BY RICHARD A. FRITZ
Being a training officer in today’s fire ser-vice is a lot like being a petty officer aboard the Titanic. As you stand on the deck kicking the pieces of ice around, you feel the ship shudder, you hear the water rushing in below your feet, and you know in your heart that the ship is going to sink. You then turn on your heel and look up at the bridge and ask yourself, “Who’s steering this boat, anyway?”
In the fire service, the iceberg is the myriad of standards with which we must comply, including OSHA, NFPA, Insurance Services Office (ISO), NIOSH, EPA, DOT-and all the EMS protocols. Our ship, the fire service, has run headlong into these requirements because we failed to see them on the horizon and began to navigate around them as part of our environment. Broken bits and pieces of the iceberg have hit the deck, causing confusion and making it slippery and hard to maneuver across. The iceberg has not diminished in size, and officers and crews scramble about not knowing what to do or what it all means.
The iceberg continues to loom before us, getting thicker and harder, and keeps punching holes in the sides of our ship. The passengers, our firefighters, who look to us for training and whose lives depend on the information we provide, are confused and angry. They demand to know what is expected of them and what we are going to do to help them.
Who is steering this boat? I have been asking this question all across the country. I began to ask it after I noticed a label on an in-service ladder at my department that basically said that all personnel are required to comply with OSHA, ANSI, and NFPA standards before using this ladder.
As a training officer, I would have to develop a ladder training program that is compliant with NFPA 1001, Fire Fighter Professional Qualifications-1997; NFPA 1932, Use, Maintenance and Service Testing of Fire Department Ground Ladders-1999; OSHA 29 CFR 1926.1053, Ladders; and ANSI A14.2, Safety Requirements for Portable Metal Ladders-1990. We are talking about fire service ladders here. The fire service is not required to meet all of the above standards. Federal OSHA does not have jurisdiction over state and municipal employees; however, state OSHA offices may have.
(b)(1) When portable ladders are used for access to an upper landing surface, the ladder side rails shall extend at least 3 feet (.9 m) above the upper landing surface to which the ladder is used to gain access; or, when such an extension is not possible because of the ladder’s length, then the ladder shall be secured at its top to a rigid support that will not deflect, and a grasping device, such as a grabrail, shall be provided to assist employees in mounting and dismounting the ladder. In no case shall the extension be such that ladder deflection under a load would, by itself, cause the ladder to slip off its support.
This isn’t exactly the way it is spelled out in NFPA 1001 or in the IFSTA Essentials manual, but this is a small thing, not worth getting into too much of an uproar over. If my memory serves me correctly, the fourth edition of the IFSTA Essentials manual recommends at least three rungs (three feet). Although this article isn’t specifically about ladders, the above example does indicate the confusion over standards that exists in today’s fire service.
EMS protocols are also examples of contradictory requirements. Your state EMS people may say one thing, but your medical director (authority having jusidiction, or AHJ) may demand something else. The AHJ wins every time.
IS THE CONFUSION AN EXCUSE TO DO NOTHING?
The fire service seems to be mired in a sinkhole of unattainable standards. When speaking with other training professionals, most of the sentences begin with phrases like “The state says” or “OSHA says” or “NFPA says.” When I ask these same professionals what the standard really “says,” they say they don’t know because they never read it. The fire service is working on urban myths and legends or, worse, training information and standards provided by salespeople. Are we using the confusion as an excuse to do nothing?
I was recently confronted by a training officer who said it was a federal mandate that all firefighters attend SCBA training that involves a maze and search and rescue drills. When I asked to see a copy of this requirement in writing, he could not produce it. He was also unable to tell me which federal document was involved: OSHA, the EPA, or maybe an NFPA standard? To this day, I have not seen that document.
In another class, I was questioned about the OSHA two-in/two-out rule. This training officer was under the assumption that the rule, found in 29 CFR 1910.134 (g), specifies that a rapid intervention team (RIT) be on-site and in place before entry can be made. I asked this individual if he had read the standard; of course, he had not. He was basing his information on what “he had heard.” The 29 CFR 1910.134 standard does not mention RIT teams. It “says” the following:
(g)(4) Procedures for interior structural firefighting. In addition to the requirements set forth under paragraph (g)(3), in interior structural fires, the employer shall ensure that:
(g)(4)(i) At least two employees enter the IDLH atmosphere and remain in visual or voice contact with one another at all times;
(g)(4)(ii) At least two employees are located outside the IDLH atmosphere; and
(g)(4)(iii) All employees engaged in interior structural firefighting use SCBAs.
Note 1 to paragraph (g): One of the two individuals located outside the IDLH atmosphere may be assigned to an additional role, such as incident commander in charge of the emergency or safety officer, so long as this individual is able to perform assistance or rescue activities without jeopardizing the safety or health of any firefighter working at the incident.
Note 2 to paragraph (g): Nothing in this section is meant to preclude firefighters from performing emergency rescue activities before an entire team has assembled.
Where did the RIT team legend come from? It isn’t in the standard. Also, pay special attention to Note 2 to paragraph (g). There is no wording in there that specifically states that there must be an imminent rescue of a viable victim either. OSHA is not trying to tell the fire service how to do its jobs; it is trying to develop standards that will ensure that we stay as safe as possible.
The fire service is its own worst enemy. We believe just about everything anybody tells us. We never ask for it in writing; we never demand that information be proven. We continue to follow urban myths and legends or something somebody once told us. We say we are compliant only when we comply with the parts with which we want to comply. A good example of complying when it’s convenient to do so involves NFPA 1403, Live Fire Training Evolutions-1997. At many of the burns I attended lately, the lead instructor turned away participating students because their turnout clothes were “non-NFPA compliant” (they were wearing OSHA-compliant leather helmets).
As he stood there talking about standard compliance, he was holding a bucket of diesel fuel he was about to splash all over the old farmhouse. NFPA 1403 forbids the use of Class B fuels in live fire training at acquired structures. “We take exception to that part of the rule,” he said when questioned. Take exception? If a state training organization and its instructors can take exception to a rule, why can’t the authority having jurisdiction take exception and replace the questionable part of the standard with a more stringent section or a section that applies directly to the department?
What if those participating in the training take exception to the exception and will not participate in a live burn evolution they have been trained to consider as unsafe because of the presence of class B fuels? What about the chief of the department whose members are being trained? Is he aware that he has invited a noncompliant function to take place within his compliant department?
It should be, and is, straightforward: Either comply with the standard as a whole, or write your own standard and comply with it. You cannot say you are “NFPA compliant” when it is obvious that you are not! Much of the confusion and problems associated with standards is that the fire service, specifically individual fire departments, complies with parts of all the standards only and with no standard in its entirety.
That iceberg looming in front of you is big and thick and is getting thicker by the day. With which standard do you comply? What standard do you pick? Who’s steering this boat, anyway? Two terms are commonly used in standards: “employer” and “authority having jurisdiction, or AHJ.” They should be steering the boat.
DEVELOP AND EXECUTE PROGRAMS SUITED TO YOUR DEPARTMENT
All the standards that affect the fire department have one common theme throughout. That theme is a written program. The fire service, especially the training division, cannot function on hearsay, rumor, or a sales pitch. The training officers of the not-so-distant past had written programs they developed and followed. Granted, they didn’t have the number of standards we have today, but they had then what we lack now: a training program. Where is that program today?
If nothing else, today’s requirements scream for us to return to strongly developed, well-executed training programs!
Does your department have a written training program in place? You cannot possibly comply with all the requirements of any standard without sitting down and analyzing your needs and developing a program. How can you even begin to track the required ISO training hours if you have no program? Developing a program takes work, but it is the only way to determine the manner in which the boat will be steered.
Your first priority as training officer is the safety and well-being of the firefighters you train. The second priority is to develop a program based on the response needs of your department. Meet with the chief or whoever runs your department. Determine the direction the department should take, and go that way. As a training officer, it is your job to provide the chief with information about the department’s training needs and those standards that apply directly to the department.
Develop your training programs based on your department’s needs, and train all firefighters and company officers to that program or “standard.” Will you be in compliance with all the standards? Verbatim, probably not; but intent, yes. If, for example, you develop a ladder training program on the NFPA standards, chances are almost 100 percent that you will also comply with OSHA. OSHA and the NFPA have a close relationship, and many NFPA standards are incorporated by reference into OSHA standards.
In delivering the training, you will most likely comply with ISO training hour requirements as well as any recertification hours your certifying agency dictates. The most important fact, however, is that you have your own “standard” by which you train and hold members accountable. You are far less likely to be compliant if you have nothing in writing and no developed program. Lawyers love training officers who fly by the seat of their pants.
Read the standards. You cannot be compliant with any standard unless you put your hands on a copy of it, open it, and read it. Many standards are straightforward and are written for ease of understanding.
Ask questions. Use the Internet to check on standards and interpretations. The OSHA site not only contains all the standards but also has links to interpretations of those standards to help you comply.
We in the fire service must stop throwing up our hands and whining that we can’t comply. Our fellow firefighters are looking to us for information to keep them safe and help them perform their jobs. As a training officer, you have a duty to those members. Put training in the forefront. We must get back on track.
RICHARD A. FRITZ is a 26-year veteran of the fire service, currently serving as a training captain with the High Point (NC) Fire Department. He previously served with the Muscatine (IA) and Davenport (IA) Fire Departments and the University of Illinois Fire Service Institute. He has taught a variety of hands-on and college-level courses across the country and is the author of the book and video series Tools of the Trade: Firefighting Hand Tools and Their Use, published by Fire Engineering.