Firefighting has continued to evolve to the point where there is more universal recognition of the need for training and compliance with standards by those individuals and organizations that respond to emergencies.
But, there are very specific events that require specialized training and specific equipment. There is not as much “wiggle room” regarding this from a regulatory and standard perspective. These events-hazmat responses and technical rescue scenarios-are relatively late additions to fire departments’ responsibilities, and they have been regulated almost from day one. As such, it behooves organizations to know the requirements so they not only provide the quality service their customers expect but also avoid liability should something go wrong.
I am certain that some response teams don’t comply 100 percent with the various regulations and standards that provide guidance and direction to responders. And, as with many circumstances similar to this, it only becomes an issue when something goes wrong. To put it another way: Many drivers do not comply with various posted speed limits or other roadway regulations. They don’t get into trouble unless they are caught by law enforcement or, worse yet, they cause a crash. They only suffer consequences after a mishap. Similar thought processes can contribute to neglect on the part of response teams to these special incidents. Only if there are unexpected outcomes will there be challenges. If there are, there will be a review of applicable regulations and standards. Some have the force of law, and others are expected to be followed.
Responses to hazmat incidents may have been the first official add-on to fire departments’ responsibilities other than emergency medical services (EMS). And, like EMS, hazmat has established protocols with a requirement to comply with accepted standards. Departments cannot purchase a supply of “kitty litter” and buy a few encapsulating suits to begin responding to calls. They must have the equipment commensurate with the types of hazards they can reasonably expect along with the appropriate training. This will vary according to expectations for what will be done regarding identifying and mitigating hazards. There is a qualification classification system-awareness, operations, technician, specialist-that identifies the involvement an individual may have during a hazmat incident.
National Fire Protection Association (NFPA) 472, Standard for Competence of Responders to Hazardous Materials/Weapons of Mass Destruction Incidents (2013 ed.), establishes criteria for response to hazmat incidents. Those involved with response teams must be intimately familiar with this document. Chief officers, even if they are not direct responders, must also know the standard and take steps for compliance. Even though some may argue this is an advisory standard, ignoring its contents would be foolish. Should something run afoul, there will be consequences. There will be legal liabilities relative to the standard, and Occupational Safety and Health Administration (OSHA) states will consider this as an acceptable standard that must be followed. Fortunately, almost anyone with official responsibilities in the hazmat arena will know this. It is those who are not prepared who should reconsider.
Speaking of OSHA, there are regulations identified in the Code of Federal Regulations (CFR) that responders must know and follow. This is not to imply that they need to be memorized, but a working knowledge is essential, and the contents of the regulations must be part of regular training. Each of the CFRs is not necessarily applicable on every hazmat call. Regardless, you won’t know which ones apply until the event happens. Here are some for you to consider refreshing your knowledge on:
- 29 CFR 1910.120 (q)(3)(G) mandates that an incident safety officer be assigned and used at hazmat incidents.
- 29 CFR 1910.134 Respiratory Protection: This also has application for firefighting, so it should be familiar to most.
- 29 CFR 1910.120 Hazardous Waste Operations and Emergency Response (HAZWOPER).
- 29 CFR 1910.95 Occupational Noise Exposure Limits.
- 29 CFR 1910.1030 Blood-Borne Pathogens: Agencies involved with EMS should be very familiar with this.
- CFR 1910.1200 Hazard Communication.
- 2929 CFR 1910.146 Permit-Required Confined Spaces.
TechnICal Rescue Response
The last bullet above is usually affiliated with a specific confined space event. In addition, there are numerous other technical rescue situations. This could include rope rescues, various water rescues from rapids to dive to ice, urban search and rescue (collapse), industrial and farm machinery, and trench collapse. Obviously, organizations only need to prepare for the types of incidents they are most likely to encounter. I don’t think Phoenix, Arizona, has to spend too much time preparing for an ice water rescue! Part of the readiness is knowing rules, regulations, and standards. NFPA 1670, Standard on Operations and Training for Technical Search and Rescue Incidents, and NFPA 1006, Standard for Technical Rescuer Professional Qualifications, should be of interest. In addition to the CFRs mentioned above regarding hazmat response, the following should be part of a regular review process of team members and department leadership:
- 29 CFR 1910.147 The Control of Hazardous Energy (lockout/tag out).
- 29 CFR 1910.126 Excavations, Trenching Operations.
From just a regulation and standard perspective, hazmat and technical rescue responses can be very complicated, and there is a need for a good foundation built on requisite knowledge based on legal and liability perspectives. Added to the challenges are the need for proper equipment, maintenance of that equipment, training on that equipment, and a solid foundation of the principles needed to be successful. There is a need for practice (sets and reps) to be proficient and continual study, as there are new challenges every day.
Response to hazmat and technical rescue incidents seems almost a contrast to how firefighters and fire departments have traditionally approached structural fires. Though there is some change, many fire departments don’t consider regulations and standards as their first approach to attacking a fire. NFPA standards are sometimes considered guidelines. Regulations only come into play if there is a serious injury or fatality. Yet, special teams on fire departments established to address incidents that could be considered extraordinary would not remotely consider ignoring established standards or the regulations. Of course, this adds to the responsibilities and the need to continually remain current within the profession. Organizations that are expected to respond with special teams need to know all aspects of the job at hand and will not have any excuses if they don’t follow the rules!
RICHARD MARINUCCI is the executive director of the Fire Department Safety Officers Association (FDSOA). He retired as chief of the Farmington Hills (MI) Fire Department in 2008, a position he had held since 1984. He is a Fire Apparatus & Emergency Equipment and Fire Engineering editorial advisory board member, a past president of the International Association of Fire Chiefs (IAFC), and past chairman of the Commission on Chief Fire Officer Designation. In 1999, he served as acting chief operating officer of the U.S. Fire Administration for seven months. He has a master’s degree and three bachelor’s degrees in fire science and administration and has taught extensively.