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OSHA's Interpretation for Fire Emergency Planning

Posted on Thu, Apr 28, 2011

According to the Occupational Safety and Health Administration (OSHA), regulations mandate the minimum number of workers required for operations in environments that are immediately dangerous to life and health (IDLH). These minimum personnel requirements numbers should be reflected in fire emergency planning and training.

Numerous standards apply, and should be reviewed for employees who work in IDLH conditions. OSHA refers to the following standards:

1. Hazardous Waste Operations and Emergency Response (HAZWOPER), 29 CFR 1910.120

HAZWOPER requires that operations in hazardous areas shall be performed using the buddy system in groups of two or more. (1910.120(q)(3)(v)).  In addition, paragraph 1910.120(q)(3)(vi) states that "back up personnel (at least two or more) shall stand by with equipment ready to provide assistance or rescue." Thus, there must be at least four individuals at the site. One of the two individuals outside the hazard area can be assigned to another task, provided that the second assignment does not interfere with the performance of the standby role.

HAZWOPER standard defines the buddy system and IDLH as follows:

Buddy system means a system of organizing employees into work groups in such a manner that each employee of the work group is designated to be observed by at least one other employee in the work group. The purpose of the buddy system is to provide rapid assistance to employees in the event of an emergency.

IDLH or Immediately dangerous to life or health means an atmospheric concentration of any toxic, corrosive or asphyxiant substance that poses an immediate threat to life or would cause irreversible or delayed adverse health effects or would interfere with an individual's ability to escape from a dangerous atmosphere.

2. Fire Brigades, 29 CFR 1910.156 and Respiratory Protection, 29 CFR 1910.134

The Fire Brigade regulation covers emergency operations involving interior structural fire fighting. According to OSHA, it is universally recognized that conditions present during an advanced interior structural fire create an IDLH. Because fire brigades vary in type, function and size, the OSHA requirements are performance oriented to provide enough flexibility for the employer to organize a fire brigade which best reflects the needs of the workplace. The Fire Brigade regulation does not directly address the minimum number of fire fighters required when engaged in operations presenting an IDLH atmosphere. However, the Respiratory Protection standard states that failure to have four employees at an interior structural fire, would be a violation of 1910.134(g)(4).

3. NFPA Standards: 1500-1992, Fire Department Occupational Safety and Health Program and 600-1992, Standard on Industrial Fire Brigades

Amendment 6-4.1.1 of the NFPA 1500-1992 states: "At least four members shall be assembled before initiating interior fire fighting operations at a working structural fire."

A working structural fire is defined as follows: Any fire that requires the use of a 1 and 1/2 inch or larger fire attack hose line and that also requires tee use of self-contained breathing apparatus for members entering the hazardous area."

OSHA states that the terms interior structural fire fighting and working structural fire are similar in nature. Consequently, four persons (two inside and two outside), each with protective clothing and respiratory protection are essential for the safety of those performing this work inside a structure.

Chapter 5-3.5 of the NFPA 600-1992, specifies requirements for the number of members to be involved at the scene. Requirements in chapter 5-3.5 are similar to those in NFPA 1500-1992, Sections 6-4.3 and 6-4.4, and states a minimum of four members on the scene before beginning to fight interior structural fires: two inside as a team, operating in the hazardous area; two outside the hazardous area, where one is standing by and another may be performing another function, such as managing the incident, as long as its performance does not interfere with the second outside person's ability to assist in the event of an emergency.

NOTE: This standard does not address the number of persons necessary to staff a fire apparatus leaving a station before on-scene evaluation has occurred. That is a matter to be determined by each local fire fighting unit.

4. Section 5(a)(1) of the Occupational Safety and Health Act of 1970 which is intended to apply to operations where IDLH conditions exist or potentially exist in the following situations:

a.     Emergency response to uncontrolled releases of a hazardous substance or substances;
b.     Emergency operations covering interior structural fire fighting.

Any citation or Section 5(a)(1) must meet the requirements outlined in the Field Inspection Reference Manual (FIRM), Chapter III, and may be issued where there is a hazard which cannot be abated by compliance with a specific OSHA standard.

The NFPA national consensus standards serves as guidance as to what is generally recognized as hazardous in the industry.  Therefore, a citation for violation of the General Duty Clause shall be issued when it is documented that only one person conducted interior structural fire fighting operations or when less than two persons were standing by when interior structural fire fighting operations were being conducted. A Section 5(a)(1) citation may not be issued for incipient stage interior fires or for exterior fire fighting operations conducted during advanced interior structural fires.

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Tags: Fire Department Training, OSHA, Emergency Preparedness, Crisis Management

Shipboard Fire Control Pre Planning

Posted on Tue, Mar 15, 2011

Shipboard fires are among the most difficult to control. Realistic and effective pre-fire planning is crucial to successfully respond to such emergencies. The chances of mounting an effective response are greatly reduced without fire control planning and exercises.

Shipboard pre-fire plans should address the following factors:

  • Description of ship areas and associated environments
  • Personnel safety and environmental protection
  • Scope of authority of responders
  • Preferred locations for operations
  • Major hazards to the port and its inhabitants
  • On-board hazards
  • Description of the ship’s systems and facilities
  • Site-specific strategies and tactics

The plan should be divided into several major sections, with a logical progression according to the sequence of response actions. Diagrams, flowcharts, are photographs can be useful to emphasize or clarify important points.  All responders need to understand their roles and responsibilities and the scope of their authority.

Some vessels, often tank vessels, will provide a copy of the fire plan and international shore connection at the top of the gangway when in port. This is not required, however it is common practice. According to the International Maritime Organization (IMO), the fire plan enclosure should be red and the contents of the enclosure should be indicated by a red ship silhouette on a white background. The dimensions of the location sign should be not less than 11.7 in. × 15.7 in. (297 mm × 400 mm).

Fire control plans are required by both SOLAS (Safety of Life at Sea), Chapter II-2, Regulation 20, and 46 CFR 78.45-1(a)(1). Therefore, all new and existing U.S. flag and foreign flag ships entering U.S. ports should carry a fire control plan.

SOLAS describes two different regulations:

  • "International Convention for Safety of Life at Sea" which applies only to ships engaged on international voyages
  • Public Law 89-777 from 1966, popular name: "Safety at Sea Act" or "Safety of Life at Sea Act".

The pre-fire plan, or fire control plan, should be periodically reviewed and tested by each potential response unit. In addition, a copy should be provided to the Masters of Ships that regularly visit the port. The plan is also a useful as a training tool. Through training and drills, responders can become more familiar with the ship’s vital systems even though they might not have the opportunity to frequently board the vessel.

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Tags: Fire Department Training, Fire Pre Plans, Emergency Preparedness

OSHA's HAZWOPER Operational Training for Fire Department

Posted on Wed, Jun 16, 2010


HAZWOPER operational training sessions and response exercises provide fire department personnel with useful, practical information designed to improve response capabilities when dealing with hazardous materials.

According to OSHA, first responders at the operations level are individuals who respond to releases, or potential releases, of hazardous substances as part of the initial response to the site. The purpose of the first responder at the operational level is to protect life, property, or the environment from the effects of the release.

Operation mode firefighters are trained to respond in a defensive fashion without actually trying to stop the release. Their function is to contain the release from a safe distance, keep it from spreading, and prevent exposures.

First responders at the operational level shall have received at least eight hours of training, or have had sufficient experience to objectively demonstrate competency in the following areas:
  • Knowledge of the basic hazard and risk assessment techniques.
  • Know how to select and use proper personal protective equipment provided to the first responder operational level.
  • An understanding of basic hazardous materials terms.
  • Know how to perform basic control, containment and/or confinement operations within the capabilities of the resources and personal protective equipment available with their unit.
  • Know how to implement basic decontamination procedures
  • An understanding of the relevant standard operating procedures and termination procedures.


For more tips and best practices on HAZWOPER Training, download our HAZWOPER training guide



Tags: Fire Department Training, OSHA HAZWOPER