud, and when ignited, the flame front expands outward in the form of a fireball. The resulting effect of the fireball's energy with respect to radiant heat significantly enlarges the hazard areas around the gas released.

Statement of Problem and Substantiation for Public Input

This standard establishes the minimum performance requirements of PPE for protection of industrial personnel from short duration thermal exposures from industrial fires, not from a specific type of fire. "Flash" fires, or vapor cloud fires are a very small subset of actual fire types experienced in industrial environments with fire hazards. The potential fires that exist can be in the form of pressurized flammable line breaks (jet fires), flammable liquid spills (pool and running pool fires), combustible dust, and fireballs (from Boiling Liquid Expanding Vapor Explosions or flammable material container BLEVE). Actual thermal exposures can be in the form of full or partial flame contact or engulfment and/or exposure to the radiant energy from a fire's flame emissive power (e.g., when a worker is not in contact with the flames but is escaping the hazard). The standard is better served by identifying thermal exposures to fire, which encompasses all of the noted hazards and fits with the established standard's Purpose (1.2.1), rather than singling out a specific fire type (as in the case of "Flash Fires"). As such, a definition specific to "Flash Fires" is not required.

Submitter Information Verification

Submitter Full Name: Roger Parry Organization: The DuPont Company, Inc. Street Address: City: State: Zip: Submittal Date: Tue Jul 01 16:16:02 EDT 2014

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Public Input No. 8-NFPA 2112-2013 [ New Section after A.3.3.15.2 ]

A.3.3.20 Interlining. The outer and inner layers are compliant to the fabric requirements of this standard. Examples of an interlining are a fabric layer used to stiffen the waist band in a pair of pants or a facing fabric used inside the closure flap of a coverall. Interlining materials do not come in contact with the wearer’s skin or underclothing.

Additional Proposed Changes

File Name Description Approved Proposed_TIA_1105_2112_.docx Balloted TIA

Statement of Problem and Substantiation for Public Input

Note: This Public Input originates from Tentative Interim Amendment 2112-12-2 (TIA 1105) issued by the Standards Council on August 1, 2013.

The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out) representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

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It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

• A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

• Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

• Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

• Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

• A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

• Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

• Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

Submitter Information Verification

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Submitter Full Name: TC on FLG-AAA Organization: TC on Flash Fire Protective Garments Street Address: City: State: Zip: Submittal Date: Fri Sep 06 14:11:05 EDT 2013

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NFPA 2112®-2012 Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire TIA Log No. 1105 Reference: Various Comment Closing Date: June 14, 2013 Submitter: Jeffrey O. Stull, International Personnel Protection, Inc.

1. Revise 3.3.6, A.3.3.6, and 3.3.20, and add a new A.3.3.20 to read as follows:

3.3.6* Cold Weather Insulation Material. A fabric that consists of one or more nonseparable layers that is used for protection in a low-temperature environment. A cold weather insulation material is not an interlining (see interlining).

A.3.3.6 Cold Weather Insulation Material. Examples of insulation materials are include textile battings(s) alone or batting(s) that are attached to a face cloth. For example, an insulation material consisting of two layers are considered nonseparable by the attachment that combines the two layers. The insulation material may or may not have a face cloth. Cold weather insulation materials generally are provided within the garment such that their area of coverage coincides with the majority of garment area covering the wearer’s body. Cold weather insulation material as defined in this standard does not preclude the use of intermediate layers for additional protection against thermal hazards.

3.3.20* Interlining. Any textile that is incorporated into any garment as a layer between outer and inner layers that only covers a small portion of the overall garment. [1975, 2009]

A.3.3.20 Interlining. The outer and inner layers are compliant to the fabric requirements of this standard. Examples of an interlining are a fabric layer used to stiffen the waist band in a pair of pants or a facing fabric used inside the closure flap of a coverall. Interlining materials do not come in contact with the wearer’s skin or underclothing.

2. Revise subsections 5.1.2, 5.1.9(7), and 5.1.12, and add a new 5.1.13 to read as follows:

5.1.2 At least one product label shall be conspicuously located inside each flame-resistant garment. when the item is properly assembled with all layers and components in place.

5.1.9(7) Fiber content for each primary fabric layer including cold weather insulation materials, but excluding interlinings and labels.

5.1.12 Garments with multiple layers, including an outer layer and removable cold weather insulation layer, shall specify the certified wearable configurations on the label configuration and include a warning on the label stating that all layers must be properly secured and worn in accordance with the manufacturer’s instructions.

5.1.13 For garments with multiple layers that include an outer layer and a removable cold weather insulation layer, a label shall be conspicuously attached to the removable insulation layer that states “DO NOT WEAR THIS LINER BY ITSELF. FOR COMPLIANCE WITH THE FLASH FIRE REQUIREMENTS OF NFPA 2112, THE COMPLETE GARMENT MUST BE WORN. FOR COMPLIANCE INFORMATION, SEE THE PRODUCT LABEL ON OUTER GARMENT.”

3. Add new Section 6.4 and subsections 6.4.1, and A.6.4.1 to read as follows:

6.4 Use of a Liner for Cold Weather Insulation. Garments shall be permitted to include liners in their construction including cold weather insulation materials where the liner is either integral to the garment or removable.

6.4.1* Where garments incorporate a cold weather insulation material as part of a removable lining system, the garment shall be designed such that the removable liner consisting of the cold weather insulation material cannot be independently worn.

A.6.4.1 Removable liners are permitted to be worn separately if the liner material(s) independently meets the appropriate fabric requirements in Chapter 7 including 7.1.1 for heat transfer performance and 7.1.5 for overall flash fire performance. If the liner contains cold weather insulation materials that are not evaluated to 7.1.1 and 7.1.5 and do not pass the thermal shrinkage resistance requirement in 7.1.3, then the manufacturer must label the liner as specified in 5.1.13 and provide a design that does not allow separate wearing of the liner without the outer layer. This may be demonstrated by the absence of a means of closure for the closure area of shirts, pants, and coveralls.

4. Add new subsections 7.1.1.1 and 7.1.1.2 to read as follows:

7.1.1.1 Where the flame-resistant garment consists of multiple and separable layers intended to be worn separately, the outer layer and the inner layer or layers shall be separately tested.

7.1.1.2 Where the flame-resistant garment consists of multiple layers intended only to be worn together, only the outer layer shall be tested.

5. Revise subsections 7.1.2 and 7.1.3 to read as follows:

7.1.2 Fabric, cold weather insulation material, and reflective striping utilized in the construction of flame-resistant garments shall be tested for flame resistance as specified in Section 8.3, and shall have a char length of not more than 100 mm (4 in.) and an after-flame of not more than 2 seconds, and shall not melt and drip.

7.1.3 Fabric utilized in the construction of flame-resistant garments, excluding manufacturer’s labels, interlinings, and cold weather insulation materials, shall be individually tested for thermal shrinkage resistance as specified in Section 8.4, and shall not shrink more than 10 percent in any direction.

6. Delete existing subsection 7.1.3.1 as follows:

7.1.3.1 Cold weather insulation materials utilized in the construction of flame-resistant garments shall be tested in accordance with Section 8.4 and shall not shrink more than 20 percent in any direction.

7. Revise subsection 7.1.4 to read as follows:

7.1.4 Fabric, cold weather insulation materials, other textile materials, and reflective striping other than those items described in 7.1.4.1 and 7.1.4.2, used in the construction of flame-resistant garments shall be individually tested for heat resistance in their original form as specified in Section 8.4, and shall not melt and drip, separate, or ignite.

8. Add a new subsection 8.3.1.7 to read as follows:

8.3.1.7 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.3.13.

9. Revise subsections 8.3.3.1, 8.3.3.2, and 8.3.3.3 to read as follows

8.3.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3.

8.3.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after 100 cycles of dry cleaning as specified in 8.1.4.

8.3.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3, or after 100 cycles of dry cleaning as specified in 8.1.4.

10. Add new subsections to 8.3.13 to read as follows:

8.3.13 Specific Requirements for Testing Cold Weather Insulation Materials.

8.3.13.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 66-cm × 66-cm (26-in. × 26-in.) panel of the cold weather insulation material. A similar-sized piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0- oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric.

8.3.13.2 Following wash or dry-clean conditioning, 5 specimens measuring 75 mm × 300 mm (3 in. × 12 in.) from each of the warp and filling direction shall be removed from the cold weather insulation material layer of the conditioned panels.

8.3.13.3 If applicable, all specimens shall be prepared for testing by trimming the scrim material, batting, or other layer(s) away from the face cloth by 50 mm ± 3 mm (2.0 in. ± 1/8 in.) such that the face cloth can be folded back covering the scrim, batting, or other layer(s) by 50 mm ± 3 mm (2.0 in. ± 1/8 in.); the folded specimen shall be secured in the specimen holder.

8.3.13.4 Testing shall be performed as described in 8.3.2 through 8.3.7.

11. Revise subsection 8.4.1 and add new subsections 8.4.1.1 through 8.4.1.5 to read as follows:

8.4.1 Application. The heat and thermal shrinkage resistance test method shall apply to flame resistant garment fabrics, components, and hardware.

8.4.1.1 This test method shall apply to flame-resistant garment fabrics, components, hardware, and cold weather insulation materials.

8.4.1.2 Modifications to this test method for testing flame-resistant garment textile materials shall be as specified in 8.4.8.

8.4.1.3 Modifications to this test method for testing other flame-resistant garment materials, including reflective striping, shall be as specified in 8.4.9.

8.4.1.4 Modifications to this test method for testing hardware shall be as specified in 8.4.10.

8.4.1.5 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.4.11.

12. Revise subsections 8.4.2.1 and 8.4.3.1 through 8.4.3.3 to read as follows:

8.4.2.1 Only heat resistance testing shall be conducted on not fewer than three specimens for each hardware item, label material, and other flame-resistant garment fabrics, and cold weather insulation materials not listed in 8.4.2.2 and 8.4.2.3.

8.4.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3.

8.4.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after three cycles of dry-cleaning as specified in 8.1.4.

8.4.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3, after three cycles of dry-cleaning as specified in 8.1.4.

13. Delete existing subsection 8.4.8.2 and renumber 8.4.8.3 to 8.4.8.2 to read as follows:

8.4.8.2 Measurements of cold weather insulation material thermal shrinkage shall be made on the side of the fabric facing the wearer as used in the construction of the garment.

8.4.8.3 8.4.8.2 Testing shall be performed in accordance with 8.4.2 through 8.4.7.

14. Add new subsection 8.4.11 to read as follows:

8.4.11 Specific Requirements for Testing Cold Weather Insulation Materials.

8.4.11.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 50-cm × 20-cm (20-in. × 8-in.) panel of the cold weather insulation material. A similar-sized cloth piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0-oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric .

8.4.11.2 Following wash or dry-clean conditioning, 3 specimens measuring 152 mm × 152 mm (6 in. × 6 in.) shall be removed from the cold weather insulation material layer of the conditioned panel.

8.4.11.3 Testing shall be performed in accordance with 8.4.2 through 8.4.7, and thermal shrinkage shall not be measured.

Submitter’s Substantiation: The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out)

representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

 A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

 Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

 Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

 Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

 A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

 Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

 Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes

criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

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Public Input No. 50-NFPA 2112-2014 [ Section No. A.5.2.1 ]

A.5.2.1 The garment manufacturer should provide, at a minimum, the following instructions and information with each flame-resistant garment:

(1) Pre-use information

(2) Safety considerations (3) Limitations of use (4) Garment marking recommendations and restrictions (5) Warranty information

(6) Preparation for use

(7) Sizing/adjustment (8) Recommended storage practices

(9) Inspection frequency and details (10) Donning and doffing procedures (11) Proper use consistent with NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Short-Duration Thermal Exposures from Fire (12) Maintenance and cleaning

(13) Cleaning instructions and precautions (14) Maintenance criteria and methods of repair where applicable

(15) Retirement and disposal criteria

Statement of Problem and Substantiation for Public Input

Corrected the NFPA 2113 title in this section.

Submitter Information Verification

Submitter Full Name: Roger Parry Organization: The DuPont Company, Inc. Street Address: City: State: Zip: Submittal Date: Tue Jul 01 16:30:58 EDT 2014

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Public Input No. 13-NFPA 2112-2013 [ New Section after A.5.2.2 ]

A.6.4.1 Removable liners are permitted to be worn separately if the liner material(s) independently meets the appropriate fabric requirements in Chapter 7 including 7.1.1 for heat transfer performance and 7.1.5 for overall flash fire performance. If the liner contains cold weather insulation materials that are not evaluated to 7.1.1 and 7.1.5 and do not pass the thermal shrinkage resistance requirement in 7.1.3, then the manufacturer must label the liner as specified in 5.1.13 and provide a design that does not allow separate wearing of the liner without the outer layer. This may be demonstrated by the absence of a means of closure for the closure area of shirts, pants, and coveralls.

Additional Proposed Changes

File Name Description Approved Proposed_TIA_1105_2112_.docx Balloted TIA

Statement of Problem and Substantiation for Public Input

Note: This Public Input originates from Tentative Interim Amendment 2112-12-2 (TIA 1105) issued by the Standards Council on August 1, 2013.

The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out) representing a “worst case” exposure and

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wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

• A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

• Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

• Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

• Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

• A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

• Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

• Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not

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provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

Submitter Information Verification

Submitter Full Name: TC on FLG-AAA Organization: TC on Flash Fire Protective Garments Street Address: City: State: Zip: Submittal Date: Fri Sep 06 14:20:51 EDT 2013

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NFPA 2112®-2012 Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire TIA Log No. 1105 Reference: Various Comment Closing Date: June 14, 2013 Submitter: Jeffrey O. Stull, International Personnel Protection, Inc.

1. Revise 3.3.6, A.3.3.6, and 3.3.20, and add a new A.3.3.20 to read as follows:

3.3.6* Cold Weather Insulation Material. A fabric that consists of one or more nonseparable layers that is used for protection in a low-temperature environment. A cold weather insulation material is not an interlining (see interlining).

A.3.3.6 Cold Weather Insulation Material. Examples of insulation materials are include textile battings(s) alone or batting(s) that are attached to a face cloth. For example, an insulation material consisting of two layers are considered nonseparable by the attachment that combines the two layers. The insulation material may or may not have a face cloth. Cold weather insulation materials generally are provided within the garment such that their area of coverage coincides with the majority of garment area covering the wearer’s body. Cold weather insulation material as defined in this standard does not preclude the use of intermediate layers for additional protection against thermal hazards.

3.3.20* Interlining. Any textile that is incorporated into any garment as a layer between outer and inner layers that only covers a small portion of the overall garment. [1975, 2009]

A.3.3.20 Interlining. The outer and inner layers are compliant to the fabric requirements of this standard. Examples of an interlining are a fabric layer used to stiffen the waist band in a pair of pants or a facing fabric used inside the closure flap of a coverall. Interlining materials do not come in contact with the wearer’s skin or underclothing.

2. Revise subsections 5.1.2, 5.1.9(7), and 5.1.12, and add a new 5.1.13 to read as follows:

5.1.2 At least one product label shall be conspicuously located inside each flame-resistant garment. when the item is properly assembled with all layers and components in place.

5.1.9(7) Fiber content for each primary fabric layer including cold weather insulation materials, but excluding interlinings and labels.

5.1.12 Garments with multiple layers, including an outer layer and removable cold weather insulation layer, shall specify the certified wearable configurations on the label configuration and include a warning on the label stating that all layers must be properly secured and worn in accordance with the manufacturer’s instructions.

5.1.13 For garments with multiple layers that include an outer layer and a removable cold weather insulation layer, a label shall be conspicuously attached to the removable insulation layer that states “DO NOT WEAR THIS LINER BY ITSELF. FOR COMPLIANCE WITH THE FLASH FIRE REQUIREMENTS OF NFPA 2112, THE COMPLETE GARMENT MUST BE WORN. FOR COMPLIANCE INFORMATION, SEE THE PRODUCT LABEL ON OUTER GARMENT.”

3. Add new Section 6.4 and subsections 6.4.1, and A.6.4.1 to read as follows:

6.4 Use of a Liner for Cold Weather Insulation. Garments shall be permitted to include liners in their construction including cold weather insulation materials where the liner is either integral to the garment or removable.

6.4.1* Where garments incorporate a cold weather insulation material as part of a removable lining system, the garment shall be designed such that the removable liner consisting of the cold weather insulation material cannot be independently worn.

A.6.4.1 Removable liners are permitted to be worn separately if the liner material(s) independently meets the appropriate fabric requirements in Chapter 7 including 7.1.1 for heat transfer performance and 7.1.5 for overall flash fire performance. If the liner contains cold weather insulation materials that are not evaluated to 7.1.1 and 7.1.5 and do not pass the thermal shrinkage resistance requirement in 7.1.3, then the manufacturer must label the liner as specified in 5.1.13 and provide a design that does not allow separate wearing of the liner without the outer layer. This may be demonstrated by the absence of a means of closure for the closure area of shirts, pants, and coveralls.

4. Add new subsections 7.1.1.1 and 7.1.1.2 to read as follows:

7.1.1.1 Where the flame-resistant garment consists of multiple and separable layers intended to be worn separately, the outer layer and the inner layer or layers shall be separately tested.

7.1.1.2 Where the flame-resistant garment consists of multiple layers intended only to be worn together, only the outer layer shall be tested.

5. Revise subsections 7.1.2 and 7.1.3 to read as follows:

7.1.2 Fabric, cold weather insulation material, and reflective striping utilized in the construction of flame-resistant garments shall be tested for flame resistance as specified in Section 8.3, and shall have a char length of not more than 100 mm (4 in.) and an after-flame of not more than 2 seconds, and shall not melt and drip.

7.1.3 Fabric utilized in the construction of flame-resistant garments, excluding manufacturer’s labels, interlinings, and cold weather insulation materials, shall be individually tested for thermal shrinkage resistance as specified in Section 8.4, and shall not shrink more than 10 percent in any direction.

6. Delete existing subsection 7.1.3.1 as follows:

7.1.3.1 Cold weather insulation materials utilized in the construction of flame-resistant garments shall be tested in accordance with Section 8.4 and shall not shrink more than 20 percent in any direction.

7. Revise subsection 7.1.4 to read as follows:

7.1.4 Fabric, cold weather insulation materials, other textile materials, and reflective striping other than those items described in 7.1.4.1 and 7.1.4.2, used in the construction of flame-resistant garments shall be individually tested for heat resistance in their original form as specified in Section 8.4, and shall not melt and drip, separate, or ignite.

8. Add a new subsection 8.3.1.7 to read as follows:

8.3.1.7 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.3.13.

9. Revise subsections 8.3.3.1, 8.3.3.2, and 8.3.3.3 to read as follows

8.3.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3.

8.3.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after 100 cycles of dry cleaning as specified in 8.1.4.

8.3.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after 100 cycles of washing and drying as specified in 8.1.3, or after 100 cycles of dry cleaning as specified in 8.1.4.

10. Add new subsections to 8.3.13 to read as follows:

8.3.13 Specific Requirements for Testing Cold Weather Insulation Materials.

8.3.13.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 66-cm × 66-cm (26-in. × 26-in.) panel of the cold weather insulation material. A similar-sized piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0- oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric.

8.3.13.2 Following wash or dry-clean conditioning, 5 specimens measuring 75 mm × 300 mm (3 in. × 12 in.) from each of the warp and filling direction shall be removed from the cold weather insulation material layer of the conditioned panels.

8.3.13.3 If applicable, all specimens shall be prepared for testing by trimming the scrim material, batting, or other layer(s) away from the face cloth by 50 mm ± 3 mm (2.0 in. ± 1/8 in.) such that the face cloth can be folded back covering the scrim, batting, or other layer(s) by 50 mm ± 3 mm (2.0 in. ± 1/8 in.); the folded specimen shall be secured in the specimen holder.

8.3.13.4 Testing shall be performed as described in 8.3.2 through 8.3.7.

11. Revise subsection 8.4.1 and add new subsections 8.4.1.1 through 8.4.1.5 to read as follows:

8.4.1 Application. The heat and thermal shrinkage resistance test method shall apply to flame resistant garment fabrics, components, and hardware.

8.4.1.1 This test method shall apply to flame-resistant garment fabrics, components, hardware, and cold weather insulation materials.

8.4.1.2 Modifications to this test method for testing flame-resistant garment textile materials shall be as specified in 8.4.8.

8.4.1.3 Modifications to this test method for testing other flame-resistant garment materials, including reflective striping, shall be as specified in 8.4.9.

8.4.1.4 Modifications to this test method for testing hardware shall be as specified in 8.4.10.

8.4.1.5 Modifications to this test method for testing cold weather insulation materials shall be as specified in 8.4.11.

12. Revise subsections 8.4.2.1 and 8.4.3.1 through 8.4.3.3 to read as follows:

8.4.2.1 Only heat resistance testing shall be conducted on not fewer than three specimens for each hardware item, label material, and other flame-resistant garment fabrics, and cold weather insulation materials not listed in 8.4.2.2 and 8.4.2.3.

8.4.3.1 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be washed, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3.

8.4.3.2 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be dry-cleaned, specimens shall be tested before and after three cycles of dry-cleaning as specified in 8.1.4.

8.4.3.3 For fabrics and cold weather insulation materials that are designated on the flame-resistant garment label to be either washed or dry-cleaned, specimens shall be tested before and after three cycles of washing and drying as specified in 8.1.3, after three cycles of dry-cleaning as specified in 8.1.4.

13. Delete existing subsection 8.4.8.2 and renumber 8.4.8.3 to 8.4.8.2 to read as follows:

8.4.8.2 Measurements of cold weather insulation material thermal shrinkage shall be made on the side of the fabric facing the wearer as used in the construction of the garment.

8.4.8.3 8.4.8.2 Testing shall be performed in accordance with 8.4.2 through 8.4.7.

14. Add new subsection 8.4.11 to read as follows:

8.4.11 Specific Requirements for Testing Cold Weather Insulation Materials.

8.4.11.1 Samples for wash or dry-clean conditioning shall be prepared by cutting a 50-cm × 20-cm (20-in. × 8-in.) panel of the cold weather insulation material. A similar-sized cloth piece of 200-g/m2 to 270-g/m2 (6.0-oz/yd2 to 8.0-oz/yd2) flame-resistant fabric meeting all requirements of this standard shall be sewn around the perimeter of the cold weather insulation material such that the batting side is covered by the fabric .

8.4.11.2 Following wash or dry-clean conditioning, 3 specimens measuring 152 mm × 152 mm (6 in. × 6 in.) shall be removed from the cold weather insulation material layer of the conditioned panel.

8.4.11.3 Testing shall be performed in accordance with 8.4.2 through 8.4.7, and thermal shrinkage shall not be measured.

Submitter’s Substantiation: The current criteria in NFPA 2112-2012 are not workable to support the inclusion of cold weather insulation materials that provide safe and effective protection of flame resistant garments used for protection of workers against accident flash fires. Changes were made to the 2012 edition of NFPA 2112 without the benefit of a full validation effort. An effort intended to meet this purpose has now been completed by a task group under the direction of the Technical Committee where several prospective cold weather insulation materials were evaluated using existing and proposed test methods that included both current and modified flame resistance and heat/thermal shrinkage resistance testing. Additional evaluations were carried out using full scale manikin testing with garments incorporating the selected cold weather insulation materials in jackets of a simple design to assess effects of simulated flash fires on the clothing and insulation materials.

This effort produced the following two primary findings:

1. One of the cold weather insulation materials included in the investigation exhibited average afterflame times in excess of the 2-second requirement using the current flame resistance test procedures. When tested according to the proposed modified flame resistance test procedures, afterflame times were compliant or near compliant. In addition, the manikin-based testing for the same fabric exhibiting extended afterflame times, showed no unusual burning behavior during manikin testing of full garments where the liner consisted of the cold weather insulation material or showed shrinkage that differed radically from garments using materials that qualify to current NFPA 2112 performance criteria. Based on these findings, the modified flame resistance testing can be utilized for the evaluation of cold weather insulation materials.

It was observed that after flame times were observed to be generally shorter when a 50 mm folded edge was used as compared to a 25 mm folded edge. It was also rationalized that more consistent results would be provided with the 50 mm folded edge for the modified flame test because the specimen is positioned 19 mm into a 38 mm high flame leaving only a 6 mm space between the top of the flame and the beginning of the unprotected (by the folded edge) batting. It was therefore reasoned and consistent with the observed test results that the modified flame resistance test should use a 50 mm folded edge.

Specific changes to NFPA 2112 have been proposed in proposed modifications shown in Section 8.3.

2. Certain cold weather insulation materials exhibited significant distortion in heat/thermal shrinkage resistance testing and thermal shrinkage. Yet, these same materials when employed in the form of a liner in a flame resistant jacket utilizing a lightweight shell material did not show significant differences in their shrinkage (of the liner) with materials that would otherwise pass the NFPA 2112-2013 thermal shrinkage resistance criteria. This further included testing with the jacket samples inverted (turned inside out)

representing a “worst case” exposure and wearing configuration where no adverse safety issues were observed. From these results, the exemption of cold weather insulation materials from the thermal shrinkage resistance requirement can be justified. Specific changes to NFPA 2112 implementing these modifications are provided as in paragraphs 7.1.3, 7.1.3.1 (deletion), 7.1.4, and Section 8.4.

It is important to point out that the cold weather insulation material is required to meet a heat resistance requirement and is always covered by an outer (shell) material (paragraph 7.1.4). If it is not, it would not qualify as a cold weather insulation material. It is also important to point out that while these changes were based on testing that did not show any safety of the protective garment to be compromised when presented to a simulated flash fire, conditions may exist for which cold weather insulation materials (and other garment materials) will fail to provide intended levels of protection.

The following substantiations are proposed for the additional changes in this amendment to address cold weather insulation material definitions, labeling, design criteria, performance criteria, and test methods:

 A clarification was added to the definition of cold weather insulation material to indicate that the material is not an interlining. Additional language was also added to distinguish an interlining that is not tested for heat resistance or thermal shrinkage resistance from a cold weather insulation material, which is tested for heat resistance but not thermal shrinkage resistance (paragraphs 3.3.6, 3.3.20, A.3.3.6, and A.3.3.20).

 Additional labeling language was added to require the identification of the cold weather insulation material fiber content, the inclusion of a warning that garments with cold weather insulation materials must be properly secured and that a separate label must be provided on the liner if detachable, that indicates that the liner must not be worn by itself. These changes are covered in paragraph 5.1.2, 5.1.9, 5.1.12, and 5.1.13).

 Design criteria were added to permit garment with sewn-in or detachable liners that utilize cold weather insulation materials but that manufacturers must design removable liners so that the liner cannot be worn without the outer layer (paragraphs 6.4 and A.6.4).

 Changes were made in the performance criteria to clarify to which requirements cold weather insulation materials are tested (paragraphs 7.1.2, 7.1.3, and 7.1.4).

 A clarification was provided to specify that the cold weather insulation material is not tested for thermal protective performance (paragraphs 7.1.1.1 and 7.1.1.2).

 Specific procedures were added to address the modified testing of the cold weather insulation material as specified in U.S. Air Force purchase description NCTRF PD N2-01-3A, Batting, Quilted, Aramid, involving the removal of 50 mm of batting and folding of the face cloth over the remaining batting, as supported by the test information provided above (paragraph 8.3.1.7 and Section 8.3.13). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.3.13.1 and 8.3.13.2).

 Modifications for the heat and thermal shrinkage resistance test method were made to clarify that the cold weather insulation materials are not evaluated for thermal shrinkage resistance as supported by the test information above (paragraphs 8.4.1.1 through 8.4.1.5, paragraph 8.4.2.1, and section 8.4.11). Additional instructions were provided for preparing samples for conditioning by sewing a layer of flame resistant fabric to the cold weather insulation material prior to laundering with its removal following laundering or dry cleaning (paragraphs 8.4.3.1 through 8.4.3.3).

For supporting documentation see the doc info pages at www.nfpa.org/2112.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action. As currently written, NFPA 2112 includes

criteria that create a bias against cold weather insulation materials that is inconsistent with their use and in consistent with demonstrated levels of safety.

The OSHA interpretation of March 2010 encouraging employers to provide their employees with garments certified to a consensus standard like NFPA 2112 has created a need and demand for outerwear garments for cold weather protection that are certified to the NFPA 2112 standard. The current edition of the NFPA 2112 standard does not provide clear methods to properly test and certify garments that incorporate insulation for additional protection from cold weather.

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Public Input No. 51-NFPA 2112-2014 [ Section No. B.1 ]

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B.1 Test Properties and Methods.

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Table B.1 provides a description of the test properties and methods used for evaluating flame-resistant garments. A number of additional properties can be used in the evaluation of flame-resistant garments that are not required as part of this standard. Table B.1 also lists these additional properties, recommended test methods, and their suggested application. Table B.1 Performance Properties and Additional Evaluation Properties for Flame-Resistant Garments

Property Test Method Description of Test Method Application of Test Method (Section No.) Cited Mandatory Tests A 150 mm (6 in.) square fabric specimen is placed on a specimen holder that suspends the specimen horizontally over This test is a measure of the two Meker burners and a radiant panel. unsteady state heat transfer The heat and flame source is adjusted to properties of garment materials. provide an exposure heat flux of 84 The HTP test uses an exposure 2 2 kW/m (2.0 cal/cm · sec). A weighted heat flux that is representative of sensor containing a copper calorimeter is a JP4 (Jet Fuel) pool fire placed on top of the specimen and environment. NFPA 2112 measures the heat transfer through the requires that specimens have an specimen. A water-cooled shutter 2 HTP rating of 12.6 J/cm (3.0 between the specimen and heat source is 2 Heat transfer Method withdrawn to begin the exposure. The test cal/cm ) or more when performance appears in measures the amount of time with measured in “contact,” (HTP) (7.1.1) Section 8.2. continuous heating for heat breakthrough simulating direct contact with the resistance (using an arbitrary criterion of 2 2 skin, and 25 J/cm (6.0 cal/cm ) heat through the specimen to cause a or more when measured second-degree burn). This time is “spaced,” simulating an air gap multiplied by the exposure heat flux to between the skin and the provide an HTP rating. HTP ratings are garment material. Higher HTP measured with the sensor both in ratings indicate better unsteady “contact” with the specimen and “spaced” 1 state heat transfer performance 6 mm ( ⁄4 in.) away from the specimen. for this test but do not correlate Note that this test method does not result to improved predicted skin burn in a burn injury prediction. The heat injury performance. remaining in a test sample is not accounted for, which would otherwise contribute to a predicted skin burn injury. A 75 mm × 305 mm (3 in. × 12 in.) fabric specimen is placed in a holder that is 1 suspended vertically over a 38 mm (1 ⁄2 in.) high methane-fueled flame. The 3 ASTM D specimen is placed 19 mm ( ⁄4 in.) into This test is used to determine 6413; the flame for 12 seconds. After exposure how easily fabrics ignite and washing and to the flame, the amount of time during how easily they continue to burn drying per which the specimen continues to burn once ignited. In order to pass Flame commercial (after-flame) is recorded. The length of NFPA 2112, materials cannot resistance laundering the burn or char length is then measured have an average after-flame (7.1.2) procedure or by attaching a weight to the specimen time greater than 2 seconds, a dry cleaning and measuring the length of the tear char length greater than 102 mm (100 cycles) along the burn line. Observations are (4 in.), or any melting with (Section 8.3) recorded if any melting and dripping are dripping. observed. Samples are tested in this manner both before and after 100 wash/dry cycles or 100 dry cleaning cycles.

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Property Test Method Description of Test Method Application of Test Method (Section No.) Cited A 381 mm (15 in.) square fabric specimen A fabric's resistance to Method is marked for width and length shrinkage of a fabric when appears in dimensions and is then suspended in a exposed to heat is considered Section 8.4; forced air–circulating oven at 260°C important in minimizing the Thermal washing and (500°F). Following a 5-minute exposure, effects of a flash short duration shrinkage drying per the specimen dimensions are remeasured thermal exposure from fire. resistance commercial and then compared against the original NFPA 2112 permits shrinkage in (7.1.3) laundering measurements to determine the amount this laboratory-based test of 10 procedure or of shrinkage. The specimen is examined percent or less. Lower reported dry cleaning for evidence of melting, dripping, shrinkage indicates fabric that is (3 cycles) separation, or ignition. Specimens that more resistant to thermal demonstrate such behavior fail the test. shrinkage. The exposure used for thermal shrinkage This test measures how garment Method is also used for measuring heat fabrics and components react to appears in resistance. Fabrics or garment the high heat that could occur Section 8.4; components not required to meet thermal during a flash short duration washing and shrinkage requirements can be 152 mm Heat thermal exposure from fire. The drying per (6 in.) square specimens. Following a resistance purpose of the test is to prevent commercial 5-minute exposure, the specimen is (7.1.4/7.3) materials or components that laundering examined for evidence of melting and will easily ignite, melt, drip, or procedure or dripping, separation, or ignition. separate during exposure to dry cleaning Specimens that demonstrate such high heat from being used in (3 cycles) behavior fail the test. The test is also garments. applied to hardware items. The fabric is made into a standardized coverall design and placed on an This test provides an overall ASTM F instrumented manikin that is dressed in evaluation of how the fabric 1930; cotton underwear. The manikin is performs in a standardized washing and subjected to an overall flame and heat coverall design. NFPA 2112 drying per 2 exposure averaging 84 kW/m (2.0 requires a body burn prediction Manikin commercial 2 of 50 percent or less of the testing (7.1.5) laundering cal/cm · sec) for 3 seconds. Sensors surface area covered by sensors procedure or embedded in the manikin's skin predict (hands and feet are excluded). dry cleaning whether a second- or third-degree burn Lower percent body burn (1 cycle) will occur at that specific location. A predictions indicate greater (Section 8.5) computer program determines the protection provided by the fabric. percentage of the body that would sustain second- or third-degree burns. A small segment of thread used in the Thread used in flame-resistant stitching of station/work uniforms is garments must withstand placed in a flask containing an organic temperatures of up to 260°C Thread solvent and heated. (The solvent extracts FTMS 191A, (500°F). If the melting melting substances that would interfere with the 1534 (Section temperature is less than 260°C resistance test.) Next, the extracted thread segment 8.6) (500°F), the thread fails the test. (7.2) is put in a device that slowly heats the The temperature, 260°C thread. The temperature at which the (500°F), is consistent with the thread begins to melt is the melting heat resistance test. temperature. Method appears in Section 8.7; This requirement checks for Sample labels containing the required washing and label durability. Following this Label legibility product information are subjected to 100 drying per test, the labels must remain (7.4) wash/dry or dry cleaning cycles and then commercial legible from a distance of at examined for legibility. laundering least 305 mm (12 in.). procedure or dry cleaning

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Property Test Method Description of Test Method Application of Test Method (Section No.) Cited (100 cycles) Other Property Evaluations A known, specific area of fabric is weighed using a laboratory balance. The Fabric weights are commonly Fabric weight ASTM D 3776 measured fabric weight is divided by the used to reference materials. area of the fabric. This yields a fabric weight in ounces per square yard. In this test, a 102 mm × 204 mm (4 in. × 8 in.) fabric specimen is placed between the two grips of a tensile testing machine and Tensile strength is a pulled in the direction of the specimen's measurement that describes the Tensile long axis until it breaks. The force ease with which a woven strength (grab ASTM D 5034 measured at the site of the break is material can be pulled apart. method) reported as the tensile strength. Tensile Higher tensile strengths indicate strength is reported for both the warp greater fabric strength. (machine) and fill (cross-machine) directions of the fabric. In this test, a notched 102 mm × 204 mm (4 in. × 8 in.) material specimen is placed into a test device. The test device uses a Tear resistance is a pendulum that is allowed to fall by its own measurement of the ease with Tear strength weight. The force of the falling pendulum which a woven fabric can be (Elmendorf ASTM D 1424 tears the material beyond the notch. This torn apart. Higher tear strengths method) test measures the force in pounds that is indicate fabrics with greater required to continue a tear in the notched resistance to tearing. test specimen. Tear resistance is reported for both the warp (machine) and fill (cross-machine) directions of the fabric. This test measures the force required to Burst strength is a measure of burst a knit or stretch woven fabric. A how easily a knit fabric can be Material burst material specimen is clamped over a penetrated by a hard round ASTM D 3787 strength diaphragm that is inflated until the object. Higher burst strength specimen bursts. The pressure at which indicates fabrics that are more the fabric bursts is the burst strength. resistant to bursting. A fabric specimen, on which dimensions are marked and measured in both its AATCC 135; width and length, is subjected to a machine Laundering shrinkage is a specified number of separate wash/dry cycle 3; wash measure of the percentage a cycles under controlled conditions. temp. IV; and fabric shrinks after laundering. Laundering Following the washing and drying, the drying Shrinkage measured for a fabric shrinkage dimensions of the material sample are procedure Aiii is not necessarily representative compared to its original dimensions to (number of of shrinkage measured for a determine the amount of shrinkage. cycles to be garment. Shrinkage is reported in both the warp specified) (machine) and fill (cross-machine) directions of the fabric. A fabric sample is subjected to controlled Laundering colorfastness washing and drying conditions. Following assesses the amount of color exposure, the color of the material sample change, or fading, that occurs in AATCC 61; Laundering is compared to a color scale chart that the fabric following exposure to color change colorfastness indicates the degree of a color change. washing and drying. Fabrics with procedure Color scale ratings range from Grade 1 high color scale ratings are more (change in color) to Grade 5 (negligible or resistant to color changes in no change) in 0.5 increments. laundering.

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Property Test Method Description of Test Method Application of Test Method (Section No.) Cited A fabric sample is subjected to controlled Dry cleaning colorfastness dry cleaning conditions. Following assesses the amount of color exposure, the color of the material sample change, or fading, that occurs in Dry cleaning is compared to a color scale chart that the fabric following exposure to AATCC 132 colorfastness indicates the degree of a color change. dry cleaning solvents. Fabrics Color scale ratings range from Grade 1 with high color scale ratings are (change in color) to Grade 5 (negligible or more resistant to color changes no change) in 0.5 increments. in dry cleaning. In this test method, a fabric sample is Crocking colorfastness is a placed in a device against a white transfer measure of the amount of color cloth. The device rubs the fabric against or dye that is transferred from Crocking the transfer cloth. The amount of color the fabric by rubbing or AATCC 8 colorfastness that is transferred to the white transfer abrasion. Fabrics with high color cloth is assessed by a rating scale of scale ratings are more resistant Grade 1 to 5 in 0.5 increments (similar to to loss of color through rubbing laundering colorfastness). from wearing. A fabric specimen is placed in a weatherometer using a water-cooled xenon-arc lamp, which simulates intense Light colorfastness is a measure Light exposure to sunlight and humidity. The of the amount of color loss in a colorfastness, exposure test is conducted for a total of fabric due to extended exposure AATCC 16, continuous two weeks. Following the exposure, the to light. Fabrics with high color Option e xenon-arc fabric is compared to a color scale chart scale ratings are more resistant lamp exposure that indicates the degree of color change. to fading when exposed to Color scale ratings range from Grade 1 to outdoor light. 5 in 0.5 increments (similar to laundering colorfastness). The strength of a seam is measured in Seam efficiency compares the the same way as fabric tensile strength. strength of a seam to the fabric In this test, a garment seam specimen is that it joins. Higher seam placed between two grips in a tensile strength indicates stronger Seam testing machine and pulled in a direction ASTM D 1683 seams; however, seams that efficiency perpendicular to the seam line until it break in the fabric, as opposed breaks. The force to break the seam can to at the stitching or seam area, be compared to the force to break the are stronger than the fabric fabric by itself. The location of the break itself. in the specimen can also be reported.

Statement of Problem and Substantiation for Public Input

"Flash" fires, or vapor cloud fires are a very small subset of actual fire types experienced in industrial environments with fire hazards. The potential fires that exist can be in the form of pressurized flammable line breaks (jet fires), flammable liquid spills (pool and running pool fires), combustible dust, and fireballs (from Boiling Liquid Expanding Vapor Explosions or flammable material container BLEVE). Actual thermal exposures can be in the form of full or partial flame contact or engulfment and/or exposure to the radiant energy from a fire's flame emissive power (e.g., when a worker is not in contact with the flames but is escaping the hazard). The standard is better served by identifying thermal exposures to fire, which encompasses all of the noted hazards and fits with the established standard's Purpose (1.2.1).

Submitter Information Verification

Submitter Full Name: Roger Parry Organization: The DuPont Company, Inc. Street Address: City:

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State: Zip: Submittal Date: Tue Jul 01 16:32:56 EDT 2014

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Public Input No. 28-NFPA 2112-2014 [ Chapter C ]

Annex C Informational References C.1 Referenced Publications. The documents or portions thereof listed in this annex are referenced within the informational sections of this standard and are not part of the requirements of this document unless also listed in Chapter 2 for other reasons. C.1.1 NFPA Publications. National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169-7471. NFPA 1971, Standard on Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting, 2007 edition 2013 . NFPA 1977, Standard on Protective Clothing and Equipment for Wildland Fire Fighting, 2011 edition . NFPA 1991, Standard on Vapor-Protective Ensembles for Hazardous Materials Emergencies, 2005 edition . NFPA 1992, Standard on Liquid Splash-Protective Ensembles and Clothing for Hazardous Materials Emergencies, 2005 edition 2012 . NFPA 1999, Standard on Protective Clothing for Emergency Medical Operations, 2008 edition 2013 . NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire, 2012 edition 2015 . C.1.2 Other Publications. C.1.2.1 AATCC Publications. American Association of Textile Chemists and Colorists, P.O. Box 12215, Research Triangle Park, NC 27709. AATCC 8, Colorfastness to Crocking : AATCC Crockmeter Method, 2007 2013 . AATCC 16, Colorfastness to Light (option 3) , 2004. AATCC 61, Colorfastness to Laundering, Home and Commercial : Accelerated, 2009 2013 . AATCC 132, Colorfastness to Dry Cleaning, 2009 2013 . AATCC 135, Dimensional Changes of Fabrics After Home Laundering, 2004 2012 . C.1.2.2 ASTM Publications. ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959. ASTM D 1424, Standard Test Method for Tearing Strength of Fabrics by Falling Pendulum Type (Elmendorf) Apparatus, 2009, reapproved 2013 . ASTM D 1683/D 1683M , Standard Test Method for Failure in Sewn Seams of Woven Apparel Fabrics, 2007 2011A . ASTM D 3776/ D 3776M , Test Methods for Mass Per Unit Area (Weight) of Woven Fabric, 2009A, reapproved 2013 . ASTM D 3787, Standard Test Method for Bursting Strength of Textiles: Constant-Rate-of-Transverse (CRT) Ball Burst Test, 2007, reapproved 2011 . ASTM D 5034, Standard Test Method for the Breaking Strength Force and Elongation of Textile Fabrics (Grab Test), 2009, reapproved 2013 . ASTM D 6413/D 6413M , Standard Test Method for Flame Resistance of Textiles (Vertical Test), 2008 2013B . ASTM F 1731, Standard Practice for Body Measurements and Sizing of Fire and Rescue Services Uniforms and Other Thermal Hazard Protective Clothing, 1996 (Reaffirmed 2008 Rea pproved 2013 ). ASTM F 1930, Standard Test Method for Evaluation of Flame Resistant Clothing for Protection Against Flash Fire Simulations Using an Instrumented Manikin, 1998 (Reaffirmed 2008) 2013 .

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C.1.2.3 GSA Publications. U.S. General Services Administration, 1800 F Street, N.W., Washington, DC 20405. Method 1534, Melting Point of Synthetic Fibers, Federal Test Method Standard 191A, Textile Test Methods, July 20, 1978. C.1.2.4 ISO Publications. International Organization for Standardization, 1, rue de Varembé, Case postale 56, CH-1211, Geneve 20, Switzerland. ISO DIS 9000, Quality Management Systems — Fundamentals and Vocabulary, 2005 2014 . ISO DIS 9001, Quality Management Systems — Requirements, 2008 2014 . C.1.2.5 U.S. Government Publications. U.S. Government Printing Office, Washington, DC 20402. Title 21, Code of Federal Regulations, Part 7, Subpart C. C.2 Informational References. The following documents or portions thereof are listed here as informational resources only. They are not a part of the requirements of this document. C.2.1 ANSI Publications. American National Standards Institute, Inc., 25 West 43rd Street, 4th Floor, New York, NY 10036. ANSI Z34.1, American National Standard for Third-Party Certification Program for Products, Processes, and Services , 1993. C.2.2 Other Publications. Stoll, A. M., and M. A. Chianta, “Heat Transfer Through Fabrics as Related to Thermal Injury,” Transactions New York Academy of Sciences, Vol. 33(7), Nov. 1971, pp. 649–670. Stoll, A. M., and M. A. Chianta, “Method and Rating System for Evaluations of Thermal Protection,” Aerospace Medicine, Vol. 40, 1969, pp. 1232–1238. C.3 References for Extracts in Informational Sections. ( Reserved)

Statement of Problem and Substantiation for Public Input

Referenced current editions and titles.

Related Public Inputs for This Document

Related Input Relationship Public Input No. 27-NFPA 2112-2014 [Chapter 2] Referenced current editions and titles.

Submitter Information Verification

Submitter Full Name: Aaron Adamczyk Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Fri Jun 13 18:47:17 EDT 2014

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Public Input No. 52-NFPA 2112-2014 [ Section No. C.1.1 ]

C.1.1 NFPA Publications. National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169-7471. NFPA 1971, Standard on Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting, 2007 edition. NFPA 1977, Standard on Protective Clothing and Equipment for Wildland Fire Fighting, 2011 edition. NFPA 1991, Standard on Vapor-Protective Ensembles for Hazardous Materials Emergencies, 2005 edition. NFPA 1992, Standard on Liquid Splash-Protective Ensembles and Clothing for Hazardous Materials Emergencies, 2005 edition. NFPA 1999, Standard on Protective Clothing for Emergency Medical Operations, 2008 edition. NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Short-Duration Thermal Exposures from Fire, 2012 2015 edition.

Statement of Problem and Substantiation for Public Input

Corrected the NFPA 2113 title and edition.

Submitter Information Verification

Submitter Full Name: Roger Parry Organization: The DuPont Company, Inc. Street Address: City: State: Zip: Submittal Date: Tue Jul 01 16:35:39 EDT 2014

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Public Input No. 32-NFPA 2112-2014 [ Section No. C.1.2.2 ]

C.1.2.2 ASTM Publications. ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959. ASTM D 1424 D1424 , Standard Test Method for Tearing Strength of Fabrics by Falling Pendulum Type (Elmendorf) Apparatus, 2009 (2013) . ASTM D 1683 D1683/D1683M , Standard Test Method for Failure in Sewn Seams of Woven Apparel Fabrics, 2007 2011a . ASTM D 3776 D3776/D3776M , Test Methods for Mass Per Unit Area (Weight) of Woven Fabric, 2009 2009a (2013) . ASTM D 3787 D3787 , Standard Test Method for Bursting Strength of Textiles: Constant-Rate-of- Transverse (CRT) Ball Burst Test, 2007(2011) . ASTM D 5034 D5034 , Standard Test Method for the Breaking Strength Force and Elongation of Textile Fabrics (Grab Test), 2009 (2013) . ASTM D 6413 D6413/D6413M , Standard Test Method for Flame Resistance of Textiles (Vertical Test), 2008 2013a . ASTM F 1731 F1731 , Standard Practice for Body Measurements and Sizing of Fire and Rescue Services Uniforms and Other Thermal Hazard Protective Clothing, 1996 (Reaffirmed 2008 2013 ). ASTM F 1930 F1930 , Standard Test Method for Evaluation of Flame Resistant Clothing for Protection Against Flash Fire Simulations Using an Instrumented Manikin, 1998 (Reaffirmed 2008) 2013 .

Statement of Problem and Substantiation for Public Input

date updates

Submitter Information Verification

Submitter Full Name: Marcelo Hirschler Organization: GBH International Street Address: City: State: Zip: Submittal Date: Sat Jun 28 18:27:19 EDT 2014

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Public Input No. 68-NFPA 2112-2014 [ Section No. C.1.2.2 ]

C.1.2.2 ASTM Publications. ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959. ASTM D 1424, Standard Test Method for Tearing Strength of Fabrics by Falling Pendulum Type (Elmendorf) Apparatus, 2009 09(2013) . ASTM D 1683/D1683M , Standard Test Method for Failure in Sewn Seams of Woven Apparel Fabrics, 2007 2011a . ASTM D 3776/D3776M , Test Methods for Mass Per Unit Area (Weight) of Woven Fabric, 2009 2009a(2013) . ASTM D 3787, Standard Test Method for Bursting Strength of Textiles: Constant-Rate-of-Transverse (CRT) Ball Burst Test, 2007(2011) . ASTM D 5034, Standard Test Method for the Breaking Strength Force and Elongation of Textile Fabrics (Grab Test), 2009 09(2013) . ASTM D 6413/D6413M , Standard Test Method for Flame Resistance of Textiles (Vertical Test), 2008 2013b . ASTM F 1731, Standard Practice for Body Measurements and Sizing of Fire and Rescue Services Uniforms and Other Thermal Hazard Protective Clothing, 1996 (Reaffirmed 2008 2013 ). ASTM F 1930, Standard Test Method for Evaluation of Flame Resistant Clothing for Protection Against Flash Fire Simulations Using an Instrumented Manikin, 1998 (Reaffirmed 2008). 2013

Statement of Problem and Substantiation for Public Input

Update the year date for standard(s)

Submitter Information Verification

Submitter Full Name: Steve Mawn Organization: ASTM International Street Address: City: State: Zip: Submittal Date: Mon Jul 07 14:21:01 EDT 2014

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