USING NFPA 1500 TO DEVELOP A HEALTH AND SAFETY PROGRAM

BY DAVID ROSS

The William Stieger Act creating the Occu-pational Safety and Health Act was passed in 1970. It led to the creation of the Occupational Safety and Health Administration (OSHA). The legislation’s intent was to ensure that employers and employees took reasonable precautions to keep their workplaces safe for workers. Although it is a federal law, it seems that many of us in the fire and emergency services continued to see ourselves as different. There was still that macho attitude that saw us not only accepting risks but embracing them as well. As Alan Brunacini has said, “For the past 200 years, we have been providing a service at the expense of those providing the service.”1

Fortunately, Brunacini continued to lead us as the original chair of NFPA 1500, Stan-dard on Fire Department Occupational Safety and Health Program. The pioneers on this committee emphasized that although the fire service is different in many ways, it had to get onboard and start taking care of its own. The goals of NFPA 1500 are “to specify the minimum requirements for an occupational safety and health program for a fire department and to specify safety guidelines for those members involved in rescue, fire suppression, emergency medical services, hazardous materials operations, special operations, and related activities.”2


Are we still providing service at the expense of those performing the service? (Photo by Scott Stilborn.)

This is our document; it helps guide us in what we need to do to protect members’ health and safety. But, you may say, “We are not in an OSHA state!” or “NFPA standards are voluntary consensus standards-why do we need to follow them?” This may be true. However, ask yourself this, “What would be considered reasonable to protect workers’ health and safety under the general duty clause in your jurisdiction?” My guess is that a panel of your peers would deem that to be NFPA 1500.

WHY WE NEED AN OCCUPATIONAL SAFETY AND HEALTH PROGRAM

There are moral and financial arguments that suggest we should be following NFPA 1500. Clearly, protecting our members, diminishing accidents, and minimizing pain and suffering are the “right” things to do. Also, by realizing these goals, we can save the department money in lost time, injuries, medical expenses, and rehabilitation.


Is it safe to enter this structure? Do you think this scenario is covered by the department’s risk management plan for operations? (Photo by Terry Vaura)

Aside from these beneficial arguments, I ask, “Are our injury rates acceptable to you?” “How many firefighter deaths can we reasonably accept?” If you answer none or that is your heartfelt desire, then NFPA 1500 can help point you and your department in the right direction.

SYSTEM VS. PROGRAM

A health and safety system is a set of programs, each fulfilling its own function, that are integrated into the whole organization. These programs work with other elements including policies, standard operating procedures, and training records to achieve common organizational health and safety goals. I prefer the term “system” to program, to differentiate the component parts of the program. For example, the safety and health program should include a wellness and personal protective equipment (PPE) component. By calling the collection of programs a system, it allows us to call the component parts programs without confusing anyone. A systems approach involves the coordination and integration of programs and philosophies. This approach usually includes some form of monitoring to ensure that the various component programs achieve their desired intent. A system is comprehensive. It is designed to promote health and safety and to demonstrate compliance.

OVERVIEW

Keep in mind that from a legal perspective, it makes no difference if the department is a career, composite, or volunteer organization. NFPA 1500 applies across the board and places an onus on the fire department to appoint a safety officer and ensure it has implemented an occupational safety and health program. According to this standard, a fire department occupational safety and health system or program will include

  • Organization/policy,
  • Risk management,
  • Roles and responsibilities,
  • Accident prevention and investigation,
  • Health and safety officer functions (NFPA 1521),
  • Occupational safety and health committee,
  • Training and education,
  • Records management and data analysis,
  • Vehicles and drivers,
  • Personal protective equipment,
  • Emergency operations,
  • Tools and equipment,
  • Facility safety,
  • Infection control,
  • Medical and physical,
  • Member assistance/wellness,
  • Critical incident stress management, and
  • Postincident analysis or review.

NFPA 1500 COMPLIANCE

For fire departments to comply with NFPA 1500, they must meet the requirements outlined in the following categories. Those departments that formally adopt NFPA 1500 would be expected to meet these requirements, or they should develop a phase-in schedule for compliance with specific requirements of this standard.


NFPA 1971- compliant structure firefighting gear. The rear “tail” ensure required overlap while minimizing overall weight (Photo courtesy of Total Fire Group)

Risk Management Plan. NFPA 1500 stipulates that a fire department shall adopt a risk management plan. The risk management plan is an attempt to define what you do, determine the level of risk of those activities, and decide what can be done to minimize this risk through controls (e.g., operating procedures and training).

Note: Review the Appendix. In most NFPA standards, you will often gain an in-depth understanding of the requirement by reading the Appendix. Consider it a critical and essential component of any NFPA standard.

Policy and Roles. Under Policy and Roles, NFPA 1500 tells us that the fire department shall adopt an official occupational health and safety policy (a sample is included in Appendix A.4.3.1) and that it shall be the responsibility of the fire department to research, develop, implement, and enforce an occupational safety and health program. Additionally, fire departments are responsible for compliance with all applicable laws and legal requirements. The fire chief must appoint a designated fire department safety officer who shall be responsible for the management of the occupational safety and health program.


Investigating accidents is one of the safety officer’s duties. If we can learn from our experience, we should be able to limit exposures. (Photo courtesy of author)

Safety Committees. A fire department must have an occupational safety and health committee that will serve in an advisory capacity to the fire chief. This committee shall be comprised of the health and safety officer or safety officer, members (selected by the union if one exists), management, and other resources. The purpose of the committee is to conduct research, develop recommendations, and review safety matters. The committee will typically meet at least semiannually and record and retain minutes of these meetings for the members.

Records and Data Collection. Part of the safety officer’s job is to keep important records for the department and to analyze data to identify trends that can impact or have impacted firefighter safety. You must maintain permanent records of all accidents, injuries, and illnesses; exposures to infectious agents and communicable diseases; and deaths that are or might be job-related. The department should keep individual records of any occupational exposure (toxic products or infectious or communicable diseases) along with the confidential health records for each member. Other records that should be maintained include training records for each member indicating dates; subjects passed; inspection, maintenance, repair, and service records for equipment; and the apparatus and equipment used for emergency operations.

Training, Education, and Standards. From a safety and health perspective, training is delivered to prevent occupational accidents, deaths, injuries, and illnesses. The intent is to ensure that members possess the knowledge and skills they require to perform their work in a safe manner that does not pose a hazard to themselves or others. Qualified people should provide this training. Training for emergency operations should include procedures for a safe exit from the dangerous area if equipment fails or there is a sudden change in conditions. It should be based on emergency operational guidelines or procedures.

All members likely to be involved in emergency operations shall be trained in the incident management system and meet the requirements of Fire Fighter I as specified in NFPA 1001, Standard on Fire Fighter Professional Quali-fications. Training involving live firefighting exercises shall be conducted in compliance with NFPA 1403, Standard on Live Fire Train-ing Evolutions. Members need to be trained in infectious disease control (NFPA 1581, Stan-dard on Fire Department Infection Control Program-2000), and those responding to hazardous materials situations shall meet the requirements of NFPA 472, Standard on Pro-fessional Competence of Responders to Haz-ardous Materials Incidents-1997.

Live Fire Training Evolutions (NFPA 1403). Live fire evolutions provide the most realistic training. NFPA 1521, Standard on Fire Department Safety Officer-1997, references NFPA 1403, which stipulates that a safety officer shall be appointed for all live fire training evolutions. Live fire training includes structures, specifically designed burn buildings, acquired structures located at a remote site, gas-fired permanent training structures, nongas-fired permanent training structures, exterior props, flashover simulators, vehicles, trailers, railroad tank cars, Class A combustibles, exterior Class B fires, liquefied petroleum gas, and flammable/combustible liquids. The primary duties of a safety officer for live fire are to prevent unsafe acts from occurring and to eliminate any unsafe conditions.

The safety officer at a live fire training evolution must not be assigned other duties. He has the authority to intervene and control unsafe parts of the operation. The safety officer shall ensure that the acquired structure is in compliance with the standard by ensuring the structural integrity of the building; removing hazardous materials from the structure; repairing structural members that may create a hazard; repairing stair treads, risers, and railings; securing holes in floors; securing loose floorboards; securing or patching walls and ceilings; securing or removing loose bricks (in walls and chimneys); providing adequate roof ventilation; and ensuring that the utilities are shut off and that trash and low-density combustible fiberboard are removed. The safety officer will also ensure that vermin, insects, and toxic vegetation are removed; exposures are protected; egress routes are provided; a predetermined evacuation plan is developed; and all participants understand the incident management system.

Training Frequency and Content. Training shall be provided as often as necessary but not less than twice each year. Training shall be provided for changes in SOPs, technology, new hazards, and equipment. If your department is responsible for structural firefighting operations, it shall provide structural firefighting training at least monthly and at least 24 hours yearly.

Accident Prevention Program. A component of the Occupational Safety and Health Program is the management of the accident prevention program. This requires providing instruction in safe work practices; training and testing all fire department driver/operators; and periodically surveying operations, procedures, equipment, and facilities to ensure safe practices.

Accident Investigation. The supervisor present at the scene of an accident will ensure that medical aid is available and provided. The health and safety officer shall investigate all occupational injuries, illnesses, exposures, fatalities, unusually hazardous operations, and all accidents involving apparatus, to develop corrective recommendations for the chief. The health and safety officer needs to develop and implement accident and injury-reporting and investigation procedures that comply with local, state, and federal requirements.

Vehicles and Drivers. Firefighter health and safety should be considered in the design and specification of fire apparatus. The safety program should reference NFPA 1901, Standard on Automotive Fire Apparatus-1999, and NFPA 1906, Standard on Wildland Apparatus-2001. Equipment and gear such as SCBA shall be stowed by positive mechanical means. The department needs to ensure that its drivers meet the local requirements and that they have an apparatus specification and preventative maintenance program. Part of this program would be to include records for apparatus use and maintenance. They would include inspections before and after use, conditions, work required or performed, and so on. Furthermore, the work on fire department apparatus should be performed by qualified mechanics to NFPA standards (1911, Standard on Service Tests of Fire Pumps Systems on Fire Apparatus-1997, and NFPA 1914, Standard on Fire Department Aerial Devices-Testing-1997).

Personal Protective Equipment (PPE). Fire departments have a duty to supply protective clothing that is applicable to the level of hazard or exposure. PPE is to be used whenever exposure is threatened. Members need to be trained in the care, use, maintenance, and limitations of their protective equipment. The safety officer should know and understand NFPA 1971, Standard on Protective Ensemble for Structural Fire Fighting-2000 (which also covers PASS devices, eye protection, and hearing protection), and NFPA 1851, which details the selection care and maintenance of PPE. The 2002 edition of NFPA 1500 goes into significantly more detail with regard to SCBA and air cylinders. See Appendix B for what is new in the 2002 edition.

Emergency Operations. NFPA 1500 references and reinforces the incident management system (IMS/ICS) and mandates its use. It is expected that on-scene operations will use emergency risk management, accountability, rapid intervention teams (RIT) for the rescue of members, and rehabilitation for personnel. Your program should also detail to what extent the department would be involved in civil unrest or terrorism. This will vary widely ac-cording to your department, resources, location, and so forth. It is also expected that the department will have and use a postincident review process to ensure that lessons learned are passed on in an attempt to diminish future accidents and injuries.

Facility Safety. Our facilities, the fire stations, are considered to be like other industrial establishments. The facilities should be inspected at least annually for compliance with NFPA 101, Life Safety Code, and month-ly to identify and correct health and safety hazards; conditions that create hazards for members shall be addressed and rectified. Record the results of all inspections; maintain the records for maintenance and repairs.

Medical Requirements. NFPA1500 covers medical requirements for recruits when they join the fire department (which is expanded on in NFPA 1582). The important criteria here is for recruits to obtain recognized performance and medical requirements. This standard is written to ensure members are able to achieve and maintain a requisite level of fitness to safely perform their assigned functions. Medical data and fitness levels, exposures, and injuries will be recorded and maintained in an individual, confidential, and permanent medical database or file. The fire department is also required to employ an infection control program that meets the intent of NFPA 1581 to limit or prevent exposure of members to infectious and contagious disease.

EAP/Wellness/CISM. The fire department must provide a Member Assistance Program or Employee Assistance Program (EAP) to assist members and their families with substance abuse, stress, and family or personal problems that may affect a member’s work performance. The department is also responsible for providing a wellness program that addresses physical fitness levels (aerobic conditioning, strength, and flexibility), along with smoking cessation, nutrition, and how to cope with stress. The department is also required to provide guidance in the management of problems resulting from critical incident stress.

IMPLEMENTING A SUCCESSFUL SYSTEM AND USING THE NFPA CHECKLISTS

Hopefully, by now you have a better understanding of what should be included in the fire department occupational safety and health system or program and what the health and safety officer’s responsibilities are regarding implementation of an occupational safety and health program.

The difficult questions that remain are, How can you establish a priority action plan? Which programs are most important? What actions need to be taken to meet the intent of these standards? Whose authority, permission, or support will be needed? Are barriers or constraints getting in the way? What resources will be required? What is the best way to start?

Review the checklist included in Appendix B of NFPA 1500, and use it to determine where you are not compliant. This section includes 25 pages of practical checklists. They outline what is new in the 2002 edition of NFPA 1500 and provide a list of topics that should be complied with. Then look at your injury statistics, grievances (if you are in a unionized department), issues, and concerns to determine which of the requirements it would be most prudent to address first.

If you can, attempt to delineate the steps needed to meet these requirements, who will do what, and what support they will need. In this fashion, you will be better able to address compliance issues and provide yourself with a defensible strategy or work plan to help guide you in the process.

References

1. Dodson, David, Fire Department Incident Safety Officer, (Delmar, 1999), 10.

2. NFPA 1500, 2002 edition

DAVID ROSS is the chief health and safety officer for Toronto Fire Services, which he joined in 1978. He served in suppression for 10 years and became a training officer in 1989 and chief of safety in 1995. Ross has a master’s degree in adult education, a diploma in fire science technology, and a certificate in occupational health and safety; he is a certified ISO. He has developed several training programs for Toronto Fire Services and has presented numerous seminars in Canada and the United States. He is the international director for the Fire Department Safety Officers Association (FDSOA) and a member of the FDIC Educational Advisory Board. He was the recipient of the NFPA Fellowship Award in 1992 and the George D. Post Instructor of the Year award in 1995.

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