Revised Compliance Testing Process for Body Armor 9 th Annual Technologies for Critical Incident Preparedness Conference San Francisco, California November 6, 2007 Revised Compliance Testing Process for Body Armor 9 th Annual Technologies for Critical Incident Preparedness Conference San Francisco, California November 6, 2007 NATIONAL LAW ENFORCEMENT AND CORRECTIONS TECHNOLOGY CENTER SYSTEM Lance Miller Director National Law Enforcement and Corrections Technology Center–National Rockville, Maryland Lance Miller Director National Law Enforcement and Corrections Technology Center–National Rockville, Maryland

Today’s Discussion Topics… 4 Update on Revisions to the Body Armor Standard ( ) and Compliance Testing Program. 4 Discussion of New Administrative Strategies for Compliance Testing Program. 4 Update on Revisions to the Body Armor Standard ( ) and Compliance Testing Program. 4 Discussion of New Administrative Strategies for Compliance Testing Program.

Revision to NIJ Body Armor Standard ( ) and Compliance Testing Program Discussion Topic #1

Early 1970s – Research program to develop lightweight body armor (Kevlar ® ). Field testing with 5,000 armors – 18 “saves” during 1-year demonstration ( ). NIJ developed voluntary standards/testing program at request of law enforcement (ca. 1978) Standard specifies minimum performance requirements and associated test methods. In 30+ years, more than 3,000 lives saved. Early 1970s – Research program to develop lightweight body armor (Kevlar ® ). Field testing with 5,000 armors – 18 “saves” during 1-year demonstration ( ). NIJ developed voluntary standards/testing program at request of law enforcement (ca. 1978) Standard specifies minimum performance requirements and associated test methods. In 30+ years, more than 3,000 lives saved. History of NIJ Body Armor Standard History of NIJ Body Armor Standard

Current CTP model established in 1985 (TAPIC, NIJ Standard ). Since 1987, NIJ has tested >5,000 models [More than 2,500 models passed requirements.] Testing has been limited to new armor – has not addressed used armor. Many law enforcement agencies use the NIJ program to select and procure body armor. NIJ Standard revised periodically to reflect changes in threats, technology, and testing methods. Current CTP model established in 1985 (TAPIC, NIJ Standard ). Since 1987, NIJ has tested >5,000 models [More than 2,500 models passed requirements.] Testing has been limited to new armor – has not addressed used armor. Many law enforcement agencies use the NIJ program to select and procure body armor. NIJ Standard revised periodically to reflect changes in threats, technology, and testing methods. History of NIJ’s Body Armor Standard (continued)

Independent Laboratories approved for CTP testing, selected jointly by NIJ, NLECTC, OLES (based on old NVLAP processes/procedures – ca. 1980’s). Armor manufacturers select an approved laboratory where armor is tested and pay test costs directly to laboratory. Samples inspected pre- and post-test by NLECTC. NLECTC maintains archival storage of tested samples; provides a list of models tested and found to comply with the NIJ Standard. Independent Laboratories approved for CTP testing, selected jointly by NIJ, NLECTC, OLES (based on old NVLAP processes/procedures – ca. 1980’s). Armor manufacturers select an approved laboratory where armor is tested and pay test costs directly to laboratory. Samples inspected pre- and post-test by NLECTC. NLECTC maintains archival storage of tested samples; provides a list of models tested and found to comply with the NIJ Standard. History of NIJ’s Body Armor Standard (continued)

DOJ Body Armor Safety Initiative In June 2003, a police officer in Forest Hills, Pennsylvania, was seriously injured when a bullet penetrated his body armor, made of Zylon ® -based materials. This was the first documented incident in the 30-plus-year history of NIJ’s body armor testing program that an NIJ-compliant armor was penetrated by a bullet that the armor was rated to stop. In November 2003, then-Attorney General John Ashcroft, in response to NIJ’s review of this incident and concerns from the law enforcement community, directed NIJ to: u Examine new and used Zylon-based armors. u Examine “upgrade kits” offered by manufacturers. u Review current testing/certification process and make recommendations for modifications. In June 2003, a police officer in Forest Hills, Pennsylvania, was seriously injured when a bullet penetrated his body armor, made of Zylon ® -based materials. This was the first documented incident in the 30-plus-year history of NIJ’s body armor testing program that an NIJ-compliant armor was penetrated by a bullet that the armor was rated to stop. In November 2003, then-Attorney General John Ashcroft, in response to NIJ’s review of this incident and concerns from the law enforcement community, directed NIJ to: u Examine new and used Zylon-based armors. u Examine “upgrade kits” offered by manufacturers. u Review current testing/certification process and make recommendations for modifications.

Previous Key Findings (continued) NIJ’s research indicated that its testing program should take into account the possibility of ballistic performance degradation over time.  In complete agreement with law enforcement input at the March, 2004 summit. NIJ’s testing program to date has been based on the ballistic resistance of new armor and does not take into account performance degradation in used armor. NIJ’s research indicated that its testing program should take into account the possibility of ballistic performance degradation over time.  In complete agreement with law enforcement input at the March, 2004 summit. NIJ’s testing program to date has been based on the ballistic resistance of new armor and does not take into account performance degradation in used armor.

2005 Interim Requirements On September 26, 2005, NIJ implemented the new 2005 Interim Requirements for Bullet Resistant Body Armor (“2005 IR’s”) Core Requirements of 2005 IR’s In order to be listed as a compliant model- The body armor model must be tested through NIJ’s Voluntary Body Armor Compliance Testing Program and be found by NIJ to satisfy all of the requirements of NIJ Standard The manufacturers must submit to NIJ specific certifications, information and acknowledgements concerning ongoing performance, materials of construction, labeling of the armor, NIJ’s research findings and certain related matters. On September 26, 2005, NIJ implemented the new 2005 Interim Requirements for Bullet Resistant Body Armor (“2005 IR’s”) Core Requirements of 2005 IR’s In order to be listed as a compliant model- The body armor model must be tested through NIJ’s Voluntary Body Armor Compliance Testing Program and be found by NIJ to satisfy all of the requirements of NIJ Standard The manufacturers must submit to NIJ specific certifications, information and acknowledgements concerning ongoing performance, materials of construction, labeling of the armor, NIJ’s research findings and certain related matters.

DOJ Body Armor Safety Initiative Since the introduction of the 2005 IR’s, NIJ has continued its research and evaluation program to: Determine what additional modifications to the requirements of the standard and NIJ’s compliance testing program may be appropriate. Work is nearing completion on revised standard and compliance testing program. Understand better the degradation mechanisms affecting existing or new ballistic materials. Develop test methods to evaluate the ongoing performance of body armor. (Environmental conditioning, non-destructive tests, etc.) Since the introduction of the 2005 IR’s, NIJ has continued its research and evaluation program to: Determine what additional modifications to the requirements of the standard and NIJ’s compliance testing program may be appropriate. Work is nearing completion on revised standard and compliance testing program. Understand better the degradation mechanisms affecting existing or new ballistic materials. Develop test methods to evaluate the ongoing performance of body armor. (Environmental conditioning, non-destructive tests, etc.)

DOJ Body Armor Safety Initiative NIJ has continued to seek input regarding changes or recommendations to the standard and compliance testing program: November 2005 and February 2007: Technical Workshops held at NIST, with input from public safety and armor industry representatives. Operational Needs and Requirements for future NIJ-sponsored research developed through input from Technical Working Group and LECTAC. All parties (public safety agencies, armor industry, other interested parties) are welcome to provide input.

New Strategies Under Consideration for Compliance Testing Program Administrative Processes Discussion Topic # 2

New Strategies Under Consideration for Administrative Processes Important Note: The following discussion will focus on points and strategies that are currently being considered by NIJ. They are not final. They are subject to revision or change, pending input from stakeholders, further scientific and legal review, and final NIJ review and approval. Important Note: The following discussion will focus on points and strategies that are currently being considered by NIJ. They are not final. They are subject to revision or change, pending input from stakeholders, further scientific and legal review, and final NIJ review and approval.

General Compliance Testing Program Administration (NLECTC): Possible strategies for addressing ongoing performance of armor during manufacturer declared warranty period. Compliance status of models subject to periodic renewal. Conformity Assessment process, to include periodic collection and testing of production units, based on manufacturer-provided data (reflective of quantity of units manufactured). Comparison of construction to originally tested samples. Progressively adjustable – frequency of sampling and retesting may decline based on satisfactory performance; may increase based on unsatisfactory performance. Less frequent sampling and retesting for manufacturers that adopt and implement quality management systems (e.g., ISO 9000), with additional requirements specific to manufacturing of body armor. General Compliance Testing Program Administration (NLECTC): Possible strategies for addressing ongoing performance of armor during manufacturer declared warranty period. Compliance status of models subject to periodic renewal. Conformity Assessment process, to include periodic collection and testing of production units, based on manufacturer-provided data (reflective of quantity of units manufactured). Comparison of construction to originally tested samples. Progressively adjustable – frequency of sampling and retesting may decline based on satisfactory performance; may increase based on unsatisfactory performance. Less frequent sampling and retesting for manufacturers that adopt and implement quality management systems (e.g., ISO 9000), with additional requirements specific to manufacturing of body armor. New Strategies Under Consideration for Administrative Processes

Approved Testing Laboratories: Approved laboratory for CTP would be those accredited by NIST’s National Voluntary Laboratory Accreditation Program (NVLAP). Transition period anticipated to allow laboratories to obtain NVLAP accreditation. Federal Register notice announcing NVLAP Program to be released imminently. NVLAP Program is operational now. All Laboratories that apply by December 15, 2007 will be processed in the initial “batch.” Approved Testing Laboratories: Approved laboratory for CTP would be those accredited by NIST’s National Voluntary Laboratory Accreditation Program (NVLAP). Transition period anticipated to allow laboratories to obtain NVLAP accreditation. Federal Register notice announcing NVLAP Program to be released imminently. NVLAP Program is operational now. All Laboratories that apply by December 15, 2007 will be processed in the initial “batch.” New Strategies Under Consideration for Administrative Processes

Possible Strategies for Fee Structure and Laboratory Selection: Fees associated for initial Compliance Testing Program Activities (e.g., laboratory testing to determine compliance) paid by manufacturers to NIJ-qualified laboratories. Fees associated for follow-on Compliance Testing Program activities (e.g., conformity assessment activities) paid by manufacturers to NLECTC. NLECTC, not the manufacturer, will select the approved laboratory where products are tested, and disburse fees to labs. Possible Strategies for Fee Structure and Laboratory Selection: Fees associated for initial Compliance Testing Program Activities (e.g., laboratory testing to determine compliance) paid by manufacturers to NIJ-qualified laboratories. Fees associated for follow-on Compliance Testing Program activities (e.g., conformity assessment activities) paid by manufacturers to NLECTC. NLECTC, not the manufacturer, will select the approved laboratory where products are tested, and disburse fees to labs. New Strategies Under Consideration for Administrative Processes

Armor Manufacturers: Possible strategy for enhanced documentation: Standardized “build sheet” template, fully documenting construction details. Discussion of using manufacturer-provided production statistics to develop retest frequency scenarios. Discussion of manufacturers having processes in place for traceability of production units (serial # tracking for manufacturer- initiated recalls). Armor Manufacturers: Possible strategy for enhanced documentation: Standardized “build sheet” template, fully documenting construction details. Discussion of using manufacturer-provided production statistics to develop retest frequency scenarios. Discussion of manufacturers having processes in place for traceability of production units (serial # tracking for manufacturer- initiated recalls). New Strategies Under Consideration for Administrative Processes

General Compliance Testing Program Administration (NLECTC): Possible strategies to revise current process for addressing “appeals” and complaints. Impartial committee to review “appeals” and complaints. Committee members selected from various organizations based on technical qualifications and subject matter expertise. Organizations under consideration include Law Enforcement Organizations such as IACP, FOP, and NSA; Technical organizations such as US Army Natick Soldier Center, NIST TS/SCCG, and ANSI. General Compliance Testing Program Administration (NLECTC): Possible strategies to revise current process for addressing “appeals” and complaints. Impartial committee to review “appeals” and complaints. Committee members selected from various organizations based on technical qualifications and subject matter expertise. Organizations under consideration include Law Enforcement Organizations such as IACP, FOP, and NSA; Technical organizations such as US Army Natick Soldier Center, NIST TS/SCCG, and ANSI. New Strategies Under Consideration for Administrative Processes

NIJ Standards & Testing Program –Debra Stoe, Program Manager Wk: NLECTC National, Compliance Testing Program –Lance Miller, Director Wk: National Institute of Standards and Technology (NIST), Office of Law Enforcement Standards (OLES) –Kirk Rice, Program Manager — Weapons and Protective Systems Wk: Further Questions?

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