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Letter to All Respirator Manufacturers
December 08 , 2006
Subject: NIOSH NPPTL and NFPA Joint Approval Process for NFPA
1981 2007 Edition Respirator Approvals
Background:
The changes to the NFPA 1981 2007 edition require NIOSH CBRN approval
as a component of NFPA 1981 approval. The NIOSH CBRN Statement of Standard
for CBRN approval for SCBA devices requires NFPA 1981 approval as a component
of the CBRN SCBA approval. The combined effect of these two standards
is NFPA compliance and NIOSH CBRN compliance approvals must be issued
jointly.
Due to scheduling challenges with the August 31, 2007 stop labeling
date for NPPA 1981 2002 labels NIOSH is modifying the application process
for submitting approvals for Title 42, Code of Federal Regulations, Part
84 (42 CFR Part 84), NIOSH CBRN and NFPA 1981 2007 as follows.
Process:
The NIOSH CBRN Approval Process has three components, a NIOSH 42 CFR
Part 84, a NFPA 1981 compliance certification, and a NIOSH CBRN approval
including RDECOM live agent testing.
The NIOSH 42 CFR Part 84 approval must be obtained before the NFPA 1981
2007 and NIOSH CBRN approvals will be granted. NIOSH CBRN approval applications
and NFPA 1981 2007 applications will be accepted at the same time as
42 CFR Part 84 approvals. If a CBRN approval and a NFPA 1981 2007 approval
are submitted at the same time as the 42 CFR Part 84 approval, NIOSH
CBRN testing and NFPA 1981 certification testing will be initiated on
devices that have not completed a 42 CFR Part 84 approval as time and
resources permit.
When manufacturers submit NIOSH 42 CFR part 84 approvals along with
NIOSH CBRN approvals and NFPA 1981 approvals, NIOSH, as time and resources
permit, will begin CBRN testing including submitting units to RDECOM
for live agent testing and notify SEI of the progress of approval testing.
SEI will notify NIOSH of the start and progress of NFPA 1981 compliance
testing. NIOSH and SEI will inform the other party and the manufacturer
in the event of a test failure. Both NIOSH and SEI reserve the right
to stop all further testing at the time of failure of either testing
requirements. Upon the request of the manufacturer, and depending on
the availability of resources, testing at either NIOSH or SEI may continue
for data generating purposes. The decision of the laboratory on whether
or not to continue testing after a failure is final.
Manufacturers may still request prototype or correlation testing on
devices without 42 CFR Part 84 approvals.
Manufacturers have two options for NFPA 1981/NIOSH CBRN joint approvals
on devices holding 42 CFR Part 84 approvals. They may initiate NFPA 1981
compliance certification first with NIOSH CBRN testing taking place in
sequence after NFPA certification. In this option, NFPA 1981 compliance
certification will not be issued until the NIOSH CBRN approval testing
is successfully completed and NIOSH CBRN testing will not begin until
NFPA compliance certification testing is successfully completed.
The second option is the manufacturer may simultaneously apply for NFPA
1981 compliance certification testing and NIOSH CBRN approval testing
on devices holding 42 CFR Part 84 approvals. NIOSH will begin CBRN testing
including submitting units to RDECOM for live agent testing and notify
SEI of the progress of approval testing. SEI will notify NIOSH of the
start and progress of NFPA 1981 compliance testing. NIOSH and SEI will
inform the other party and the manufacturer in the event of a test failure.
Both NIOSH and SEI reserve the right to stop all further testing at the
time of failure of either testing requirements. Upon the request of the
manufacturer, and depending on the availability of resources, testing
at either NIOSH or SEI may continue for data generating purposes. The
decision of the laboratory on whether or not to continue testing after
a failure is final.
The testing flow chart for the second option is attached.
Under the second option both NIOSH CBRN and NFPA 1981 compliance will
be issued upon completion of both testing requirements.
Sincerely yours,
Heinz W. Ahlers
Chief, Technology Evaluation Branch
National Personal Protective Technology Laboratory
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