NFPA 1500 Compliance Audit William Ruting, STA Emergency Planning Specialist Argonne National Laboratory.

NFPA 1500 Compliance Audit

William Ruting, STA

Emergency Planning Specialist

Argonne National Laboratory

Overview

• Rationale

• NFPA 1500

• Audit Process

• NFPA 1500 Deconstruction

• Assessment

• Findings

• Final Report

Rationale

• 10 CFR Part 851, Worker Safety and Health Programs

• DOE Part 851 Rules require:• Compliance with NFPA 1500• FD’s to determine compliance• Submit plan on achieving compliance

• DOE Orders 420.1 & 440.1

10 CFR 481 Requirements

“This [compliance] includes meeting the applicable building code and

National Fire Protection Association (NFPA) Codes and Standards or

exceeding them, when necessary, to meet safety objectives, unless explicit

written relief has been granted by DOE.”

Some “Wiggle Room” in 481!

“…DOE agrees that any requirement that is not directly related to the

safety and health of workers is not applicable in the context of this

rule.”

Equivalencies

“DOE agrees in part and concludes that, beyond the definition of a formal

exemption process to this rule, no explicit reference to ‘equivalencies’ is necessary, as this concept is an integral part of all NFPA codes and standards and DOE fire safety

directives.”

Which NFPA Codes?CODE TITLE

NFPA 1 Uniform Fire Code™ 2003 Edition

NFPA 10 Standard for Portable Fire Extinguishers, 1998 Edition

NFPA 13E Recommended Practice for Fire Department Operations in Properties Protected by Sprinkler and Standpipe Systems 2005 Edition

NFPA 25 Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems 2002 Edition

NFPA 101 Life Safety Code® 2003 Edition

NFPA 291 Recommended Practice for Fire Flow Testing and Marking of Hydrants 2002 Edition

NFPA 402 Guide for Aircraft Rescue and Fire-Fighting Operations 2002 Edition

NFPA 450 Guide for Emergency Medical Services and Systems 2004 Edition

NFPA 471 Recommended Practice for Responding to Hazardous Materials Incidents 2002 Edition

NFPA 472 Standard for Professional Competence of Responders to Hazardous Materials Incidents 2002 Edition

NFPA 473 Standard for Competencies for EMS Personnel Responding to Hazardous Materials Incidents 2002 Edition

NFPA 601 Standard for Security Services in Fire Loss Prevention 2005 Edition

NFPA 801 Standard for Fire Protection for Facilities Handling Radioactive Materials 2003 Edition

NFPA 901 Standard Classifications for Incident Reporting and Fire Protection Data 2001 Edition

NFPA 921 Guide for Fire and Explosion Investigations 2004 Edition

NFPA 1000 Standard for Fire Service Professional Qualifications Accreditation and Certification Systems 2000 Edition

NFPA 1001 Standard for Fire Fighter Professional Qualifications 2002 Edition

NFPA 1002 Standard on Fire Apparatus Driver/Operator Professional Qualifications 2003 Edition

NFPA 1003 Standard for Airport Fire Fighter Professional Qualifications 2005 Edition

NFPA 1006 Standard for Rescue Technician Professional Qualifications 2003 Edition

NFPA 1021 Standard for Fire Officer Professional Qualifications 2003 Edition

NFPA 1031 Standard for Professional Qualifications for Fire Inspector and Plan Examiner 2003 Edition

NFPA 1033 Standard for Professional Qualifications for Fire Investigator 2003 Edition

NFPA 1035 Standard for Professional Qualifications for Public Fire and Life Safety Educator 2005 Edition

NFPA 1041 Standard for Fire Service Instructor Professional Qualifications 2002 Edition

NFPA 1051 Standard for Wildland Fire Fighter Professional Qualifications 2002 Edition

NFPA 1061 Standard for Professional Qualifications for Public Safety Telecommunicator 2002 Edition

NFPA 1071 Standard for Emergency Vehicle Technician Professional Qualifications 2000 Edition

NFPA 1145 Guide for the Use of Class A Foams in Manual Structural Fire Fighting 2000 Edition

NFPA 1201 Standard for Providing Emergency Services to the Public 2004 Edition

NFPA 1221 Standard for the Installation, Maintenance, and Use of Emergency Services Communications Systems, 1999 Edition

NFPA 1250 Recommended Practice in Emergency Service Organization Risk Management 2004 Edition

NFPA 1401 Recommended Practice for Fire Service Training Reports and Records 2001 Edition

NFPA 1402 Guide to Building Fire Service Training Centers 2002 Edition

NFPA 1403 Standard on Live Fire Training Evolutions 2002 Edition

NFPA 1404 Standard for Fire Service Respiratory Protection Training 2002 Edition

NFPA 1405 Guide for Land-Based Fire Fighters Who Respond to Marine Vessel Fires 2001 Edition

NFPA 1410 Standard on Training for Initial Emergency Scene Operations 2005 Edition

NFPA 1451 Standard for a Fire Service Vehicle Operations Training Program 2002 Edition

NFPA 1452 Guide for Training Fire Service Personnel to Conduct Dwelling Fire Safety Surveys 2005 Edition

NFPA 1500 Standard on Fire Department Occupational Safety and Health Program 2002 Edition

NFPA 1521 Standard for Fire Department Safety Officer 2002 Edition

NFPA 1561 Standard on Emergency Services Incident Management System 2005 Edition

NFPA 1581 Standard on Fire Department Infection Control Program 2005 Edition

NFPA 1582 Standard on Comprehensive Occupational Medical Program for Fire Departments 2003 Edition

NFPA 1583 Standard on Health-Related Fitness Programs for Fire Fighters 2000 Edition

NFPA 1584 Recommended Practice on the Rehabilitation of Members Operating at Incident Scene Operations and Training Exercises 2003 Edition

NFPA 1600 Standard on Disaster/Emergency Management and Business Continuity Programs 2004 Edition

NFPA 1620 Recommended Practice for Pre-Incident Planning 2003 Edition

NFPA 1670 Standard on Operations and Training for Technical Search and Rescue Incidents 2004 Edition

NFPA 1710 Standard for the Organization and Deployment of Fire Suppression Operations, Emergency Medical Operations, and Special Operations to the Public by Career Fire Departments 2004 Edition

NFPA 1851 Standard on Selection, Care, and Maintenance of Structural Fire Fighting Protective Ensembles 2001 Edition

NFPA 1852 Standard on Selection, Care, and Maintenance of Open-Circuit Self-Contained Breathing Apparatus (SCBA) 2002 Edition

NFPA 1901 Standard for Automotive Fire Apparatus 2003 Edition

NFPA 1906 Standard for Wildland Fire Apparatus 2001 Edition

NFPA 1911 Standard for Service Tests of Fire Pump Systems on Fire Apparatus 2002 Edition

NFPA 1912 Standard for Fire Apparatus Refurbishing 2001 Edition

NFPA 1914 Standard for Testing Fire Department Aerial Devices 2002 Edition

NFPA 1915 Standard for Fire Apparatus Preventive Maintenance Program 2000 Edition

NFPA 1931 Standard for Manufacturer's Design of Fire Department Ground Ladders 2004 Edition

NFPA 1932 Standard on Use, Maintenance, and Service Testing of In-Service Fire Department Ground Ladders 2004 Edition

NFPA 1936 Standard on Powered Rescue Tools 2005 Edition

NFPA 1951 Standard on Protective Ensemble for USAR Operations 2001 Edition

NFPA 1961 Standard on Fire Hose 2002 Edition

NFPA 1962 Standard for the Inspection, Care, and Use of Fire Hose, Couplings, and Nozzles and the Service Testing of Fire Hose 2003 Edition

NFPA 1963 Standard for Fire Hose Connections 2003 Edition

NFPA 1964 Standard for Spray Nozzles 2003 Edition

NFPA 1965 Standard for Fire Hose Appliances 2003 Edition

NFPA 1971 Standard on Protective Ensemble for Structural Fire Fighting 2000 Edition

NFPA 1975 Standard on Station/Work Uniforms for Fire and Emergency Services 2004 Edition

NFPA 1976 Standard on Protective Ensemble for Proximity Fire Fighting 2000 Edition

NFPA 1977 Standard on Protective Clothing and Equipment for Wildland Fire Fighting 2005 Edition

NFPA 1981 Standard on Open-Circuit Self-Contained Breathing Apparatus for Fire and Emergency Services 2002 Edition

NFPA 1982 Standard on Personal Alert Safety Systems (PASS) 1998 Edition

NFPA 1983 Standard on Fire Service Life Safety Rope and System Components 2001 Edition

NFPA 1989 Standard on Breathing Air Quality for Fire and Emergency Services Respiratory Protection 2003 Edition

NFPA 1991 Standard on Vapor-Protective Ensembles for Hazardous Materials Emergencies 2005 Edition

NFPA 1992 Standard on Liquid Splash-Protective Ensembles and Clothing for Hazardous Materials Emergencies 2005 Edition

NFPA 1994 Standard on Protective Ensembles for Chemical/Biological Terrorism Incidents 2001 Edition

NFPA 1999 Standard on Protective Clothing for Emergency Medical Operations 2003 Edition

That’s 80 Codes & Standards, not including cross references.

Other 10 CFR 481 Requirements

• Industrial Hygiene

• Biological Safety

• Occupational Medicine

• Motor Vehicle safety

• Electrical Safety

• Workplace Violence Prevention

A. Subpart A—General ProvisionsSection 851.1—Scope and Purpose

…to minimize the burden on contractors by clarifying that they

need not establish redundant worker protection programs to protect

workers from occupational safety and health hazards.

Appendix A—Worker Safety andHealth Functional Areas

2. Fire Protection

“DOE agrees that a more pragmatic and less prescriptive approach to the delineation of

requirements for fire protection and emergency services is appropriate. Consequently, the final

rule has been revised to include the text from the fire protection portion of DOE Order 440.1A,

which has been in effect since1998.”

Primary NFPA Standard

NFPA 1500: Standard on Fire Department Occupational Safety and

Health Program

NFPA 1500

• First publication 1987

• Current version 2007

• Designed for public fire departments

• National Standard• No regulatory force• Used as legal exhibit

Changes in 2007 Version

• Added protective ensembles for technical rescue and chemical/biological terrorism

• An updated section on risk management • Revised and reorganized chapter on training and

education• Enhanced chapter on operating fire apparatus • First-time sections on operations at traffic

incidents, establishing control zones, and fitness for duty evaluations

• Added section on appointment of a health and safety officer

1500 OverviewChapter Description

1. Equivalency Actions and programs the department can use that are equivalent to the specific requirements in some chapters.

4. Fire Department Administration How the department is organized with the focus on safety and health activities.

5. Training and Education Standards for training of personnel in all areas of activity; training related to issues of safety and health; how safety and health are incorporated into training.

6. Fire Apparatus, Equipment, and Driver/Operators

Design and maintenance criteria for apparatus; design and maintenance of equipment; training and certification of drivers.

7. Protective Clothing and Protective Equipment

Standards for the manufacture, care, wearing and use of PPE.

8. Incident Management Use of Incident Command; safety; accountability; fire ground command and communications.

9. Facility Safety Design, maintenance, and use of fire department facilities.

10. Medical Requirements Physical fitness, medical fitness, agility and other medical aspects of new and existing fire personnel.

11. Member Assistance and Wellness Programs

Availability of assistance programs such as EAP’s; department support for programs.

12. Critical Incident Stress Program Availability and use of CISD programs

Public Fire v. DOE Fire

• DOE primary coverage non-residential

• Predominance of fixed suppression systems

• Smaller total protected area

• Private roads = quicker responses

• Fire experience lower• Personal concern over fire losses

DOE Considerations

• Unique facilities

• Extremely high value• Irreplaceable

• Unique hazardous materials• Radiologcial• Non-Radiological

• Security concerns

The “1500” Pound Taco• Whole is greater than sum of parts

• More convoluted than the Mississippi River

• Is a “moving target”

• Was developed by a committee• “The camel is a horse designed by a

committee”

…and doesn’t even include

External references such as

ASTM, ANSI, etc.

This is ONLY 1500

ANL 1500 Compliance Audit

Completed in 2006

Methodology

• “Deconstruction” of 1500• 2002 Version• 406 individual criteria

• Each criterion individually evaluated• Interview with Chief & Staff• Review of Department Materials

• Policies, procedures, SOP’s, Etc.• Site-wide materials

• Personnel policies, safety rules

Methodology, Continued

• Compliance level determined• Full• Comply With Intent

• “Equivalencies”

• Partial• Non-Compliant• Not Applicable

• Detailed description of compliance status

Methodology, Continued

• Developed plan to improve or achieve compliance

• Date by which compliance could be achieved

• Projected costs for compliance• Initial• On-Going

• Exhibits• Title of document• Other supporting material

Chapter:

Section:

Sub Section:

Description:      

Status:

Plan:      

Compliance Date:      

Estimated Cost: $0.00

Exhibits: 1

2

3

4      

5      

Sample Form

Chapter: Chapter 5 Training and Education

Section: 5.1 General Requirements.

Sub Section 5.1.2 The fire department shall provide training and education for all department members commensurate with the duties and functions that they are expected to perform.

Description:      

Status: Full Partial None CWI Not Applicable

All personnel are required to have and maintain certified firefighter status and certified paramedic status at the time of hire. In addition, personnel must complete additional training in regard to specific duties performed by the ANL FD. The basic training requirements are included on a new employee checklist; all requirements must be attained during the first year of employment.All employees are also trained to the hazmat operations level, with the majority of members trained to technician or higher.

Plan:      

Compliance Date:      

Estimated Cost: $0.00

Exhibits: 1 ISFM certifications Firefighter II/Fire Officer

2 ISFM certification for Hazardous Materials

3 Loyola University Medical Center/IDPH Paramedic

4      

5      

Chapter: Chapter 5 Training and Education

Section: 5.1 General Requirements.

Sub Section 5.1.2 The fire department shall provide training and education for all department members commensurate with the duties and functions that they are expected to perform.

Description:      

Status: Full Partial None CWI Not Applicable

All personnel are required to have and maintain certified firefighter status and certified paramedic status at the time of hire. In addition, personnel must complete additional training in regard to specific duties performed by the ANL FD. The basic training requirements are included on a new employee checklist; all requirements must be attained during the first year of employment.All employees are also trained to the hazmat operations level, with the majority of members trained to technician or higher.

Chapter: Chapter 5 Training and Education

Section: 5.1 General Requirements.

Sub Section 5.1.2 The fire department shall provide training and education for all department members commensurate with the duties and functions that they are expected to perform.

Description:      

Chapter: Chapter 7 Protective Clothing and Protective Equipment

Section: 7.1 General

Sub Section 7.1.5* Where station/work uniforms are worn by members, such station/work uniforms shall meet the requirements of NFPA 1975, Standard on Station/Work Uniforms for Fire and Emergency Services.

Description:      

Status: Full Partial None CWI Not Applicable

ANL FD has evaluated the uniforms that are compliant and has determined them to have negative cost/benefits. Nomex clothing is uncomfortably hot and causes accelerated fatigue and potential hyperpyrexia in personnel. FRP cotton has life span of eight washings (equals eight wearings) making it cost prohibitive.

All personnel must wear full turn-out protection, including coat and pants over 100% cotton clothing.

Plan:    Purchase compliant uniforms; initial issue of 3 l/s shirts, 3 s/s shirts, 3 pants per person. Projected 5 year costs include annual replacement of clothing (2 of each per person).  

Compliance Date:      

Estimated Cost: $71,850

Exhibits: 1 Price per Transcom Clothing

2 Supplemental cost analysis

3

4      

5      

Assessing Results

• Numerical data• Percent in each category• Cost to achieve full compliance

• Non-Numerical• Compliance issues• Obstacles to compliance• Other issues

Final Report: Contents

• Executive Summary

• Introduction

• Results by Section

• Discussion of Results

• Cost of Compliance

• Conclusions & Recommendations

Results

• 73.9% = Full

• 8.9% = Comply With Intent

• 4.2% = Partial

• 3.4% = Non-Compliant

• 9.6 = Not Applicable

Chapter   # Criteria Full CWI Part Non DNA

Chapter 1 Equivalency 2 2 0 0 0 0

Chapter 4 Fire Department Administration 89 55 31 3 0 0

Chapter 5 Training and Education 37 32 1 0 0 4

Chapter 6Fire Apparatus, Equipment, and Driver/Operators 50 32 1 5 0 12

Chapter 7Protective Clothing and Protective Equipment 91 72 1 1 2 15

Chapter 8 Incident Management 89 76 2 3 1 7

Chapter 9 Facility Safety 11 10 0 1 0 0

Chapter 10 Medical Requirements 26 14 0 3 8 1

Chapter 11Member Assistance and Wellness Programs 7 5 0 1 1 0

Chapter 12 Critical Incident Stress Program 4 2 0 0 2 0

  TOTALS 406 300 36 17 14 39

  Based on total criteria (%):   73.9 8.9 4.2 3.4 9.6

Based On Applicable Criteria (%): 367 81.7 9.8 4.6 3.8

Results By Chapter

Compliance With ApplicableChart 2: Compliance Based On Applicable Criteria

81%

10%5% 4%

Full

CWI

Part

None

Major Compliance Costs

• Annual testing of ground ladders

• Fire resistant uniforms

• Changes to communications center

• Traffic cones

• Fitness trainer certification

• Fitness program

Total Projected Cost Year 1= $326,213

Recommendations

1. Develop a structured fitness program

2. Annual testing of ground ladders

3. FD respiratory protection program

4. Develop additional written policies

5. In-depth review of “partial” items