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Report
403-16 Log #CP16 & 403-27 Log #CP25
-Dan Pierce C.M.F.
1. NFPA 403, 3.3.2 - Actual Response Time.
“The total period of time measured from the
time of an alarm until the first ARFF vehicle
arrives at the scene of an aircraft accident
and is in position to apply agent.”
Is “actual response time” the same as
“demonstrated response time” in 9.1.3?
NFPA 1710 – Standard for the Organization and Deployment of Fire Suppression Operations,
Emergency Medical Operations, and Special Operations to the Public by Career Fire Departments.
4.1.2.1 The fire department shall establish the following objectives:
(1) Alarm handling time to be completed in accordance with 4.1.2.3
(2) 80 seconds for turnout time for fire and special operations response and 60 seconds turnout time for EMS response.
(3)* 240 seconds or less travel time for the arrival of the first arriving engine company at a fire suppression incident and 480 seconds or
less travel time for the deployment of an initial full alarm assignment at a fire suppression incident.
(4) 240 seconds or less travel time for the arrival of a unit with first responder with automatic external defibrillator (AED) or higher level
capability at an emergency medical incident.
(5) 480 seconds or less travel time for the arrival of an advanced life support (ALS) unit at an emergency medical incident, where this
service is provided by the fire department provided a first responder with AED of basic life support (BLS) unit arrived in 240 seconds or
less travel time.
4.1.2.3.3 The fire department shall establish a performance objective of having an alarm processing time of not more than 60 seconds
for at least 90 percent of the alarms and not more than 90 seconds for at least 99 percent of the alarms, as specified by NFPA 1221.
4.1.2.4 The fire department shall establish a performance objective of not less than 90 percent for the achievement of each turnout time
and travel time objective specified in 4.1.2.1.
-------------------------------------------------------------------------------------------------------------------5.2.4.1 Initial Arriving Company
5.2.4.1.1 The fire department’s fire suppression resources shall be deployed to provide for the arrival of an engine company within a
240-second travel time to 90 percent of the incidents as established in Chapter 4.
Total Response Time = 60 sec. (Alarm Processing) + 80 sec. (Turnout Time) + 240 sec. (Travel Time) = 380 SECONDS (6.3 Min.)
5.5.4.1 The airport fire department shall deploy the required number of ARFF vehicles required for the airport’s assigned category as
established by NFPA 403. (Note- A four minute response in the RRA is consistent with the NFPA 1710 travel time requirement.)
3. NFPA 1710, 3.3.53.6 - Total Response Time
a. 3.3.53.3 - Alarm processing time (60 sec.) +
b. 3.3.53.8 - Turnout time (80 sec.) +
c. 3.3.53.7 - Travel time (240 sec.)
Total Response Time =
60 sec. (Alarm Processing) +
80 sec. (Turnout Time)+
240 sec. (Travel Time) = 380 SECONDS (6.3 Min.)
4. NFPA 1710, 5.5.4.1
“The airport fire department shall deploy the
required number of ARFF vehicles required for the
airport’s assigned category as established by NFPA
403.”
5. NFPA 1710, 5.5 Airport Rescue and Fire
Fighting Services
“5.5.2 ARFF operations shall be organized to
ensure the fire department‘s capability includes
personnel, equipment and resources to deploy
the initial arriving company, the initial full alarm
assignment, and additional alarm assignments as
required in 5.2.4.”
6. NFPA 403 9.13 Using a NFPA 2-minute
“demonstrated response” anywhere in the RRA is
not consistent with ICAO Annex 14, 9.2.21
standard or FAA Part 139, 139.319 regulations.
7. NFPA 403 9.13 Using a NFPA “demonstrated
response time” requirement of 2-minutes
anywhere in the RRA does not use the same
fundamental reasoning as identified in NFPA
1710, 3.3.53.6 “Total Response Time”, for initial
response of other fire department equipment
responding to an on/off airport incident.
NFPA 1710 Annex A Fig. 3.3.53.6
8. NFPA 403, 9.13 Using a “demonstrated
response time” of 2-minutes anywhere in RRA is
not practical for U.S. Congressional funding as
identified in ACRP 7 & 12 reports.
(Reference prior presentation on ACRP Reports
Arguments).
DOT/FAA AR-11/27
a. Fig. 27 shows typical burn through of aircraft skin
adjacent to fuel in less than 2 minutes using an
“average” (pg.37) heat flux of 120-150 kW/m² with 2” of
insulation. Wouldn’t this “average” heat flux scenario
exceed current NFPA 403 3-minute control
requirements for Q1agent application?
b. Table 7@ 5(< 16.4 ft.), Table 9 @ 4?(<16.4 ft.), Table
[email protected] (16 ft.) indicates no advantage to 2-minute
response to reduce “Time Region” life safety effects in
scenario for groups 1, 2 or 3 respectively.
AR 11-27 Group Comparisons
Group 1 Group 2 Group 3 Group 4 Group 5 Group 6 Group 7 Group 8
Fire Width
240
159
89
240
73
240
240
240
Max Flame Height
266
202
137
266
240
208
208
266
Max Flame Emissive Power
20
20.4
24.6
20
20
20
20
20
Heat Release Rate
170
113
63
170
170
170
170
170
Offset Distance view factor
7.1
5.1
3.4
7.1
29
29
7.1
Distance Flux = 9.59 kW/m²
19.1
50
44
63
104
104
9.2
63
R1 Dist. for 2-min. Response
39
33
33
16.4
74
39
4.9
n/a
R1 Dist. for 3-min. Response
52
49
39
33
90
59
8.2
n/a
Group 1
Group 2
Group 3
Group 4
Group 5
involves a 73-m (240-ft)-long aircraft with a 0.5-mm (0.02-in.) aluminum skin. The wind speed is assumed to be zero.
involves a 48-m (159-ft)-long aircraft with a 0.5-mm (0.02-in.) aluminum skin. The wind speed is assumed to be zero.
involves a 27-m (89-ft)-long aircraft with a 0.5-mm (0.02-in.) aluminum skin. The wind speed is assumed to be zero.
involves a 73-m (240-ft)-long aircraft with a 2.5-mm (0.1-in.) aluminum skin. The wind speed is assumed to be zero.
involves a 73-m (240-ft)-long aircraft with a 0.5-mm (0.02-in.) aluminum skin. The wind speed is 8.9 m/s (20 mph), and
the aircraft is downwind of the source fire.
Group 6 involves a 73-m (240-ft)-long aircraft with a 2.5-mm (0.1-in.) aluminum skin. The wind speed is 8.9 m/s (20 mph), and
the aircrafty is downwind of the source fire.
Group 7 involves a 73-m (240-ft)-long aircraft with a 0.5-mm (0.02-in.) aluminum skin. The wind speed is 8.9 m/s (20 mph), and
the aircraft is upwind of the source fire.
Group 8 involves a 73-m (240-ft)-long aircraft with a robustly constructed composite skin. The wind speed is assumed to be zero.
10. DOT/FAA AR-11/29 3.31
a. “The ICAO RFFP I [10] noted that the existing 3-minute vehicle
response time specified in Annex 14 was considered an acceptable
upper limit, though it was recognized that, under many instances,
airport authorities could improve (lower) this limit. ICAO RFFP II
considered that a 2-minute response time to any part of the airport
movement area should be an objective. Their official
recommendation was that response time to any part of the airport
movement area under optimum conditions of visibility and surface
conditions should be not more than 3 minutes, but preferably, not
more than 2 minutes.”
Note – Use of the ICAO reference (above), is a subjective argument
itself based on speculative accident conditions.
“They indicated that a desirable response time would be 90 seconds (0second response time would be the goal, but it is obviously not practical),
with a 2-minute response as optimum.”
–pg. 13
Really?
b. “The current 2-minute response time in NFPA
403 is based on what is practical [1]. It was shown
that the Lindemann assumption [17] of 2 minutes
before the onset of hazardous conditions is
optimistic in some scenarios.”
–pg. 104
c. Appendix Table D-3 - “The ARFFRWG panel members suggested that
an additional time criteria be established for ARFF response to preannounced incidents. A qualitative review of the incidents in appendix D,
where ARFF had a potential impact, does not show a substantial
percentage of incident prenotification. This does not necessarily include
response to minor incidents, which could develop into major incidents.
From the data and analysis in this report, there is an insufficient technical
basis to modify the current NFPA 403 response time criteria.”
-Pg. 105
Note – The last sentence (above) is a false premise based on
the data provided in Table D-3. On many incidents, ARFF
response times over 2-minutes (majority) were NOT identified
where ARFF assisted in rescue/fire suppression operations.
The Cherry report (DOT/FAA/AR-09/18) provides additional
response time data. From the data and analysis in this report,
there is insufficient technical basis to support the current
NFPA 403 response time criteria.
TV (actual vehicle response time) +
TB (90% extinguishment time) =
TE (occupants exposure time).
Note - A TV actual vehicle response time of 2-minutes
from an ARFF station to any point in the RRA for an Alert-3
without prior notification for the incident is not practical.
This response performance requirement only satisfies a
very low probability of incidents. A “hot-spot” like that used
by the USMC may satisfy this standard. Some airports
may require multiple “hot spots” to comply with a NFPA 2minute response requirement in the RRA.
c. Immersion exception? - “Interior aircraft
ignition may not be prevented if the aircraft is
totally immersed in fire, even with a rapid (less
than 2 minutes) ARFF response. The current
assumption that there may be 2 minutes before
occupants are threatened is optimistic for the
analyzed scenarios of interest in this report.”
-pg. 112
e. Insufficient data? - “There were only 27
major accidents identified over the period from
1992 to the time of this analysis (20 years)
involving large (?) occupant load in which
Aircraft Rescue and Firefighting (ARFF)
provided potential assistance, indicating the low
probability of such an accident. Even under the
most favorable response scenarios, ARFF
response may have limited effectiveness
because of potential rapid breach of the
fuselage (by fire or by impact) and resulting
rapidly deteriorating cabin conditions.”
-pg. 111
11. ARFFRWG Final Draft to ARAC a 3-minute
time objective to begin agent application at any
point on any runway at all indexed airports is
identified.
-pg.17
“Category 4 & 5 Airports
5 3 Minutes Begin discharge of required agent from first required vehicle
6 4 Minutes Begin discharge of required agent from all other required vehicles
7 Establish incident command system and request additional resources
8 Initiate access to aircraft cabin”
etc…
12. Other NFPA Life Safety Codes (i.e. NFPA 101, 1710
etc.) do not use worst case scenarios to establish minimum
life safety standards.
Example: A fire in a high occupancy structure that
restricts egress through any corridor or door to a safe area
(i.e., WTC 1 & 2 on 9/11/2001)
-NFPA 101
Example: A bus carrying multiple occupants is involved in
a traffic collision with a tractor trailer vehicle transporting
thousands of gallons of gasoline.
-NFPA 1710
13.NFPA 403 9.13 Because of practicality, cost and
risk analysis (severity/probability matrix), the 2minute ARFF “demonstrated response time”
probably will not change an AHJ’s airport ARFF
response requirement that currently complies
with existing ICAO/FAA standards/regulations.
14. NFPA 403 9.13 Why has the 2-minute NFPA 403
“demonstrated response time” been modified for
practical use by the U.S. military?
Thank-you!

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