Grass Fire Trucks: An NFPA Compliance Conundrum

BY BILL ADAMS

A conundrum can be defined as a dispute, a problem, or even a confrontation. In the fire service, deciding to comply or not to comply with a National Fire Protection Association (NFPA) standard or any part thereof is a conundrum. It can create confusion and consternation in the ranks. Equally challenging is determining which standard to follow if more than one could be applicable.

I believe an NFPA standard is a nationwide consensus criterion specifying minimum requirements where voluntary compliance is influenced by the possibility of litigation. There are scenarios where legislation by political subdivisions as well as contractual agreements between two parties legally mandate NFPA compliance. Even in those so-called binding circumstances, fire departments have been known to fully embrace NFPA standards to secure equipment with features they desire and, in turn, systematically ignore standards with features they dislike. Prime examples of the latter are specifying noncompliant retroreflective chevron colors on the rear of apparatus and not securing fire helmets when carried in apparatus cabs. It is hypocritical but commonplace. Apparatus manufacturers tend to follow NFPA standards—especially those manufacturers recalling the demise of the Peter Pirsch Company in 1985 caused, in part, by a wrongful death lawsuit.

Purchasing or placing into service a grass fire truck is when two NFPA standards could apply to the same rig. In particular, they are NFPA 1901, Standard for Automotive Fire Apparatus, and NFPA 1906, Standard for Wildland Apparatus. When NFPA 1906 apparatus are referenced herein, Chapter 5 (wildland fire suppression apparatus) applies. When NFPA 1901 apparatus are referenced, Chapter 5 (pumpers) and Chapter 6 (initial attack apparatus) apply.

It is immaterial if a grass fire truck is built by an apparatus manufacturer, a local fabrication shop, or the fire department itself. The conundrum is determining if it has to be manufactured, equipped, and operated in compliance with either or part of the aforementioned NFPA standards. Queries to several fire departments asking if their grass fire trucks were compliant with NFPA 1901 or NFPA 1906 resulted in the following answers:

• NFPA 1901.
• Neither.
• Both.
• It doesn’t have to because we built it ourselves.
• Never thought about it.

Grass fire trucks (aka brush trucks) are not formally recognized by NFPA 1901 or 1906. Some apparatus manufacturers’ Web sites do not specifically advertise that their grass fire trucks are in full compliance with any NFPA standard. There must be a reason for them not doing so. Ask.

Grass fire trucks may fall into that ambiguous and undefined category of auxiliary apparatus not categorically defined by NFPA 1901. For the purpose of this article, an auxiliary apparatus is one with a minimum 10,000-pound gross vehicle weight rating (GVWR). Job-specific auxiliary apparatus could be for traffic control or grass fires. They could even be multipurpose support vehicles that may be equipped with a snow plow in the winter and a seasonal slip-on skid unit for grass fires. An unknown is whether or not such auxiliary apparatus have to be—or should be—in full compliance with NFPA 1901 or NFPA 1906 or any portion of either.

WILDLAND URBAN INTERFACE

Wildland urban interface (WUI) apparatus appear to be the “in thing” with many purchasers, manufacturers, and commentators. The National Wildfire Coordinating Group (NWCG) has published criteria for wildland apparatus; however, it is not officially recognized or adopted by the NFPA. Concurrently, I cannot find if NWCG apparatus require NFPA compliance. I believe WUI is an ambiguous term to both purchasers and manufacturers alike. It can be whatever you want it to be.

When reviewing the advertisements for several delivered WUI apparatus, it appears some purchasers (or manufacturers) are attempting to create universal “do-everything” multipurpose rigs that are capable of fighting wildland fires and, if specified, structural fires. It is akin to attempting to make a mini pumper perform like a full-size pumper or having a small quint perform 100 percent of the duties of a ladder truck and a full-size pumper. Some multipurpose vehicles can do a little bit of everything but possibly not one thing very well.

Merely specifying a rig to be a NWCG WUI apparatus does not guarantee compliance to either NFPA standard. If an end user wants an NFPA-compliant WUI rig, it must first determine the level of performance desired and specify the applicable standard in its purchasing specifications. The same applies to grass fire trucks.

Regardless of the seven types of apparatus that NFPA 1901 formally defines, end users usually call them whatever they want. As an example, rigs compliant with both Chapter 5 and Chapter 6 of NFPA 1901 have been called pumps, pumpers, engines, combinations, squads, attacks, and wagons. Grass fire trucks have been lettered GF, unit, forestry, brush, service, and a multitude of other localized terms up to and including “Stump Jumper” and “Grass Hopper”! Lettering on the door does not indicate compliance. If a grass fire truck is to be fully NFPA compliant, it must meet either NFPA 1906 or 1901.

There are some major differences in the two standards that purchasers should consider. Some direct quotations and comments from NFPA 1906 are referenced by sentence or chapter number. My comments are in brackets. Underlining is for emphasis.

• NFPA 1906 Sentence 1.1: “This standard shall define the minimum requirements for the design, performance, and testing of new automotive fire apparatus that are designed primarily to support wildland fire suppression operations.” [NFPA 1901 states its requirements are “for use under emergency conditions to transport personnel and equipment and to support the suppression of fires and mitigation of other hazardous situations.” It does not specify the type of fire operations or hazards.]
• NFPA 1906 Appendix Sentence A.1.1: “This standard is designed to cover new automotive fire apparatus primarily used to fight wildland fires at both on-road and off-road locations. To a limited degree, these apparatus can be used to protect exposures or fight structure fires from the exterior. The apparatus covered by this standard are not intended to replace or supersede the function of pumpers or initial attack fire apparatus.” [Second time the standard states that NFPA 1906-compliant rigs are not intended for structural (interior) firefighting.]
• NFPA 1906 Sentence 1.3.3: “This standard shall not apply to fire apparatus designed to support structural firefighting or associated fire department operations, which are covered by the requirements of NFPA 1901.” [Third time reiterating that NFPA 1906-compliant apparatus are not for structural firefighting.]
• NFPA 1906 Section 4.13 Vehicle Stability: “A rig weighing less than 33,000 pounds must remain stable to 30 degrees in both directions.” [NFPA 1901 only requires stability to 26.5 degrees—11 percent less.]
• NFPA 1906 Section 4.14.2: “The fire apparatus shall meet all the requirements of this standard while stationary on a grade of 10 percent in any direction.” [NFPA 1901’s requirement is only for six percent in any direction—40 percent less.]
• NFPA 1906 Sentence 4.15.4: “The vehicle shall be capable of maneuvering across a 20 percent grade and up and down a 25 percent grade.” [NFPA 1901 has no such requirement.]
• NFPA 1906 Sentence 5.4: “The apparatus shall be equipped with a water tank(s) that meets the requirements of Chapter 18 and that has a minimum certified capacity (combined, if applicable) of 150 gallons (600 L).” [NFPA 1901 requires a minimum 300-gallon tank for pumpers and a minimum 200-gallon tank for initial attack apparatus.]
• NFPA 1906 Table 5.5 Equipment Storage requires 20 cubic feet of enclosed equipment storage for rigs weighing 10,001 to 15,000 pounds. [NFPA 1901 requires 22 cubic feet on initial attack apparatus and 40 cubic feet on pumpers—10 percent and twice as much.]
• NFPA 1906 Section 5.7.1 requires “Two solid bottom wheel chocks, mounted in readily accessible locations, each designed to hold the apparatus, when loaded to its GVWR, on a 15 percent grade with the transmission in neutral and the parking brake released.” [NFPA 1901’s requirement does not specify solid bottom chocks. It does require two chocks that together hold the rig on a 20 percent grade and also specifies it is on a hard surface. Interestingly, NFPA 1901 infers both chocks should be used, and it must be on a hard surface.]
• NFPA 1906 Section 5.71 requires a minimum 2A-10B:C extinguisher for rigs with a GVWR less than 33,000 pounds. [NFPA 1901 requires full-size pumpers and initial attack apparatus to carry one 80-B:C rated dry chemical and a 2½-gallon water extinguisher.]
• NFPA 1906 Section 5.72 requires a very limited list of ancillary equipment that must be carried. [NFPA 1901 has extensive lists of ancillary equipment that must be carried on full-size pumpers and initial attack apparatus—probably the most expensive piece being an automatic external defibrillator (AED). How many grass fire trucks carry AEDs?]
• NFPA 1906 Chapter 5 Pumps: [Without getting into the particulars of fire pump specifications, pumps on NFPA 1901 apparatus are designed and sized for structural firefighting, whereas NFPA 1906 apparatus don’t have to be. Another NFPA 1901 requirement for pump-equipped apparatus, probably not necessary on a grass fire truck, is a provision for storage for two 1½-inch or larger preconnects.]
• NFPA 1906 Table 12.1.2 Minimum Miscellaneous Equipment Allowance requires a 200-pound allowance for equipment. [NFPA 1901 requires a 2,000-pound allowance for equipment on pumpers and 900 pounds on initial attack apparatus—a huge difference.]
• NFPA 1906 Appendix Sentence A.12.1 Off-Road Use: “If the apparatus is designed for off-road use, it is recommended that the apparatus, when loaded to its estimated in-service weight, should not exceed 80 percent of the chassis GVWR. In addition, the axle loads should not exceed 80 percent of the appropriate gross axle weight rating (GAWR). If the vehicle chassis manufacturer certifies the GVWR and GAWR for 50 percent minimum off-road use, the full weight ratings can be utilized.” [This is important. Has anyone ever determined a grass fire truck will only be used 50 percent of the time off the road? Has anyone ever asked a chassis manufacturer for certification?]
• NFPA 1906 Table 12.3.2.2 Under-Vehicle Clearance requires 12 inches of under-vehicle clearance for vehicles with 10,001-pound to 15,000-pound GVWR. [NFPA 1901 only requires eight inches of clearance—one-third less.]
• NFPA 1906 Sentence 12.3.2.3: “An angle of approach and an angle of departure of at least 20 degrees shall be maintained at the front and the rear of the vehicle when it is loaded to the estimated in-service weight.” [NFPA 1901 only requires eight degrees—60 percent less. Be careful going across lots and stump jumping.]
• NFPA 1906 Sentence 13.8 Optical Warning Devices: “Each apparatus that responds on public roads as an emergency vehicle by calling for or blocking the right-of-way from other traffic shall have a system of optical warning devices that meets or exceeds the requirements of this section; if the vehicle is not equipped to call for or block the right-of-way on a public highway, a sign shall be affixed on the dashboard that reads as follows: ‘This apparatus is not equipped to call for or block right-of-way on public highways.’ ” [NFPA 1901 requires warning lights with no caveat.]
• NFPA 1906 Sentence 13.9.2 says a siren is only needed if the rig is going to respond as an emergency vehicle on public roads. [NFPA 1901 says the rig will have a siren—period.]

It is obvious that there are significant design and performance expectations between rigs designed for off-road “vegetation” fires vs. structural firefighting. Purchasers should be cognizant that when writing purchasing specifications for a grass fire truck if they refer to one of the NFPA standards, the manufacturer is obligated to and probably will follow it verbatim. Fire departments may inadvertently be specifying more grass fire truck than they need or unfortunately one that performs less than expected.

ALTERNATIVES

If purchasers do not want or need a grass fire truck meeting all the requirements of an NFPA 1901 initial attack apparatus or an NFPA 1906 wildland fire suppression apparatus, there are a couple of courses of action that could result in a fully compliant vehicle.

NFPA 1901 Chapter 3 describes a special service fire apparatus as “a multipurpose vehicle that primarily provides support services at emergency scenes.” It appears to be an all-inclusive category in which an auxiliary fire apparatus such as a grass fire truck may fit. Perhaps specifying a grass fire truck to be compliant with NFPA 1901’s Chapter 10 and equipping it with an auxiliary pump per Chapter 17 may be a solution.

Another possibility is specifying a grass fire truck that is the second piece of a two-piece company, pairing it up to respond with a fully compliant apparatus. I would think any mandated equipment could be apportioned between the two rigs—a local decision. It does not appear that either NFPA 1901 or NFPA 1906 prohibits end users from doing so.

Or, purchasers could do whatever they feel comfortable with and trust they will not be held accountable if they are ever challenged. Purchasers, as well as those who build their own grass fire trucks, are encouraged to interact with the authority having jurisdiction to determine what, if any, NFPA standard or part thereof a grass fire truck must comply with.

It may be in a fire department’s best interests to seek legal counsel beforehand rather than after the fact in the event of an unfortunate “incident” with a grass fire truck that results in insurance claims or litigation. Remember: If you wrote the specs and signed the check, you own the truck. Good luck.

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.