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• Step 3 – Report on Comments (ROC). Once the ROP is released, the period for public comment is open. No new proposals can be submitted, but the proposals that were acted on by the TC can be addressed on a comment form and submitted to the TC for review and action. The letter-ballot by the TC does not mean a proposal is complete. The public can request with substantiation the reason for the revision to be revisited. For example, the public may ask that a deleted item be returned to the standard or the public comments may ask for items to be removed. Minor changes in wording for syntax or grammar also are considered.
The TC convenes to review and act on each public comment. Each comment is voted on in terms of the actions by the committee: accept, reject, accept in principle, accept in part and accept in principle and in part. With the exception of the committee vote to accept, the TC must substantiate the reason for voting. This will become part of the ROC record. This vote is a simple-majority vote made by the members of the committee present that lets the item move to a letter-ballot. It is not necessarily a reflection of the committee to accept the revision at this time. The letter-ballot is sent to all members of the committee after the ROC meeting is completed.
As part of the letter-ballot, TC members are balloted to accept, reject, accept in principle, accept in part or accept in principle and in part. With the exception of the committee vote to accept, the TC members must also substantiate the reason for voting.
Before the results of this phase of the cycle are published, the Technical Correlating Committee (TCC) is convened to review and verify that there is no overlap between standards that would cause significant impact to the documents. The TCC then conducts a letter-ballot with a three-quarters majority required vote to accept, reject, accept in principle, accept in part or accept in principle and in part. With the exception of the committee vote to accept, the TCC must also substantiate the reason for voting.
The actions, simple-majority vote and two-thirds-majority letter-ballot vote by the TC, and the actions and letter-ballot vote by the TCC, are all published as part of the ROC and made public on the NFPA website and in print. Anyone submitting a proposal receives a printed copy of the results.
• Step 4 – Technical Committee Reports (TCR) Session. At the NFPA Conference each June, the TCR can be submitted with certified motions, representing another opportunity for a standards document to be revised based on motions presented prior to the convening of the conference. This is accomplished by the submitter filing for a Notice of Intent to Make a Motion (NITMAM) to be submitted to the NFPA. The Motions Committee of the Standards Council reviews and certifies the motion. The motions can only be on the items based on the ROP and ROC. There are limitations as to who can make a motion. The motion is placed on the agenda and anyone can speak to the issue. The vote is made by the NPFA general membership present. Successful motions are then letter-balloted through the respective TCs and TCCs.
• Step 5 – Standards Council Issuance. All the steps previously outlined are documented and written in a way that reflects the concerns of all who participate in the process. From the proposals that are submitted by the individual or organization, the substantiations, the letter-balloting, the publications and the public comments become part of a public document transparent for all to see. Appeals can be made to the Standards Council if someone believes the process was not followed. Once the appeals are heard and acted on, the Standards Council issues the standard. The standard is published with all the revisions and the cycle is complete.
While the process appears to be complex and detailed, it is understood that this process is valid. NFPA codes and standards have saved lives and property. Unfortunately, many times, the fire service does not take advantage of the process until the document is validated and final. When standards affecting you are due for revision, get involved in the process. Write proposals. Suggest changes. Add, delete. Become acutely aware of the timing of both proposals and public comment periods. When the document is released for public comment and the proposal you submitted is rejected, write a comment. This will ensure that the TC has given thoughtful consideration to your suggestion. Additionally, consider volunteering to sit on a Technical Committee.