Are you having trouble navigating the path to get your product into the NFPA 2112 or NFPA 70E market? Different conformity assessment requirements between the NFPA 2112 (2012) and NFPA 70E (2015) standards can make the testing process confusing for those working with industrial FR and arc rated products in the U.S. We are commonly asked:
- What is each standard used for?
- Does meeting one standard mean my product meets the other?
- Who deems my product compliant?
- I’ve passed all the tests for NFPA 2112- can I label my product compliant?
- If I’m a garment manufacturer using compliant, certified components, am I compliant?
In this article, we will answer these questions and break down the processes for you.
NFPA 2112 is a standard for clothing used as protection from the industrial flash fire hazard: think petrochemical and oil and gas industries. NFPA 70E is for clothing used as protection from the thermal hazards of an electric arc. The hazards are similar as they are both industrial hazards of accidental exposure; however, it is important to recognize that compliance with one standard does not necessarily mean compliance with the other. To market for each hazard you must test (and in the case of NFPA 2112, certify) for each hazard, and the processes and testing are different for each standard.
Testing and Conformity Assessment
NFPA 2112 is relevant to both components and the finished garment; each piece must be evaluated by the certification body for compliance. For NFPA 70E/ASTM F1506, most of the requirements are based around the fabric. There are a few additional requirements for garments (mostly design), but there is no requirement to test a finished garment. NFPA 70E does say that a garment must be doffable following an arc event, so some manufacturers choose to test at the garment level (ASTM F2621) to go a step further as due dilligence.
Further, different conformity assessment processes are used by each standard; in other words, how the manufacturer or a third-party deems a product to be compliant.
NFPA 70E is a self-declaration standard. This means that a manufacturer can test products themselves (either in-house or out-of-house) and declare themselves compliant and label products as such. The testing required for NFPA 70E is outlined by ASTM F1506 for materials or ASTM F1891 for rainwear– both are specifications written mostly around materials. There is no requirement in the U.S. to test a finished garment for the electric arc hazard, though some manufacturers choose to do this as due diligence. There are also no accreditation requirements in NFPA 70E, ASTM F1506, or ASTM F1891: ISO 9001 is not required for manufacturers and data obtained from testing laboratories is not required to be ISO 17025 accredited. In fact, there are no third-party requirements at all. Some manufacturers choose to use a third-party laboratory upon customer request or internal requirements. At the end of the day, if a manufacturer is labeling a product compliant to NFPA 70E, ASTM F1506, or ASTM F1891, it is their responsibility to maintain the data proving compliance with the standard and to issue declarations of conformance. Periodic retesting is required by the standard and should be performed by the manufacturer.
Can we do better? Conformity assessment is a hot topic in the industry, and there are a few initiatives out to streamline the conformity assessment process of Personal Protective Equipment (PPE) in the U.S. ANSI/ISEA 125 was released in 2014, and efforts are currently underway in ASTM. The Proposals have been made to add ANSI/ISEA 125 to both NFPA 70E and NFPA 2112. The proposals have not been approved for publication and will be discussed at the technical committees, but recommendations have been submitted to allow manufacturers the flexibility to comply with ANSI/ISEA 125 Levels 1, 2, or 3. We will keep our readers notified of updates as they come.
NFPA 2112 requirements are more stringent and third-parties are involved. An accredited laboratory and third-party certification body must be used, and all work is carried out with oversight of the certification body.
To be compliant, a third-party accredited to ISO 17065 with NFPA 2112 on their scope MUST CERTIFY your product (for example, the Safety Equipment Institute or Underwriter’s Laboratories). This includes site audits and ISO 17025 third-party accredited testing. The requirements are ongoing, and the auditors will check the quality management system and pull random samples to be sent for testing. ISO 9001 registration is not required for compliance with NFPA 2112, but it does make the process easier. While the process is stringent, the end result is that upon completion of certification, the manufacturer is permitted to label the product with the certification organization’s mark. Certification organizations maintain listings online of certified products and components–this is a helpful tool to use if you need to verify a product’s compliance. Figure 1 demonstrates the general flow of the NFPA 2112 certification process; note that the cost, timeline, and process is a bit different for every participant, as many variables are considered in the process of certification (design of each product, number of facilities for auditing, etc.).
Testing alone is not sufficient to label compliance with NFPA 2112. Further, using certified components does NOT mean your garment is certified. While using certified components does simplify the process, third-party certification is still required at the garment level.
The concept behind component recognition can be applied to most standards, but you typically hear the term in reference to third-party certification (like NFPA 2112). Consider this example: You are a garment manufacturer and you are using three suppliers for components to construct your garment: thread, closures, and fabric. Your fabric supplier went through the NFPA 2112 certification process for their style XYZ fabric (testing, audits, certification body stamp of approval). You can verify the third-party certification by checking the certification body’s listing of certified products online or by asking the manufacturer for the report from the certification body. If you use this fabric, you theoretically would not have to retest it as the garment manufacturer, but there’s a catch: Not all certification bodies accept each other’s data. If you are a garment manufacturer, you can choose which certification body will work best for you. If you are supplying components, ask your garment manufacturer which certification body they work with; you don’t want to be forced to retest if the garment manufacturer’s certification body won’t accept your certification data.
If you are interested in evaluations to either NFPA 70E or NFPA 2112, our staff can assist with our FlashCert services. If we haven’t covered your question, we want to hear from you! Comment or reach out to get answers from our experts.