Protective clothing for aircraft firefighting

April 3, 1997
Mr. George W. Siebert
ODUSD (ES) SH
Department of Defense
[Recipient address omitted]
Dear Mr. Siebert:
The attached memorandum from the Commander In Chief, United States Pacific Fleet, regarding a waiver on Aluminized Proximity Protective Clothing for Aircraft Firefighting, NAVAIR 00-80R-14 has come to our attention. This letter is to correct a misunderstanding and avoid further confusion on this area.
The memo states in paragraph 2 that "the OSHA position is that changes in design materials of structural firefighting clothing have resulted in state-of-the-art gear that provides equal or greater protection than that afforded by crash rescue suits and that OSHA has approved the use of structural protective clothing meeting the requirements of 29 CFR 1910.156(e) (NFPA Standard 1971) for both structural and airport crash rescue firefighting."
This statement is misleading and the memorandum that the paragraph refers to was written as a specific response to a 1990 question from OSHA Region 3 regarding citations issued to the U.S. Army Transportation Command at Fort Eustis, Virginia and to the U.S. Navy at the Oceania Air Station. In that response, OSHA did not approve the use of structural gear for aircraft firefighting, OSHA stated that the employer would not be cited for using structural gear for aircraft crash response (copy of memo attached). The issue was stated that way at the time because no consensus standard existed that addressed aircraft crash and rescue protective equipment and OSHA had no basis to issue a general duty citation for failure to provide aluminized proximity protective clothing. In 1992, the National Fire Protection Association promulgated NFPA 1976 Standard on Protective Clothing for Proximity Firefighting which does address the issue and which requires aluminized proximity protective clothing for aircraft firefighting. Since there is now a consensus standard for aircraft firefighting, that earlier memorandum is no longer valid and an employer may be cited for failure to follow NFPA 1976.
Please advise DOD agencies and CINCPAC that any agency that fails to follow the equipment and other requirements of NFPA 1976 for aircraft firefighting will be subject to OSHA citation.
Should you have any further questions, [please contact 202-693-2122].
Thank you in advance for your quick action.
Sincerely,
John E. Plummer, Director
Office of Federal Agency Programs
[Corrected 1/17/03]

[Navy memorandum reproduced on OSHA page; omitted here.]