OSHA’s proposed Incident Management System (IMS) requirements

Workplace Emergency Response Employers (WEREs) and Emergency Services Organizations (ESOs) respond to a wide variety of incidents, most of which are considered routine and involve a small commitment of resources. Some incidents are more complex and involve larger commitments of resources and potentially higher-risk operations. The WERE and ESO need to develop an incident management system (IMS) that accommodates all types and sizes of incidents and provides for a systematic process of escalation from the arrival of the first units at a routine incident, to an appropriate response to larger and more complex incidents.

The proposed rule defines an IMS as

“a system used for managing and directing incident scene operations and activities. It includes establishing functions for managing incidents, describes the roles and responsibilities to be assumed by team members and responders, and standard operating procedures to be utilized.”

Because OSHA is aware that some WERTs and ESOs use the terms IMS and Incident Command System (ICS) synonymously, the definition also indicates that incident command is a functional component of the IMS.

An IMS provides for the safety and health of team members and responders by establishing structure and coordination for the management of emergency incident operations. Lack of, or deficiencies in, an IMS are routinely cited by NIOSH in their investigation reports for team member and responder injuries and fatalities.  Examples of deficiencies noted include multiple team members and responders serving in command roles in an uncoordinated manner, lack of an established accountability system for tracking team members and responders, not establishing a rapid intervention crew (RIC), and not designating an Incident Safety Officer (ISO) or otherwise ensuring for the safety and health of team members and responders.

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