This bill tasks California's occupational safety board and the Department of Industrial Relations with regular, structured reviews of the state's firefighter personal protective equipment (PPE) regulations to keep them aligned with National Fire Protection Association (NFPA) standards. It creates an advisory committee, a five‑year review cadence, and a required consideration by the board of specific modifications when consensus NFPA revisions offer greater protection than existing state safety orders.
The statute adds a targeted environmental‑health requirement: by January 1, 2028 the board must consider modifying the PPE safety order to remove or avoid NFPA performance requirements that are irrelevant to how firefighters actually use PPE yet drive the use of hazardous substances (specifically PFAS, fluoropolymers, and flame retardants). The bill directs the board to adopt California performance standards based on scientific research (using the 2025 NFPA 1970 as a minimum floor), require manufacturer certification of compliance, phase in changes (garments first, auxiliary gear later), and phase out older equipment through attrition or within 10 years.
It also imposes a progress report requirement to the Governor and Legislature.
At a Glance
What It Does
Establishes a recurring review process to align California's firefighter PPE safety orders with NFPA standards and requires the board to consider modifying those orders to eliminate requirements that lead to PFAS and other hazardous substances in PPE. It mandates scientific‑based performance standards (using 2025 NFPA 1970 as a floor), manufacturer certification, phased implementation, and a reporting duty.
Who It Affects
State regulators (Cal/OSHA board and DIR), municipal and county fire departments (career and volunteer), PPE manufacturers and suppliers, procurement officers, and public purchasers responsible for replacing or certifying firefighter gear.
Why It Matters
The bill creates a durable mechanism for keeping state PPE rules current with NFPA while explicitly prioritizing long‑term health and environmental risks from chemical additives in gear—shaping procurement, product design, and compliance work across the firefighting ecosystem.
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What This Bill Actually Does
The statute layers three recurring regulatory duties on top of California’s existing firefighter PPE framework. First, it requires convening an advisory committee of labor and management experts who understand firefighter garments and practices; that committee evaluates whether current state safety orders need changes to align with NFPA standards.
Second, it makes the board and department responsible for a comprehensive review of NFPA revisions on a five‑year cycle; when NFPA changes provide greater protection than the state rules, the board must consider and decide on adoption of matching or alternative state standards within a fixed one‑year decision window.
Third and most notable, the law directs a targeted substantive review tied to chemical exposures: by January 1, 2028 the board must consider modifying the PPE safety order to address instances where NFPA performance requirements are not applicable to real‑world firefighter use yet result in PPE that contains PFAS, fluoropolymers, flame retardants or similar hazardous substances. The statute requires the board to rely on scientific research to define California’s PPE performance standard, explicitly using the 2025 edition of NFPA 1970 as a minimum benchmark rather than an absolute ceiling.Practically, the bill requires future‑certified firefighter garments to be free of hazardous substances that could pose long‑term risks, and it obligates manufacturers to certify that their products meet the new California standards.
It staggers implementation: firefighting garments face an earlier compliance date while auxiliary items (SCBAs, hearing protection, communication devices, fall‑protection) get a later timeline. The law also sets a phase‑out approach for in‑service gear—replacement through normal attrition or no later than ten years after the safety order is modified—and it directs the Division of Occupational Safety and Health to report on progress to the Governor and Legislature by July 1, 2026.
The Five Things You Need to Know
The board must perform a comprehensive review of NFPA revisions for firefighter PPE every five years beginning July 1, 2018, and if NFPA revisions provide greater protection the board must decide whether to change state orders by July 1 of the following year.
By January 1, 2028 the board must consider modifying the PPE safety order specifically to avoid NFPA performance requirements that lead to use of PFAS, fluoropolymers, flame retardants, or similar hazardous substances in gear.
The law requires the board to use scientific research to set California PPE performance standards, treating the 2025 NFPA 1970 as a floor (minimum benchmark) rather than an automatic federal‑style adoption.
Manufacturers of firefighter PPE must certify that their future products meet the new California standards and are free of hazardous substances that may pose long‑term health or environmental risks.
The statute phases implementation: firefighting garments have an earlier compliance date than auxiliary PPE, and existing gear must be phased out via normal attrition or replaced no later than 10 years after the safety order is modified; DIR must report progress by July 1, 2026 (report requirement sunsets 7/1/2030).
Section-by-Section Breakdown
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Advisory committee to evaluate NFPA alignment
The department must convene an advisory committee composed of management and labor representatives, covering a cross‑section of the fire protection industry and community, with demonstrated knowledge of firefighter clothing, equipment, and practices. The practical effect: California builds operational expertise into regulatory reviews, ensuring that proposals to align with NFPA standards are vetted by practitioners who understand real‑world tradeoffs between protection, mobility, and durability.
Committee findings and board decision timeline
The advisory committee must present findings and recommendations to the board, which is bound by a one‑year decision deadline to act on proposed changes. That creates predictable regulatory pacing: stakeholders can expect committee input to lead to a board decision within defined dates, compressing the administrative timeline for adopting or rejecting changes to state safety orders.
Five‑year comprehensive NFPA review and decision trigger
Beginning on the statutory schedule, the board—consulting with the department—must review all revisions to NFPA standards relevant to the specified safety orders every five years. Where NFPA revisions demonstrably offer a greater degree of protection than the state rules, the board is required to consider modifying state safety orders and to render a decision by July 1 of the following year. That provision turns NFPA updates into a recurrent compliance trigger rather than a one‑off event.
2028 directive to address PFAS and hazardous additives; scientific‑based California standard
This is the bill’s substantive pivot: the board must consider modifying the PPE safety order to address NFPA performance elements that are irrelevant to firefighter use yet result in PFAS, fluoropolymers, flame retardants, or similar hazardous substances in garments and auxiliary PPE. The board must base any modified standard on scientific research and use the 2025 NFPA 1970 as a floor. The statute also requires that certified future PPE be free of specified hazardous substances, obliges manufacturers to certify compliance, staggers implementation between garments and auxiliary gear, and establishes a phase‑out window (attrition or a 10‑year cap). These mechanics place material composition and certification squarely into regulatory compliance and procurement planning.
Progress reporting and sunset for report requirement
The Division of Occupational Safety and Health must report to the Governor and Legislature on progress toward implementing the modified PPE standards by July 1, 2026. The reporting duty is subject to state statutory filing rules and the specific report requirement sunsets (becomes inoperative) on July 1, 2030. The effect: the Legislature will receive an interim accountability checkpoint while Congress and agencies work through the longer‑term implementation timeline.
Definitions of covered equipment
The statute defines 'auxiliary firefighting PPE' (SCBAs and other respiratory protection, hearing protection, communications, fall protection) separately from 'firefighting personal protective garments' (jackets, pants, gloves, helmets, shoes). Those definitions delimit which items get the earlier garment implementation date and which get the later auxiliary timetable—an important distinction for procurement and inventory planning at fire departments.
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Explore Employment in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Career and volunteer firefighters — Reduces long‑term exposure risk by steering regulation toward PFAS‑free and lower‑toxicity materials, potentially lowering cancer and chronic‑disease risks tied to chemical additives in PPE.
- Fire departments and procurement officers — Gets clearer, periodically updated standards and a statutory phase‑in schedule that helps plan budgeting and replacement cycles, reducing uncertainty about future compliance requirements.
- Manufacturers of PFAS‑free PPE — Creates market demand and regulatory preference for products that meet California’s scientific‑based standard and manufacturer certification, rewarding early movers who invest in alternative materials.
- Public health and environmental advocates — Lowers future environmental release and disposal of PFAS‑containing gear by prioritizing non‑PFAS materials in state procurement and standards.
Who Bears the Cost
- PPE manufacturers currently using PFAS or flame retardants — Face R&D, reformulation, testing, and recertification costs to meet California’s PFAS‑free certification requirement and keep competitive access to a large state market.
- Local fire agencies and smaller jurisdictions — Will absorb increased procurement costs and logistics of replacing in‑service gear over the phase‑out period, which can stress small budgets and volunteer departments.
- State regulatory agencies (DIR/Cal/OSHA) — Must manage advisory committees, scientific reviews, rulemakings, compliance monitoring, and the mandatory progress report—requiring staff time and potentially new technical capacities.
- Supply chains and distributors — May see transitional shortages or price pressure as demand shifts toward PFAS‑free alternatives and suppliers retool production lines.
Key Issues
The Core Tension
The central dilemma is trade‑off between immediate, proven protection against acute firefighting hazards (heat, flame, penetration) that NFPA performance tests ensure, and the long‑term health and environmental harms from chemicals (PFAS, flame retardants) historically used to achieve that protection; the statute pushes regulators to pick solutions that preserve operational performance while eliminating hazardous chemistries—a technically demanding and potentially costly balancing act with no guaranteed win for both objectives simultaneously.
The bill pins California standards to scientific research while also treating the 2025 NFPA 1970 as a floor. That creates a two‑track dynamic: the state will not automatically adopt NFPA text verbatim, but it will use NFPA as a minimum benchmark.
Implementers will need to reconcile scientific data about long‑term chemical harms with well‑tested NFPA performance tests that historically relied on certain chemistries to meet thermal, durability, and water‑repellency metrics. Determining when an NFPA requirement is 'not relevant or applicable' to firefighter use will be judgmental and fact‑intensive; expect disputes among NFPA proponents, manufacturers, and labor groups over the factual record used to justify departures.
Operationally, phasing out hazardous‑chemical‑containing gear through attrition or a 10‑year maximum leaves a long tail of in‑service equipment; that preserves near‑term readiness but delays full exposure mitigation. The manufacturer certification requirement places responsibility on private firms to attest to compliance, but the statute does not detail testing protocols, third‑party verification, or enforcement mechanisms—gaps that will matter when compliance is contested.
Finally, the timeline and sequencing (garments first, auxiliary later) reshapes procurement prioritization but could create mismatches between protective garments and auxiliary equipment if substitutes for PFAS‑dependent performance are not certified in step with garments.
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