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OSHA 1910SubpartLAppD

Publications for fire brigades

Subpart L

14 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.156(e)(3)(ii), which publication is incorporated by reference for protective clothing for structural firefighting?

Under 1910.156(e)(3)(ii) the incorporated publication is NFPA No. 1971 (1975), titled "Protective Clothing for Structural Fire Fighting." This publication is listed as the principal source for the criteria and test methods used to determine whether protective clothing provides the level of protection required for interior structural firefighting; see 1910.156(e)(3)(ii) and 1910 Subpart L Appendix D.

Under 1910.156(e)(4)(i), what publication is referenced for fire fighter glove test methods and where can I get it?

Under 1910.156(e)(4)(i) the referenced publication is "Development of Criteria for Fire Fighter's Gloves; Vol. II, Part II: Test Methods" (1976), and it is available from the U.S. Government Printing Office (GPO). The Appendix lists the GPO address and the Stock No. for Vol. II as 071-033-0201-1; see 1910.156(e)(4)(i) and 1910 Subpart L Appendix D.

Under 1910.156(e)(5)(i), what publication is incorporated for firefighter helmet performance and who publishes it?

Under 1910.156(e)(5)(i) the incorporated publication is "Model Performance Criteria for Structural Firefighter's Helmets" (1977), and it is available from the U.S. Fire Administration, National Fire Safety and Research Office. See 1910.156(e)(5)(i) and 1910 Subpart L Appendix D for the citation.

Under 1910 Subpart L Appendix D, am I required to purchase copies of the publications incorporated by reference in 1910.156?

No, employers are not required to purchase copies of the publications incorporated by reference. The Appendix states employers may specify in purchase orders that protective clothing meet the criteria and test methods in the referenced publications and may rely on manufacturers' assurances of compliance, although an employer may choose to obtain copies for its own information; see 1910 Subpart L Appendix D and 1910.156.

Under 1910.156, do the incorporated publications become mandatory requirements for protective clothing used in interior structural firefighting?

Yes, the incorporated publications provide the criteria and test methods that the standard uses to determine required protection, so meeting those criteria is mandatory for protective clothing intended for interior structural firefighting under 1910.156. The Appendix explains these publications are the chief sources of information for that determination; see 1910.156 and 1910 Subpart L Appendix D.

Under 1910 Subpart L Appendix D, how can an employer document compliance in a purchase order when they don't buy the referenced publications?

Under 1910 Subpart L Appendix D an employer can document compliance by specifying in the purchase order that the protective clothing must meet the criteria and test methods contained in the referenced publications and by obtaining the manufacturer's written assurances of compliance. The Appendix explicitly allows relying on manufacturers' assurances while noting employers may still obtain copies for their records; see 1910 Subpart L Appendix D.

Where can I review the publications incorporated by reference in 1910.156 if I don't want to buy them?

You can review the referenced publications (or microfiche) at many universities and public libraries, at the OSHA Technical Data Center (Room N2439-Rear, U.S. Department of Labor, 200 Constitution Ave., N.W., Washington, D.C. 20210; phone 202-219-7500), or at any OSHA Regional Office; see 1910 Subpart L Appendix D for these availability details.

Under 1910.156(e)(3)(ii), who is listed as the source to obtain NFPA No. 1971 (1975)?

Under 1910.156(e)(3)(ii) the National Fire Protection Association (NFPA), Batterymarch Park, Quincy, MA 02269, is listed as the source for NFPA No. 1971 (1975) "Protective Clothing for Structural Fire Fighting." See 1910.156(e)(3)(ii) and 1910 Subpart L Appendix D.

Does Appendix D to Subpart L explain why OSHA incorporated external publications by reference into 1910.156?

Yes, Appendix D explains OSHA incorporated those external publications because they provide the criteria and test methods for protective clothing for interior structural firefighting and serve as the chief sources for determining whether protective clothing affords the required level of protection under 1910.156; see 1910 Subpart L Appendix D and 1910.156.

If a manufacturer certifies that its turnout gear meets NFPA 1971 criteria, can an employer accept that without additional testing?

Yes, Appendix D allows employers to rely on manufacturers' assurances that the protective clothing meets the referenced criteria and test methods rather than purchasing the publications or conducting independent testing, provided the employer's procurement documents specify that the gear must meet those criteria; see 1910 Subpart L Appendix D and 1910.156.

Are microfiche copies of the publications mentioned in 1910 Subpart L Appendix D available for public review?

Yes, Appendix D states that the referenced publications (or a microfiche of the publications) are available for review at many universities and public libraries, in addition to OSHA facilities, so microfiche copies can be examined without purchasing the originals; see 1910 Subpart L Appendix D.

Under 1910.156, what part of firefighter protective equipment do the incorporated publications primarily address?

Under 1910.156 the incorporated publications primarily address protective clothing and components used by fire brigade members expected to perform interior structural firefighting, including structural firefighting garments, gloves, and helmets; see 1910.156 and 1910 Subpart L Appendix D.

If I need the GPO stock number for the fire fighter glove test methods referenced in 1910.156(e)(4)(i), where is it listed?

The GPO Stock No. for "Development of Criteria for Fire Fighter's Gloves; Vol. II, Part II: Test Methods" (1976) referenced in 1910.156(e)(4)(i) is listed in Appendix D as 071-033-0201-1; see 1910.156(e)(4)(i) and 1910 Subpart L Appendix D.

Under 1910 Subpart L Appendix D, can state-plan OSHA offices or regional OSHA offices help me access the referenced publications?

Yes, Appendix D states the referenced publications may be examined at any OSHA Regional Office, and the OSHA Technical Data Center is also listed as a point of access for review; see 1910 Subpart L Appendix D.