In regards to the revised regulations, the following sentence is of concern: "Based
upon this research, the FHWA believes that the PPE for firefighters specified in
the NFPA 1971 standard is equivalent to the ANSI 107-2004 Class 2 garment."
Some within the firefighting community have interpreted this to mean that as long
as a firefighter is wearing PPE that meets NFPA 1971 they have met the
regulations of 23 CFR 634, regardless of whether a firefighter is exposed to a
hazardous situation.
I believe the intent of the FHWA is to deem PPE meeting NFPA 1971 as
adequate for hazardous situations but not for all situations - that the wearing of an
ADDITIONAL ANSI 206-2007 or Class 2 & 3 ANSI 107-2004 garment would be
required when a firefighter was not exposed to a hazardous situation.
Some firefighters believe that since they have PPE meeting NFPA 1971, they will
be meeting the regulations of 23 CFR 634 during any operation on a federally-
funded roadway when this PPE is worn and that a vest is no longer necessary, as
the FHWA just stated that their PPE is EQUIVALENT to a Class 2 ANSI 107-
2004 garment, required by the standard. This should be further clarified to avoid
confusion. All emergency workers wearing PPE meeting NFPA 1971 should also
be wearing an additional ANSI 206-2007 or Class 2 / 3 ANSI 107-2004 when a
hazardous situation is not encountered in a federally funded roadway.
Related Comments
Total: 2
Anonymous Public SubmissionPosted: 11/24/2008
ID: FHWA-2008-0157-0002
Jason Faryniak Public SubmissionPosted: 11/24/2008
ID: FHWA-2008-0157-0003
Jason Faryniak
This is comment on Rule
Worker Visibility
View Comment
Related Comments
Public Submission Posted: 11/24/2008 ID: FHWA-2008-0157-0002
Public Submission Posted: 11/24/2008 ID: FHWA-2008-0157-0003