By Steve Sanborn – Publisher, CODE 3

As GSA Triple K specifications for ambulances makes the likely shift to NFPA specifications, questions abound – and so do answers.

In any industry, processes, standards and practices which come before our day or era have their own history and reasons for having been established.  We can easily become used to ‘the way we do things’ without having a real connection to them or understanding why we do them.  And when those things change, any number of forms of communication can rear up causing confusion, doubt, suspicion, mixed messages and more.

The object of this article is to address the EMS community and lay down a foundational understanding of the likely shift from the use of GSA’s Triple K specifications for ambulance purchasing to the currently developing NFPA standards.  This requires a history of the facts as well as how they lead to the current changes, what the status of the changes are, and how the EMS community can participate in them. 

History of GSA’s Triple K Specifications for Ambulance Purchasing

Taken directly from GSA’s website:  GSA oversees the business of the U.S. federal government. GSA’s acquisition solutions supplies federal purchasers with cost-effective high-quality products and services from commercial vendors.

In the early 1970s, the General Services Administration (GSA) created the first written list of specifications for the federal government’s purchase of ambulances.  In other words, GSA used these specifications, to bid for and purchase ambulances.  The Triple K specifications were not intended to be industry standards, just the federal government’s own way to buy ambulance vehicles.  To date, GSA has issued Triple K specifications, versions A – F.

As GSA automotive commodities specialist, John McDonald, puts it, “the federal specifications for the ambulance is a document written by the government to buy its roughly 150 to 200 ambulances per year and obtain a quality commercial product.”

McDonald also points out that the use of this specification by State and local Governments is permitted but the use of this specification is voluntary. For State governments, each State Department of Health generally determines if their state wishes to use this specification.

A couple of additional issues helped to morph these specifications into the private sector “standards” they are understood to be today.

In 1972, the Department of Transportation, DOT, after having performed its own studies, requested the GSA form ambulance specifications based on those studies.

Excerpt from the June 27, 1972 letter from the U.S. Department of Transportation

National Highway Traffic Safety Administration to the Acting Administrator of

General Services Administration:

“…we have conducted extensive studies and demonstration projects to improve various elements of the emergency response system… A vital part of the emergency response system is the surface emergency ambulance vehicle and we have found that there is a lack of design standardization in this vehicle. Literally thousands of such ambulances are not configured to make possible optimal care to patients during transit to a medical facility.”

 At the time GSA instituted its specifications, there were no other organizations doing comparable research and testing for the development of ambulance standards and this created a certain impression of standardization within the EMS industry. 

Also important to understand is the role Block Grants played in this history.  A Block Grant was a large sum of money granted by the federal government to a regional government with only general provisions as to the way it is to be spent.

Several years after the development of the Triple K specifications, Block Grants, offered by the Department of Transportation, came available for ambulance purchasing and since the grant funds came from the federal government, regional ambulance purchasers were required to meet the minimum Triple K specifications in order to qualify for the grant. This may have led to a further galvanized impression that ambulances were always required to meet Triple K specifications.  In truth, they have always been voluntary standards. Today despite Block Grants having gone the wayside years ago, most of the nearly six thousand ambulances purchased annually in the US have to meet the Triple K specifications as the minimum standard.

Over time, the specifications have become the de facto standards for much of the ambulance community, either in part or in whole, in 40 of 50 states in the Union because State EMS directors have chosen to adopt legislatively the Triple K standards as their state standards.  

For non-GSA ambulance buyers, this is where the standards have come into play.  It is the state laws and regulations which make the Triple K, and likely in the future, the NFPA specifications, their own mandates, i.e., it is not a federal mandate which defines what can be purchased.

Minnesota, for example, lists as state law the Triple K specifications as the minimum requirement for ambulances.  Other states list some part of the specifications in statutes or rules.  As a matter of course, the Triple K specifications have in part driven the ambulance manufacturing industry.

The last item of significant historical importance is a presidential directive given by President Reagan in the 1980’s. Reagan directed all government agencies, developing and maintaining their own standards and specifications, to seek out whether a private sector solution could be found for this purpose and if so to allow the private sector to provide the function of standard and specification setting.

This does leave a question.  Why now?  If government agencies were directed to find private sector solutions for standard setting in the 1980’s, why is this transition coming around in 2010? More on this in a minute.

The Coming Change

Aarron Reinert, executive director of Lakes Region EMS in Minnesota serves on the NFPA committee as a paramedic and ambulance manager as well as a representative of National Emergency Medical Services Managers Association, NEMSMA.

Reinert says the NFPA process to develop new standards has been and will continue to be a very consensus driven process involving a wide range of stake holders and many opportunities for the community at large to participate.

The committee itself is made of up of a people assigned to different named groups to maintain a balanced approach.  Groups include representatives like regulators with National Association of State EMS Officials, NASEMSO, the National Highway Traffic Safety Administration’s Office of EMS, manufacturers and affiliated laborers, the National Association of EMTs, NEMSMA, insurance companies, Volunteer Fireman’s Insurance Services, VFIS, National Institute for Occupation Safety and Health, NIOSH and the American Ambulance Association, AAA.  Reinert says nearly everyone involved is either a first responder, EMT, paramedic, firefighter, fire chief, or has some affiliation with Fire and/or EMS.

For 3 years, the committee and its functional groups have met to build and review draft specifications line by line considering all aspects.  It is fair to say that debate among the committee members continues to be healthy and lively.  For example, the technical committee group was charged by NFPA to take existing Triple K specifications and translate them into NFPA language without starting from scratch but rather adding only obvious needs.  This has presented questions and concerns about the need for innovation and a need to replace older specifications if they are omitted. 

Nevertheless, the initial draft specifications went through a majority vote among committee members and though not every individual committee member was supportive or unsupportive of each line item, the draft went out to the public for comment on October 26. The comment period closed on December 15 collecting more than 500 comments covering all aspects of the draft document.  Reinert strenuously assures that each of the comments must be reviewed and responded to by the technical committee which will meet again in the first week of February, 2011.

The initial intent of NFPA was to release the draft document earlier for comment, but more time was needed to resolve issues between NFPA and the Ambulance Manufacturers Division, AMD, (a subdivision of the National Truck Equipment Association).  AMD had previously been the author of testing processes specifically for electrical design in ambulances and the two groups needed to determine how each would cite the other’s work for the draft document.  This took longer than expected.  Some have also said the comment period was not communicated as broadly as it could have been, leaving many groups unaware until late November and even early December.

However, this was the first of two comment periods.  The second public comment period is expected toward the end of summer, 2011. This is a particularly important item for the EMS community to be on the watch for.  More also on this in a minute.

While this article is not meant to be a detailed reporting of the draft document comments, Reinert says there is a sort of ‘Top 5 Concerns’ list forming from the first comment period.  Without delving into specifics, they are:

·         A Stability Control System requirement which would affect the speed of ambulance vehicles

·         A seatbelt monitoring system requirement

·         A load capacity requirement which would affect some ambulance types

·         A tire pressure monitoring system requirement

·         A vehicle data recorder system requirement

While certain aspects of the heretofore rather quiet public comment phase and initial concerns collected from it may cause some fear and doubt among the EMS community, Reinert says familiarity with the process is necessary to understand and allay concerns.

Participation in the Standards Process

Reinert says the EMS community is strongly encouraged to review the existing specifications draft and determine individually whether the recommendations are positive or negative.  This will be important for the second public comment period.

The work derived from the assessment of the first comment period will be republished with any changes or adjusted specifications and then reposted and rereleased for comment.  This means, as mentioned, the public will have a second opportunity to comment on changes. Once the second round of comments is in, the committee will again review the comments, make any final changes and forward the draft document to the NFPA standards committee, ultimately to be published in the early 2012.  All in all, this will have been a 3 year process. 

Very important to note, it is NFPA’s intention to immediately put the final specifications back into review making the process a five year ordeal, at which time new innovations and concepts could be included in the final specifications. 

Reinert notes there are really two important opportunities or ways to participate in the NFPA process.

He says users should know this process is happening and engage in it. Be on the lookout for the second public comment period and let your voice be heard.

Next, he says those who regulate ambulance services are really the key to the process.  In the end, the NFPA standards are voluntary standards.  NFPA has no legal authority to require that ambulance services comply with its standards so it is state directors of EMS, or whoever regulates the ambulance service, that will decide whether or not the standards are to be adopted.  EMS personnel should reach out to the regulators to learn whether Triple K specifications are currently required in their region and whether NFPA standards will be adopted when the Triple K specifications go away.  Discussion with regulators about the strengths and weaknesses of the current and coming draft document is highly encouraged.

Your Action Items

To conclude, it must be explained that the reason for the near 30 years between President Reagan’s directive that governmental agencies seek private sector standards providers and GSA transferring the practice to NFPA is pretty straightforward.  The executive order was never rescinded – but there simply was no private sector agency able or willing to perform the task until now.

As it stands, each year GSA has to go through a formal process explaining to the National Institute of Standards and Technology, NIST, why it continues to make its own specifications and has even entertained in the past transferring the specifications process to the American National Standards Institute, but the result in the end was not a standard that could be used by GSA as a procurement tool.

Now with a change in NFPA automotive fire apparatus committee leadership, a new priority has been established for ambulance consensus standards.  The hope is that GSA can abandon the Triple K specifications and transition to NFPA for its own ambulance purchasing the same way it did with automotive fire apparatus some years back.

As for maintaining your awareness of the developing situation with NFPA, watch for an announcement from NFPA regarding the updated draft of standards via the NFPA website, www.nfpa.org.  It may also be helpful to create Google news alerts with keywords such as ‘NFPA’ or ‘NFPA ambulance’ in order to receive updates as they happen. 

Also, as Reinert points out, do not underestimate the power of working with your local regulator.  Make the phone call and/or send the email.  Perhaps start with this article as a means to develop the conversation.  Be sure they are aware of the new standards and express your thoughts and opinions about the matter. 

For more information about the NFPA standards, contact: Aarron Reinert at aarronr@lrems.com