I am the Marine Maintenance Officer for Army Prepositioned Stock Set 4 (APS-4) Watercraft in Yokohama, Japan. We have 17 vessels in our inventory that are required to adhere to the NFPA 1851 standards concerning Care, Inspection, and Maintenance of Fire Fighting Ensembles. We are an organization of storage, tasked to maintain watercraft and its support equipment in a ready state in the event of a contingency or humanitarian assistance or disaster relief mission. These vessels are unmanned and equipment is stored off of the vessels until we are given the directive to issue. At that point, Soldiers would fly to our location and draw our equipment to respond accordingly.
Issue: We are turning in brand new, never worn, still in the package suits due to paragraph 10.2.1: Structural firefighting ensembles and ensemble elements shall be retired in accordance with 10.2.1 or 10.2.2, no more than
10 years from the date the ensembles or ensemble elements were manufactured.
This is extremely costly.
According to paragraph 10.1: Retirement, Disposition, and Special Incident Procedure commentary section it states "Organizations need to evaluate their PPE and make the determination to retire based on damages beyond repair. PPE may need to be replaced prior to reaching the 10 year mark based on wear and tear. A cost analysis evaluating the remaining economic benefit and the remaining level of protective properties relative to the 10 year cutoff may also be helpful in determining when to retire PPE."
Which in turn leads me into my question:
If we have brand new firefighting ensembles (yellow reflective tape) that have never been worn and still in the package, is there a waiver authority for the 10 yr. service life? We are required to carry a certain amount of equipment to be at the ready, but it is very expensive when we are changing out a large quantity of brand new suits because they are at the 10 years from manufactured date. Through procurement channels, there are times that we get these suits with half of their service life already expired.
In addition, if we were to purchase brand new suits, vacuum seal and store them would this help in NFPA supporting this special 10 yr. service life from manufactured date waiver request? In accordance with Section 9:
Storage, paragraph 9.1.3: Ensemble and ensemble elements shall not be stored in airtight containers unless they are new and unissued.
The idea is that once they are issued and the package torn open, they have some service life regardless to the manufactured date. If we can get a written waiver or some sort of consent or agreement from NFPA it would certainly support our case in an effort to be conscientious in spending US government funds.