By Bill Adams
Throughout National Fire Protection Association (NFPA) 1901, Standard for Automotive Fire Apparatus, are statements requiring the certification of certain components and levels of performance mandated by the standard. When a purchaser spends hundreds of thousands of dollars to more than a million dollars for a new rig, there must be verifiable methods of validating compliance to the specifications (specs). I concur 100percent. There are several methods of certification recognized by NFPA 1901. One is by the manufacturer of the apparatus itself. Another is by the manufacturer of a vendor-supplied component such as a siren. And, one is by an independent third party. The standard is explicit in the qualifications and procedures in the process. A certification is a confirmation—an official statement of compliance.
Some purchasing specs contain nebulous criterion, meaning the requirement itself is unclear and the means to prove compliance is equally ill-defined. The following statement was taken from a fire department’s purchasing spec: “A road test shall be conducted with the apparatus fully loaded and a continuous run of ten (10) miles or more shall be made under all driving conditions, during which time the apparatus shall show no loss of power or overheating. The transmission drive shaft or shafts and rear axle shall run quietly and be free from abnormal vibration or noise throughout the operating range of the apparatus.” The intent is obvious and well meaning, and historically bidders always claim compliance. But, who conducts the test? Where is it conducted? Is it before or after delivery? Can the rig be fully loaded before it is fully paid for? What is a loss of power? What constitutes overheating? Who determines running quietly and excessive noise? Are test results documented? What happens if the purchaser and the manufacturer disagree on something that is vaguely described such as abnormal vibration?
NFPA 1901, Section 4.15, Highway Performance, sentence 4.17, titled General Pre-Delivery Tests, stipulates that prior to delivery the manufacturer shall test definitive requirements such as acceleration, attaining and maintaining certain speeds, and braking under specific conditions. To be NFPA 1901 compliant, such requirements must be met whether or not the purchaser reiterates each one in its specifications. Other than Sentence 4.21 requiring certification that the apparatus fully complies, I can’t find where documented certification must be provided to the purchaser specifically for the highway performance tests. Most fire departments don’t specify whether predelivery testing must be witnessed and if written certification is required. Sentence 4.18 does state if tests are to be conducted upon delivery, the purchaser should make note of the specifics. That seldom happens. Unfortunately, highway performance is something many fire departments just accept as normal. “Here’s our check—we know everything will work just fine. And, we’ll all live happily ever after.” Taxpayers may not agree.
Types of Certification
Section 4.8, Manufacturer Certification of Test Results, states: “Where this standard requires the results of tests or the performance of a component to be certified by the manufacturer, the manufacturer shall meet the requirements of this section.” The requirements are explicit in requiring facilities and equipment for testing, training programs and procedures to ensure control of tests, and who signs what. The NFPA is setting the rules for self-testing.
Section 4.7, Third Party Certification of Test Results, is equally explicit in detailing the requirements of testing. Third party testing cannot be performed by an entity with a financial interest in the product being tested or in the manufacturer who made or installed it. That prevents the fox from guarding the henhouse. Interestingly, sentence 4.7.8 states: “The certification organization’s operating procedures shall provide a mechanism for the manufacturer to appeal decisions. The procedures shall include provisions for the presentation of information from representatives of both sides of a controversy to a designated appeals panel.”
It is odd that the NFPA requires a means for a manufacturer to challenge a third party tester’s findings, but there is no such recourse for a purchaser to challenge an apparatus manufacturer’s self-claim of compliance. I guess that’s why they have courts.
Spec writers should choose their specification wording carefully. As an example, NFPA 1901, sentence 3.3.46, defines a contractor as: “The person or company responsible for fulfilling an agreed upon contract.” Sentence A3.3.46 in the Appendix takes it a step further: “The contractor might not necessarily manufacture the fire apparatus or any portion of the fire apparatus but is responsible for the completion, delivery, and acceptance of the entire unit.” A vendor may not be interpreted as the same thing as a dealer, salesperson, manufacturer, or bidder.
The fire department may want the actual manufacturer to conduct certain tests and provide certifications. A contractor who may be a dealer, salesperson, delivery service, or the local service center may not be equipped to or adequately trained to do so. This is particularly important when acceptance tests are required at the point of delivery. Be fair to apparatus manufacturers. They must be told if full payment is contingent upon passing all tests required at the time of delivery.
Purchasers writing their own purchasing specifications should seek professional help (guidance, assistance, advice, direction, etc.) to ensure they do not specify something that physically can’t be provided, is illegal, or can’t be defined. A statement seen for years in fire-department-generated purchasing specs is: “The apparatus, when fully equipped and loaded, shall have not less than 25 percent nor more than 50 percent of the weight on the front axle, and not less than 50 percent nor more than 75 percent on the rear axle.” I wonder if that requirement meets NFPA 1901’s requirement that axle weight ratings are within the chassis manufacturer’s load balance guidelines? You might want to ask.
BILL ADAMS is a member of the Fire Apparatus & Emergency Equipment editorial advisory board, a former fire apparatus salesman, and a past chief of the East Rochester (NY) Fire Department. He has 50 years of experience in the volunteer fire service.