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Comments to ISO/CD 22488
2002-02-19
Ref.: S-262/HJM
The Danish comments to ISO/CD 22488 Shipboard fire-fighters outfit are divided into two categories, general and technical.
The general comments highlight the problems with this proposed standard seen in the context with other international and regional standards on the same subject. The technical comments relate to specific technical details specified in CD 22488.
GENERAL COMMENTS
European directive and European standards
European P-member countries in ISO/TC 8/SC 1 have problems when voting and commenting on ISO/CD 22488.
The problem is that different types of equipment for fire-fighters outfits (protective clothing, gloves, boots and helmets) are covered by the European Directive for Marine Equipment (Council Directive 96/98/EC of 20 December 1996 on marine equipment. Amended by Commission Directive 98/85 EC of 11 November 1998, and by Commission Directive 2001/53/EC of 10 July 2001).
This European directive makes reference to a set of European standards for different types of equipment. These European standards are not specific for maritime requirements for the particular types of equipment, but applies to the general use of the equipment.
All CEN member countries are bound to implement these European standards as national standards, and to withdraw standards with different and conflicting requirements. This will prevent the European P-member countries in ISO/TC 8/SC 1 to vote positive to an internationals standard with different requirements.
Recommended solution
The recommended solution to the actual problem is that the international standard ISO 22488 from SC 1
1. includes the European standards as normative references as for general requirements
2. concentrates the SC 1 standard to requirements specific to the maritime use of the equipment.
The maritime requirements to be reflected in ISO 22488 are - for a number of reasons foreseen to be stronger and further to the general requirements given in the European standards.
The procedural basis for this recommended solution is given in IS0/IEC Directives, Part 2, Clause 6.2.2. a). What is required is, that SC 1 recognizes the referenced European standards. The European P-members of SC 1 have to!.
Actual European standards
The European standards with general requirements to be included in the normative references of ISO 22488 from ISO/TC 8/SC 1 are:
For protective clothing:
EN 469:1995 Requirements and test methods for protective clothing for firefighting
EN 1486:1996 Test methods and requirements for reflective clothing for specialized Fire-fighting
For gloves:
EN 659:1996 Protective gloves for firefighters
For boots:
EN 344-2:1996 Safety, protective and occupational footwear for professional use -Part 2: Additional requirements and test methods
EN 345-2:1996 Safety footwear for professional use -Part 2: Additional specifications
For helmets:
EN 443:1997 Helmets for firefighters
Structure change in CD 22488
Acceptance of the recommended solution in the way forward with development of CD 22488 will further imply inclusion of an additional sub-clause 5.x.0 General in the following clauses of CD 22488:
5.2 Protective clothing
5.3 Gloves
5.4 Boots
5.5 Helmets
As text for the separate new sub-clauses is proposed:
5.2.0 General
General requirements for protective clothing given in EN 469 and EN 1486 applies also for protective clothing used in maritime conditions.
Specific requirements for protective clothing used in maritime conditions are specified in following sub-clauses 5.2.1 to 5.2.6 of this standard.
5.3.0 General
General requirements for gloves given in EN 659 applies also for gloves used in maritime conditions.
Specific requirements for gloves used in maritime conditions are specified in following sub-clauses 5.3.1 and 5.3.2 of this standard.
5.4.0 General
General requirements for boots given in EN 344-2 and 345-2 applies also for boots used in maritime conditions.
Specific requirements for boots used in maritime conditions are specified in following sub-clauses 5.4.1 to 5.4.4 of this standard.
5.5.0 General
General requirements for helmets given in EN 443 applies also for helmets used in maritime conditions.
Specific requirements for helmets used in maritime conditions are specified in following sub-clauses 5.5.1 to 5.5.3 of this standard.
International standards for fire-fighters outfit from ISO/TC 94
It is further recommended that international standards for fire-fighters' outfit developed by ISO/TC 94 are included as normative references in ISO 22488 in the same way as the European standards. Special attention shall in this respect be given to
ISO/CD 11613 Protective clothing for fire fighters
ISO 15383 Protective gloves for fire fighters
ISO/DIS 17250 Safety footwear for fire fighters
The real need for a specific maritime standard on fire-fighters' outfits
The Danish vote to the ballot to this Committee Draft is negative, as a consequense of the amount of observations and comments raised to the document/work item.
It is foreseen that also other P-member countries of SC 1 would have extensive comments to this CD. Should, this be the case, we will recommend ISO/TC 8/SC 1 to reconsider the project and the feasibility for having this subject covered by a standard in ISO/TC 8/SC 1, at the earliest possible stage.
TECHNICAL COMMENTS
The technical comments to CD 22488 are included in the template format for CD-comments
German Comment on ISO/CD 22488
Germany, as a CEN member country, is bound to the Commission Directive 98/85/EC of 11 November 1998. This European directive refers to a set of European standards for equipment for fire-fighters' outfits (protective clothing, gloves, boots and helmets). Therefore we can not vote positive to an international standard with different requirements.
As Germany has stated before, when voting on the NWI proposal, we are of the opinion, that this project belongs to the scope of ISO/TC 94/SC 14. No new standard is needed, IMO and SOLAS may refer to the existing standards.
If to the contrary, IMO decides, that the existing standards can not cover the special requirements of ships and marine technology, additional standards with more specific requirements may be needed.
Avoidance of duplication and unnecessary deviations should be a general principle in the methodology of standardization. Therefore the first step should be to check the existing standards to determine if
a) IMO can refer to these standards directly, or if
b) additional standards are needed, or if some requirements of the existing standards have to be modified for the application of ships and marine structures. In this case new standards could be worked out which include references to the existing standards and which give some specific requirements needed for ships and marine structures.
No general requirements should be stated in a new standard.
For the ISO standards we recommend to ask the ISO/TC 94 Secretariat for information, the following standards may apply to the general use of fire-fighters' outfits:
ISO/CD 11613 Protective clothing for fire fighters
ISO 15383 Protective gloves for fire fighters
ISO/DIS 17250 Safety footwear for fire fighters
For the CEN standards we recommend to ask the CEN/TC 162 Secretariat for information, the following standards apply to the general use of fire fighters' outfits:
EN 469:1995 Requirements and test methods for protective clothing for firefighting
EN 1486:1996 Test methods and requirements for reflective clothing for specialized fire-fighting
EN 659:1996 Protective gloves for firefighters
EN 344-2:1996 Safety, protective and occupational footwear for professional use - Part 2:
Additional
requirements and test methods
EN 345-2:1996 Safety footwear for professional use - Part 2: Additional specification
EN 443:1997 Helmets for firefighters
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