Legislation about emergency escape and self-rescue ropes and system components for firefighters has created a lot of confusion for fire departments throughout the state of New York. Department of Labor Code Rule 800.7 is now in full effect and departments must take immediate action to become compliant or risk receiving a citation from Public Employee Safety & Health (PESH).
The law requires that the authority having jurisdiction take four distinct steps: completing a risk assessment, reviewing and editing SOPs, purchasing equipment if needed and training firefighters. Despite a legal challenge, the “final” regulation went into effect on December 2, 2009. Although another lawsuit regarding the legislation is ongoing, the New York State Association of Fire Chiefs encourages departments not to delay compliance with the final regulation.
“Departments need to be moving forward on compliance with this legislation,” said Thomas LaBelle, Executive Director of the New York State Association of Fire Chiefs. “If the Department of Labor shows up and you have done nothing, you are going to have trouble.”
“The law has gone into effect,” said Chief John P Brown, Chief Instructor at the Nassau County Fire Service Academy. “There are no more deadlines. The deadlines have come and gone.”
All of us in the fire service may struggle to understand the intricacies of the new law, the implications of the lawsuit and how best to comply for each of our individual departments. We leave it to the lawyers and politicians to battle it out. Meanwhile, we have a few ideas that might help:
Step One: Complete a Risk Assessment. The first step toward compliance is to conduct a thorough risk assessment to determine when escape ropes might be necessary and what type of ropes and system components will be needed. That risk assessment should put into writing the types of structures firefighters may encounter, as well as the height of buildings in the area and how many buildings there are at each height.
Each department is responsible for providing appropriate escape equipment to interior firefighters, even when those firefighters are working outside their own district. Therefore you must be ready with equipment that meets your own needs, as well as the needs of districts to which you provide reasonable mutual aid.
Step Two: Review and Edit your SOPs. Once a risk assessment is completed, you will need to look closely at your standard operating procedures to determine whether those procedures allow for effective rescue of firefighters from elevations, or if changes are needed to address this possibility.
Step Three: Purchase Equipment if Needed. The risk assessment and SOP changes also provide a guide to the type of equipment each department will need for its individual circumstances–and purchasing equipment, if it is needed, is the next step to compliance. Appropriate equipment must be provided for interior structural firefighters–those firefighters at risk of entrapment at elevation.
Step Four: Train your Firefighters. Once appropriate ropes and system components are available for all interior firefighters, the last step in compliance is to train them thoroughly on any new equipment.
While becoming compliant may seem difficult or confusing, there are a few pieces of advice that may help the process go more smoothly.
1. Consult your legal counsel. Ask specifically how this legislation directly affects your department and what steps you need to take. Get clarification on anything you’ve heard from other sources.
2. Ask for advice and input. Ask departments bordering yours for their risk assessments and consider working from those where appropriate.
3. Work together. Get together with your mutual aid area and see if you can save dollars and time by purchasing equipment together or training together.
Attend a Special Forum
Chief John P Brown will hold a forum on April 11, 2010 at the Nassau County Fire Service Academy from 9 a.m. to 4 p.m. to discuss how to conduct a risk assessment and to share resources and ideas among fire departments throughout New York State. Departments will also have a chance to try out various systems to see which might be right for them. There will be no charge to any departments that want to send a delegation. Registration is required for this important forum
For complete details on the Nassau County Forum contact:
NY Fire Rescue Training Group
Dennis Amodio Tom O’Brien
(941) 628-3854 (516) 672-7570
(212) 239-9051
dennis@nyfirerescue.com tom@nyfirerescue.com
