JUSTNET - Body Armor Labeling Requirements: Ballistic-resistant and Stab-resistant Body Armor

Body Armor Labeling Requirements
Ballistic-resistant and Stab-resistant Body Armor

Please note that as of Sept. 26, 2005, NIJ Standard-0101.04 was replaced by the NIJ 2005 Interim Requirements for Bullet-Resistant Armor. The NIJ 2005 Interim Requirements incorporated the test procedures of NIJ Standard-0101.04 in their entirety. The figures linked to below have been updated with the information from the NIJ 2005 Interim Requirements.

Note: This information was previously released to manufacturers as NLECTC Memorandum BA2000-05, dated Dec. 8, 2000.

The release of NIJ Standard-0101.04,Ballistic Resistance of Personal Body Armor and NIJ Standard-0115.00 Stab Resistance of Personal Body Armor has introduced a series of new labeling requirements for manufacturers submitting samples to the Compliance Testing Program (CTP) of the National Law Enforcement and Corrections Technology Center (NLECTC). Additionally, the possibility now exists that one model of armor could comply with multiple versions of the NIJ Standards for Personal Body Armor (i.e., any combination of 0101.03, 0101.04 and 0115.00).

Since the introduction of 0101.04 and 0115.00, NLECTC CTP staff have noticed an increased volume of requests from manufacturers to clarify the intent of the new labeling requirements, as well as an increased level of armor models submitted with labeling that do not comply with the new labeling requirements of 0101.04 and/or 0115.00. The intent of this memorandum is to provide clarification and specific guidance regarding proper labeling requirements and procedures.

The two most significant changes in labeling requirements in both 0101.04 and 0115.00 concern the manufacturer's statement of compliance. Section 4.5.1, "l" of 0101.04, and Section 4.4.1.1, "m" of 0115.00, now requires manufacturers to incorporate a specific statement on the ballistic/stab resistant panel label indicating that the model has been tested by NLECTC and found to comply with an appropriate protection level as defined by NIJ Standard-0101.04 (or 0115.00). However, Section 4.5.1, "m" of 0101.04 and Section 4.4.1.2 of 0115.00 strictly prohibit this statement from appearing on labels for models that have not successfully completed the NLECTC compliance testing process.

The correct interpretation of this requirement is that samples submitted to NLECTC for compliance testing should not have the statement specified in Section 4.5.1, "l" of 0101.04 and Section 4.4.1.1, "m" of 0115.00 on the label. However, in order to verify that a compliant model contains the correct compliance statement once compliance status is granted, it will be necessary for the manufacturer to provide the NLECTC CTP with a copy of the "post-approval" label containing the compliance statement. This "post-approval" label will become part of the permanent compliance file maintained at NLECTC for that model. For the convenience of the manufacturers and to avoid unnecessary delays in the approval process, the CTP will allow manufacturers to submit the "post-approval" label bearing the compliance statement as an attachment to the letter enclosed with the samples at the time of pre-test submission to NLECTC. It is important to note that effective immediately, the NLECTC CTO will no longer issue letters of compliance to manufacturers for models found to comply with the requirements of an NIJ Standard until the CTO is in receipt of an acceptable "post-approval" compliance label. (Figures 1a-1b, Figures 1c-1d)

NLECTC recognizes that this may cause concern for some manufacturers who print "generic" labels in bulk using outside sources, as they will need two sets of labels, one pre-test (without the compliance statement) for compliance testing purposes, and one post-test (with the compliance statement), for production units of a model. In order to facilitate this requirement, we recommend the following options, which are acceptable methods of complying with the requirements and intent of the standard:

Use a secondary label (Figure 2) that contains only the compliance statement. This secondary label can be attached to production units of the model after official compliance status has been granted.

Use "post-test"-compliant labels, but for samples submitted to the CTO for compliance testing, completely obliterate the compliance statement with the use of a black permanent marker (Figure 3).

As the standard does not specify the order in which the required information is presented, place the compliance statement at the top or bottom of the label. For the samples submitted to NLECTC for compliance testing purposes, cut off the top/bottom portion of the label that contains the compliance statement prior to attaching them to the test samples (Figure 4).

A secondary labeling issue resulting from the introduction of 0101.04 and 0115.00 is the appropriate labeling methodology to be used for a model found to comply with both the ballistic and stab resistant standards. In the interest of minimizing labeling errors, NLECTC offers the following guidance with respect to these models:

The voluntary compliance testing programs for ballistic and stab resistant armor operated by the NLECTC CTP in accordance with NIJ Standard-0101.04 and -0115.00, respectively, are separate and distinct testing programs. As such, a manufacturer seeking to obtain compliance status to both standards for a single design of armor must submit the required number of samples, with the correct labeling information, for each standard. No preference will be established as to which standard the model should be tested to first (i.e., stab, then ballistic; or ballistic, then stab), as this will be left to the discretion of the manufacturer. However, manufacturers should be advised that the NLECTC CTP will reject any samples submitted for testing to either standard which contain references in the labeling to other protection capabilities of the model (i.e., ballistic protection for models submitted for stab resistance testing, and vice versa), unless that model has been previously tested through NLECTC and found to comply with the requirements of that standard.

NLECTC recommends that the labeling on any model submitted for compliance testing solely address the protection capabilities for which the manufacturer has submitted the model for testing. If subsequent testing to the other standard determines that the model complies with the protection requirements for a particular protection level/class for both standards, then the manufacturer may choose either of the following options in labeling subsequent production units of that model:

Durably attach two separate labels to each panel, each one complying with the requirements of the specific standard.

Durably attach a "combined" label that meets the informational requirements of both standards (Figure 5).

As always, if you have questions about any of the labeling requirements, you may call the CTP during regular business hours (Monday through Friday, 8:30 a.m. to 5 p.m. Eastern Time) to receive individual assistance from the CTO staff. It is also recommended that if you are a new manufacturer, a currently participating manufacturer who is considering making any modifications to your labels, or a manufacturer located outside of the continental United States, that you fax a sample of your label(s) to the CTP at (301) 519-5149 for review before shipping your samples to the CTP. This will greatly increase the efficiency of the submission process for your model and prevent unnecessary delays in processing.

We thank you for your attention to these matters. The Compliance Testing Program staff is committed to continuing to provide you with a high quality of service. If you have any questions about these requirements, please do not hesitate to contact NLECTC at (800) 248-2742 or (301) 519-5060.

Last updated: Aug. 6, 2009