Jason Faryniak

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.