1. #26
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    Another money grab by the "corporate members" of the NFPA.
    I am now a past chief and the views, opinions, and comments are mine and mine alone. I do not speak for any department or in any official capacity. Although, they would be smart to listen to me.

    "The last thing I want to do is hurt you. But it's still on the list."

    "When tempted to fight fire with fire, remember that the Fire Department usually uses water."

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    Quote Originally Posted by ChiefKN View Post
    Another money grab by the "corporate members" of the NFPA.
    Wake up, Chief. The "corporate members" don't write the standards.
    "Nemo Plus Voluptatis Quam Nos Habant"

    The Code is more what you'd call "guidelines" than actual rules.

  3. #28
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    Quote Originally Posted by DeputyMarshal View Post
    Wake up, Chief. The "corporate members" don't write the standards.
    (yawn)

    They are on the committee.

    Its an older list, and I took out some of the non-corporate members, just to shorten the post.

    http://www.nfpa.org/assets/files/pdf/ComList.pdf

    Fire and Emergency Services Protective Clothing and
    Equipment

    FAE-AAC
    Bruce W. Teele
    Technical Correlating Committee
    Staff Liaison:
    Chair
    Richard M. Duffy [L]
    International Association of Fire Fighters 1750 New York Avenue,
    NW Washington, DC 20006 Rep. IAFF

    Secretary
    William M. Lambert [M]
    Mine Safety Appliances Company PO Box 426 Pittsburgh, PA
    15230 Rep. CGA Principal

    Leslie Anderson [E]
    The DuPont Company 5401 Jefferson Davis Highway Richmond,
    VA 23234

    Nicholas J. Curtis [M]
    Lion Apparel, Inc. 6450 Poe Avenue, Suite 300 Dayton, OH
    45413-0576

    Robert A. Freese [M]
    Globe Manufacturing Company 37 Loudon Road PO Box 128
    Pittsfield, NH 03263-0128

    Bill Grilliot [M]
    Morning Pride Manufacturing, LLC #1 Innovation Court PO Box
    13616 Dayton, OH 45413-0616 Rep. FEMSA

    William E. Haskell [U]

    Fire & Industrial (P.P.E) Ltd. Rose Farm, Chapel Road Necton,
    Norfolk PE37 8JA England

    Jim Minx [C]

    Safety Equipment Institute (SEI) 1307 Dolley Madison Blvd.,
    Suite 3A McLean, VA 22101

    Denise N. Statham [M]
    Southern Mills, Inc. 6501 Mall Boulevard PO Box 289 Union City,
    GA 30291

    Jeffrey O. Stull [SE]
    International Personnel Protection, Inc. 10907 Wareham Court
    Austin, TX 78739

    David Trivette [M]
    Tyco/Scott Health & Safety Monroe Corporate Center PO Box 569
    Monroe, NC 28111 Rep. ISEA

    Robert D. Tutterow [U]
    Underwriters Laboratories Inc. 12 Laboratory Drive PO Box 13995
    Research Triangle Park, NC 27709-3995

    Alternate
    Janice C. Bradley [M]
    International Safety Equipment Association 1901 North Moore
    Street Arlington, VA 22209 Rep. ISEA Alt. to D. Trivette

    Gregory S. Copeland [M]
    Celanese AG 2300 Archdale Drive Charlotte, NC 28210 Alt. to
    R. W. Blocker

    Patricia A. Freeman [M]
    Globe Manufacturing Company 37 Loudon Road Pittsfield, NH
    03263 Alt. to R. A. Freese

    Patricia A. Gleason [RT]
    Safety Equipment Institute (SEI) 1307 Dolley Madison Blvd.,
    Suite 3A McLean, VA 22101 Alt. to S. R. Sanders

    Mary I. Grilliot [M]
    TFG/Morning Pride Manufacturing L.L.C. #1 Innovation Court PO
    Box 13616 Dayton, OH 45413-0616 Rep. FEMSA Alt. to B.
    Grilliot

    Steven B. Lumry [C]
    Lion Apparel, Inc. 219 Archer's Mead Williamsburg, VA 23815
    Alt. to N. J. Curtis



    SCOPE:
    This Committee shall have primary responsibility for documents
    on the design, performance, testing, and certification of protective
    clothing and protective equipment manufactured for fire and
    emergency services organizations and personnel, to protect
    against exposures encountered during emergency incident
    operations. This Committee shall also have the primary
    responsibility for documents on the selection, care, and
    maintenance of such protective clothing and protective
    equipment by fire and emergency services organizations and
    personnel.
    This Committee has jurisdiction over the following documents:
    PROPOSED Selection, Care and Maintenance (SCAM) of
    Structural Fire Fighting Protective Ensemble Elements (NFPA
    1851), PROPOSED Selection, Care, and Maintenance of
    Open-Circuit SCBA (NFPA1852), (PROPOSED) Protective
    Ensemble for Urban Technical Rescue Incidents (NFPA 1951),
    Protective Ensemble for Structural Fire Fighting (NFPA 1971),
    Station/Work Uniforms for Fire Fighters (NFPA 1975), Protective
    Ensemble for Proximity Fire Fighting (NFPA 1976), Protective
    Clothing and Equipment for Wildland Fire Fighting (NFPA 1977),
    Open-Circuit Self-Contained Breathing Apparatus for the Fire
    Service (NFPA 1981), Personal Alert Safety Systems (PASS)
    (NFPA 1982), Standard for Closed-Circuit SCBA for Fire Fighters
    (NFPA 1984), PROPOSED Breathing Air Quality for Fire
    Emergency Service Respiratory Protection (NFPA 1989), Fire
    Service Life Safety Rope and System Components (NFPA 1983),
    Vapor-Protective Ensembles for Hazardous materials Emergencies
    (NFPA 1991), Liquid Splash-Protective Clothing and Ensembles
    for Hazardous Materials Emergencies (NFPA 1992), Protective
    Ensembles for Chemical or Biological Terrorism Agents (NFPA
    1994), Protective Clothing for Emergency Medical Operations
    I am now a past chief and the views, opinions, and comments are mine and mine alone. I do not speak for any department or in any official capacity. Although, they would be smart to listen to me.

    "The last thing I want to do is hurt you. But it's still on the list."

    "When tempted to fight fire with fire, remember that the Fire Department usually uses water."

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    Quote Originally Posted by DeputyMarshal View Post
    It's really a bit of both but, with regard to the technology, that's one of the reasons cited for the 10 year service life. PPE technology has consistently evolved. A 10 year old piece of PPE is typically 2 to 3 standards revisions and numerous TIAs behind the current technology.
    How can one standard apply when there are different materials used? A leather helmet and a composite helmet will both have the same lifespan?

    Do we really anticipate some new science to impact protection? Significant enough to warrant the considerable expense of replacing a helmet that is 10 years old?

    You can educate me on this point, what level of research was used to determine 10 years? Was destructive testing done on 10 year old helmets? Last I heard, these composite materials will be in the landfills for a few thousand years....
    I am now a past chief and the views, opinions, and comments are mine and mine alone. I do not speak for any department or in any official capacity. Although, they would be smart to listen to me.

    "The last thing I want to do is hurt you. But it's still on the list."

    "When tempted to fight fire with fire, remember that the Fire Department usually uses water."

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    Quote Originally Posted by ChiefKN View Post
    They are on the committee.
    Manufacturing interests are never more than 1/3 of the principle voting members. Currently there are 9 out of 29. None of them, BTW, manufacture helmets.

    Its an older list, and I took out some of the non-corporate members, just to shorten the post.
    It also contains several alternates and non-voting members and organizational members with no profit interest whatsoever. Surely you know better than that.
    "Nemo Plus Voluptatis Quam Nos Habant"

    The Code is more what you'd call "guidelines" than actual rules.

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    Quote Originally Posted by DeputyMarshal View Post
    Manufacturing interests are never more than 1/3 of the principle voting members. Currently there are 9 out of 29. None of them, BTW, manufacture helmets.
    They do sell helmets, though.

    http://www.morningpride.com/Helmets.aspx

    t also contains several alternates and non-voting members and organizational members with no profit interest whatsoever. Surely you know better than that.
    Know better than what? The secretary is an industry rep, for pete's sake.

    Say what you will, but as long as there are industry voting members, there will be questions about motivation.
    I am now a past chief and the views, opinions, and comments are mine and mine alone. I do not speak for any department or in any official capacity. Although, they would be smart to listen to me.

    "The last thing I want to do is hurt you. But it's still on the list."

    "When tempted to fight fire with fire, remember that the Fire Department usually uses water."

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    From an engineering perspective - I do see the desire to 'expire' the date on PPE.

    -Composite plastics can break down over time due to UV light exposure.
    -Composite plastics can develop fatigue cracking around attachment holes based on heating/cooling cycles.
    -PBI does break down in UV light
    -plastics and rubber can become brittle over time
    - Leather tends retain is characteristics for a very long time - so WTF about a 10yr life on leather lids?

    The fact is - gear does were out with time. The question is how do you know 'when its time'? Wear is easy. You can see it and it becomes obviously worn out. The age based wear is much harder to determine. Frankly - it would be really interesting to do some destructive testing on 'condemned' gear and see what the timelines are really looking like. It may be we are overly conservitive on some items and liberal on others. Anything less than
    actual testing is speculation.

    As for the question of service life for apparatus - we already have this to some extent. Pumps are to be tested, ladders are to be tested and regular maintenance is required. If the truck (engine, sqaud, ladder etc) fails this - its taken out of service until it can be repaired. We even pressure test hose. Its just that PPE (bunkers pants/coats) cannot be tested non-destructively to ensure its protective properties remain intact.

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    I think enough has be said about this issue.

    I have tried to show the reality and economic situation.

    I don't think it is a matter of proving the issue.

    It is clear that the opinions of NFPA are across the board, that is to be expected. But it is also clear that most do not agree with where the Standards are or where they are going.

    Whether it is a Standard or Law may indeed be a Local issue, but the intent does not stay in touch with the majority of the departments that look to it as guidance. You are either compliant or you're not. To what degree a department is compliant might have some value in some areas where others are of little benefit.

    If you should be held to the standard as a matter of law, then every element of the Standard that is not compliant is a violation of law.

    In the case of the Standard used only as the Standard, then you are just not reaching the Standard, or the intent.

    These are two very different things, but defined in one series of Documents.

    It strikes me that the suggestion that we must comply at all costs, is still not achievable. Does one simply eliminate all of the departments that can never comply, based on the suggestion that if you can't, you should not exist?

    No doubt you may be held to the Standard, and shortcomings may be noted. Each department of firefighter must place a value on that risk. If the money isn't there, then I would really like to see the proposal that changes that situation. Statements void of a plan that solves the issue are just words.

    I don't have the answers that can solve this. I have stated so. That is the entire basis of what I state. But, the economic burden is not overcome by just stating you must do it or you're not trying.

    Unfortunatley, DM and I disagree on the this issue. EDIT: I mispoke. We are debating two different issues. I don't think we disagree on the purpose or need for the Standards. He chooses to continue to focus on something much different that what I have stated.

    I present food for thought not to create division, but to make you think about you and your situation and how this applies to you. That seems to have been successful.

    I do not boycott NFPA. I don't even comdemn NFPA. We all agree there must be something to measure us against and strive to reach. All I am trying to suggest is the economic reality prevents most from reaching compliancy. If you are subjected to the Standard as Law, then you are more exposed. But I would not condone the eradiction of your department because someone believes you to be failing or not trying hard enough.

    You can present the case to your public that we are failing and must have more of your money.... but recently this has been a failed venture. The message "if the public wants fire protection, then they must pay for it", again doesn't solve it. I want alot of things, but if I can't afford it, it must wait or it may never happen. You must balance the public demand with the economic condition. Money is always the easy answer... but it just doesn't grow on trees.
    Last edited by PaladinKnight; 08-17-2010 at 07:32 AM.
    HAVE PLAN.............WILL TRAVEL

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    Well spoken as usual. Whether you like it or not,demographics still play into this fray. We(my agency) COULD still do our jobs very nicely in 1970's gear. Oh,you can argue with me all you want,but the simple fact is based on our responses and incident load NOTHING would change if we were in the OLD esemble.AND while we're in good shape in adhereing to the Standards it is STILL a HUGE expense to the Town that by and large is unnecessary.INJURY rate was no higher in the old stuff than the new,if anything our injury rate went UP with the new gear, mostly heat related injuries. The Admin here has ALWAYS been safety concious,not to the point of not getting the job done,but they have ALWAYS looked after the membership. Since my wife comes from Conn and I used to drive a Rig there,I'm familiar with some of the States ODD way of looking at things.Not restricted to FIRE issues. On NFPA,I think most of us are going to agree to disagree. AND to an extent,age will play into that arguement.
    The younger folks,having been told by Government what to do all their lives are more apt to "buy in" to the program than many of the older seasoned vets that know it isn't the "standard" that keeps you safe,it is knowing your job,WELL,and taking proper steps to stay out of arenas that may KILL you.
    I'm not a fan of having a helmet holder in my rig,I'm a fan of operating the Rig in a manner that will keep it from CRASHING which is why they sold you the Helmet holder in the FIRST place. We bring this crap on ourselves,SO..........WHEN are we going to start operating in a reasonable and thought out manner that virtually eliminates the need for all this "hand holding"? It STARTS with YOU.then your agency,then your neighbors,until we fix the problems. And PAPER doesn't "FIX" stuff,personnel and common sense DOES. T.C.
    Last edited by Rescue101; 08-17-2010 at 08:59 AM.

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    Quote Originally Posted by PaladinKnight View Post
    Unfortunatley, DM and I disagree on the this issue. EDIT: I mispoke. We are debating two different issues. I don't think we disagree on the purpose or need for the Standards. He chooses to continue to focus on something much different that what I have stated.
    FWIW, I don't think we're all that far apart. I see NFPA standards as an ideal goal for where we should be but recognize that it's not always feasible to get there. What's important is to make an effort and to have good reasons when we don't. (IMHO, cost alone isn't a good reason.)

    We all agree there must be something to measure us against and strive to reach. All I am trying to suggest is the economic reality prevents most from reaching compliancy. If you are subjected to the Standard as Law, then you are more exposed. But I would not condone the eradiction of your department because someone believes you to be failing or not trying hard enough.
    Agreed.

    Quote Originally Posted by Rescue101 View Post
    We(my agency) COULD still do our jobs very nicely in 1970's gear. Oh,you can argue with me all you want,but the simple fact is based on our responses and incident load NOTHING would change if we were in the OLD esemble.AND while we're in good shape in adhereing to the Standards it is STILL a HUGE expense to the Town that by and large is unnecessary.
    The trick is knowing that your "1970's gear" is adequate based on a thorough and well documented risk evaluation versus just hoping it'll do based on a seat of the pants guess. Saying it's "unnecessary" isn't enough; you need to be able to back it up.

    AND to an extent,age will play into that arguement.
    The younger folks,having been told by Government what to do all their lives are more apt to "buy in" to the program than many of the older seasoned vets...
    For the record, I'm not all that much younger than you are. I don't think that age is a significant factor.

    And PAPER doesn'r "FIX" stuff,personnel and common sense DOES. T.C.
    In my experience, the more "seasoned" I get the more convinced I am that "Common Sense" is more rare than we've been led to believe.
    "Nemo Plus Voluptatis Quam Nos Habant"

    The Code is more what you'd call "guidelines" than actual rules.

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    I also think that having standards is a good thing. Even if they are a bit overambitious. However, there is no doubt that there is a conflict of interest having industry reps as voting members. Why do they need to be voting members?

    Quote Originally Posted by DeputyMarshal View Post
    The trick is knowing that your "1970's gear" is adequate based on a thorough and well documented risk evaluation versus just hoping it'll do based on a seat of the pants guess. Saying it's "unnecessary" isn't enough; you need to be able to back it up.
    In all fairness, is the opposite also true? Is there a scientific basis for 10 years for a helmet's lifespan? There may be, I honestly don't know.
    I am now a past chief and the views, opinions, and comments are mine and mine alone. I do not speak for any department or in any official capacity. Although, they would be smart to listen to me.

    "The last thing I want to do is hurt you. But it's still on the list."

    "When tempted to fight fire with fire, remember that the Fire Department usually uses water."

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    Quote Originally Posted by ChiefKN View Post
    However, there is no doubt that there is a conflict of interest having industry reps as voting members. Why do they need to be voting members?
    Sorry, but there's no doubt that they should be part of the process. There's no more "conflict of interest" in having industry representatives than there is having fire department representatives. The point is to draw consensus from among all the stakeholders, not just one inbred special interest. Balancing committees among a variety of interests insures that no single special interest can possibly dominate the process.


    In all fairness, is the opposite also true? Is there a scientific basis for 10 years for a helmet's lifespan?
    Which year did they add a hard date? As I recall, it's only been within the last couple of editions; either 2000 or 2007. It'll be in the published committee ROP and/or ROC. If you object to the 10 year rule, by all means submit a proposal to change it for the next edition. It's an open process and you're free to participate or not -- it's your choice.
    "Nemo Plus Voluptatis Quam Nos Habant"

    The Code is more what you'd call "guidelines" than actual rules.

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    Quote Originally Posted by DeputyMarshal View Post
    FWIW, I don't think we're all that far apart. I see NFPA standards as an ideal goal for where we should be but recognize that it's not always feasible to get there. What's important is to make an effort and to have good reasons when we don't. (IMHO, cost alone isn't a good reason.)



    Agreed.



    The trick is knowing that your "1970's gear" is adequate based on a thorough and well documented risk evaluation versus just hoping it'll do based on a seat of the pants guess. Saying it's "unnecessary" isn't enough; you need to be able to back it up.



    For the record, I'm not all that much younger than you are. I don't think that age is a significant factor.



    In my experience, the more "seasoned" I get the more convinced I am that "Common Sense" is more rare than we've been led to believe.
    One of the MANY reasons I like debating with you DM. While we are often on opposite sides of the fence,it seems we are often moving in the same direction. By the way,your State is still whacked,hehe T.C.

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    Quote Originally Posted by Rescue101 View Post
    One of the MANY reasons I like debating with you DM. While we are often on opposite sides of the fence,it seems we are often moving in the same direction. By the way,your State is still whacked,hehe T.C.
    Different paths; same goal.

    Of course my state is whacked. Aren't they all?

    Stay safe!

    Bob
    "Nemo Plus Voluptatis Quam Nos Habant"

    The Code is more what you'd call "guidelines" than actual rules.

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    It was kinda dicussed here but I did not see the "10-year rule" defined completely.

    10 years, as discussed in this forum, is from date of manufacture. If a set of PPE sits on a shelf for eight (8) years and then is sold, the buyer can "legally" use it for two (2) additional years.

    Ponder that when you purchase PPE. Alot of the ads you see on this website are for vendors having "clearance sales" on different components of PPE. If you pay half price for a pair of leather fireboots during one of these sales, you are likely buying something that has been sitting on the shelf for many, many years.

    Just a thought.

    Stay safe and stay low brothers and sisters.
    Last edited by rjtoc2; 08-17-2010 at 10:30 AM.
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    Hey Harve,

    I guess this means we can't wear our old rubber coated below the knee coat, 3/4 boots, our Tin Lizzie and fireball gloves anymore, Huh??



    Stay Safe and Well Out There....

    Always remembering 9-11-2001 and 343+ Brothers

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    Snell recommends that motorcycle helmets be replaced every 5 years due to wear and degredation of materials. Our helmets are made from similar materials.

    http://www.smf.org/faqs.html#10

    You fire helmet less important to protecting your brain pan?

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    Quote Originally Posted by neiowa View Post
    Snell recommends that motorcycle helmets be replaced every 5 years due to wear and degredation of materials. Our helmets are made from similar materials.

    http://www.smf.org/faqs.html#10

    You fire helmet less important to protecting your brain pan?
    I'm betting our helmets spend a LOT less time in the Sun than a MC helmet. I'd ALSO be willing to bet that if you tested MOST of our ten year old HELMETS they would STILL pass. T.C.

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    Quote Originally Posted by DeputyMarshal View Post
    Why would you want to replace PPE based on an outdated standard?
    Exactly.

    But - there are applications in some parts of the fire service where a canvas coat would be perfectly acceptable. And given comments about our current gear being almost too protective, maybe we ought to go back. If the firefighters know the gear won't protect them in certain circumstances, maybe they won't go there in the first place...

    Just playing the devil's advocate here...
    Opinions my own. Standard disclaimers apply.

    Everyone goes home. Safety begins with you.

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    Quote Originally Posted by DeputyMarshal View Post
    Why would you want to replace PPE based on an outdated standard?
    Exactly.

    But - there are applications in some parts of the fire service where a canvas coat would be perfectly acceptable. And given comments about our current gear being almost too protective, maybe we ought to go back. If the firefighters know the gear won't protect them in certain circumstances, maybe they won't go there in the first place...

    I just found some old literature whilst doing some uncluttering. Coat (nomex) - $175. Pants the same.

    Just playing the devil's advocate here...
    Opinions my own. Standard disclaimers apply.

    Everyone goes home. Safety begins with you.

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    Quote Originally Posted by DeputyMarshal View Post
    Sorry, but there's no doubt that they should be part of the process. There's no more "conflict of interest" in having industry representatives than there is having fire department representatives. The point is to draw consensus from among all the stakeholders, not just one inbred special interest. Balancing committees among a variety of interests insures that no single special interest can possibly dominate the process.
    No need to apologize. They can be a part of the process, but should not have a vote.

    If you object to the 10 year rule, by all means submit a proposal to change it for the next edition. It's an open process and you're free to participate or not -- it's your choice.
    Sure, I can submit comments. However, my comments will never have the weight of the people who are selling the products and have a VOTE on the standards.
    I am now a past chief and the views, opinions, and comments are mine and mine alone. I do not speak for any department or in any official capacity. Although, they would be smart to listen to me.

    "The last thing I want to do is hurt you. But it's still on the list."

    "When tempted to fight fire with fire, remember that the Fire Department usually uses water."

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    Quote Originally Posted by tree68 View Post
    But - there are applications in some parts of the fire service where a canvas coat would be perfectly acceptable.
    ....
    Just playing the devil's advocate here...
    I agree. This brings us around to another discussion altogether. We (the fire service) often has a sort of "one size fits all" mentality when it comes to PPE. It's the old, "When the only tool you have is a hammer, everything starts to look like a nail."

    We spend big bucks on highly specialized stuructural firefighting gear and then insist on using it for just about everything -- including activities where an old canvas coat or even a set of Walmart coveralls would be more appropriate.

    Somewhere we need to get it into our heads that "PPE" doesn't always equal "structural firefighting gear." (NFPA compliant or otherwise. )
    "Nemo Plus Voluptatis Quam Nos Habant"

    The Code is more what you'd call "guidelines" than actual rules.

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    Quote Originally Posted by ChiefKN View Post
    No need to apologize. They can be a part of the process, but should not have a vote.
    Why not? Can you think of anyone who knows the technology better?

    Sure, I can submit comments. However, my comments will never have the weight of the people who are selling the products and have a VOTE on the standards.
    With all due respect, you're mistaken. If your comments have merit, they're as likely to sway a technical committee as anyone else who submits a proposal. The "people selling products" don't control a majority vote; they have to back their proposals just like everybody else.

    Then there's always the possibility for you to volunteer to be one of those voting members...
    "Nemo Plus Voluptatis Quam Nos Habant"

    The Code is more what you'd call "guidelines" than actual rules.

  24. #49
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    Quote Originally Posted by DeputyMarshal View Post
    Why not? Can you think of anyone who knows the technology better?
    Oh, I agree they may have access to technical information. Does anyone know if they share that information or is it mostly proprietary? I don't object to their participation, I do object to their voting on the standard.

    Why do they need to vote? There are other non-voting members.

    With all due respect, you're mistaken. If your comments have merit, they're as likely to sway a technical committee as anyone else who submits a proposal. The "people selling products" don't control a majority vote; they have to back their proposals just like everybody else.
    I understand they don't have a majority and I'm sure that they have valuable input, but again... why do they have to vote?

    Then there's always the possibility for you to volunteer to be one of those voting members...
    Not in the cards for me.
    I am now a past chief and the views, opinions, and comments are mine and mine alone. I do not speak for any department or in any official capacity. Although, they would be smart to listen to me.

    "The last thing I want to do is hurt you. But it's still on the list."

    "When tempted to fight fire with fire, remember that the Fire Department usually uses water."

  25. #50
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    Quote Originally Posted by ChiefKN View Post
    There are other non-voting members.
    FWIW, non-voting members are typically liaisons from other interested organizations/agencies. For instance, you sometimes see OSHA representatives coordinating between standards and related regulations.

    I understand they don't have a majority and I'm sure that they have valuable input, but again... why do they have to vote?
    As I said before, why shouldn't they? You can't create a "consensus" standard by excluding a whole class of stakeholders.

    Not in the cards for me.
    That's a shame, there's always a need for alternative perspectives.
    "Nemo Plus Voluptatis Quam Nos Habant"

    The Code is more what you'd call "guidelines" than actual rules.

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