In this economy, we should take 10 minutes and call our local Fire Department (FD) and discuss any changes that have been made that could impact our business. FACT: All fire departments have been forced to make cuts in recent years; some more than others, but all have had to cut their budgets. The first cuts come to specialized programs, such as HAZMAT teams, Special Rescue teams, etc. The vast majority of U.S. businesses rely solely on their local FD to provide 100% of their emergency response needs (i.e. fire, rescue, HAZMAT, EMS) and even some very “minor” changes in their local FD can have MAJOR implications on their business.
This quote from a recent article from the International Association of Fire Chiefs (IAFC) says it all… “A simple example is that if you had 30 firefighters on your first alarm in the past, all arriving within seven minutes, but due to city hall cuts, you now have 15 firefighters in 10 minutes, it’s impossible for you and your members to provide service as expected previously. Simple math. No emotion. Just the way it is.”
If a facility relies on their local FD, even in a back-up capacity to their own interal response teams, there are some regulatory requirements that MANDATE some “pre-planning” be done. Examples:
- 1910.120(q) requires an Emergency Response Plan and the VERY FIRST topic in this plan is to be “Pre-emergency planning and coordination with outside parties”. The term “outside parties” as used in 1910.120(q)(2)(i) means outside responders (fire departments, police, private HAZMAT teams, emergency medical service personnel, and other pertinent components of the local, state, and federal emergency response system) and other employers in the surrounding area who could be affected by a hazardous substance emergency incident. Compliance Safety and Health Officers (CSHO) may ask the following questions with respect to an employer’s pre-emergency planning and coordination efforts:
- (a) Does the plan address coordination with outside emergency response organizations?
- (b) Have employers notified and coordinated their ERP with the organizations listed? CSHOs will verify with the local fire department(s) that the employer has contacted them regarding the employer’s emergency response capabilities and needs and the fire department’s role, if any, in providing emergency response (e.g., CSHO’s may request written mutual aid agreements with the response organizations). The planning and coordination procedures in the employer’s written ERP should state the particular conditions or circumstances under which outside responders will provide emergency response to the site or facility. The CSHO should also verify with other randomly-selected emergency response organizations listed in the ERP that these outside parties are aware of and capable of fulfilling their role under the employer’s ERP.
- (c) Are telephone numbers and contact personnel for in-plant officials and local authorities updated and made available?
- (d) Do the employer’s pre-emergency planning and coordination procedures address how outside parties are notified of a potential emergency situation and what role each would play in an incident? The CSHO’s may verify whether the employer has conveyed these elements of the ERP by contacting several of the affected outside parties.
- (e) Are outside responders aware of any circumstances that were either not disclosed or considered by the employer that would delay or prevent them from responding to an incident (e.g., distance, lack of training, etc.)?
(Source: 1910.120 CPL)
- 1910.146(k) requires the business to “Evaluate a prospective rescue service’s ability, in terms of proficiency with rescue-related tasks and equipment, to function appropriately while rescuing entrants from the particular permit space or types of permit spaces identified”.
Non-host employer rescue employees (off-site):
- 1. Who provides the off-site rescue service and where is the service located?
- 2. How is the arrangement between the employer and the off-site rescue service documented (contract, letter of agreement, verbal agreement)?
- 3. How does the employer decide, given the identified permit-space hazards, that the off-site rescue service’s response time, experience, and training are adequate?
- 4. Have the rescue service training requirements in paragraph (k)(1) been met?
- 5. What method is used to summon rescuers?
- 6. Are rescue services on-call or on-site when permit space entry is underway?
- 7. What is the response time for rescue service?
- 8. How does the employer verify that the rescue service will be available during the time of employee entry?
Combinations:
- 1. If combination of on-site and off-site rescue services is employed:
- a. Obtain a copy of the rescue plan which describes the roles of each party, and
- b. Verify that the on-site and off-site rescue services employees have trained together as a team.
- c. Determine if, the combined rescue services enable the employer to comply with the requirements for rescue services.
(Source: 1910.146 CPL)
There are NO time limits setting how often these pre-plan reviews should be done; of course, annually would be optimal, but because of limited resources, many businesses are hard pressed to maintain an annual frequency. But due to the recent economic downturn, it is ABSOLUTELY CRITICAL that we take 10 minutes and check-in with our local FD regarding our emergency response expectations from them. In the past 2-3 years we have found SIGNIFICANT gaps during some audits and risk assessment in what the business needs and expects from the FD and what the FD can currently provide. Most of these businesses had met with their local FD years ago and determined their capabilities; however, things changed in the FD and the FD is NOT required to notify you that they disbanded their HAZMAT team and instead uses the regional HAZMAT team (causing MUCH longer response times) or went from Tech level reponders to Op’s level responsders, or they no longer provide specialized rescue services or they went from entry style CS rescue team to a support role in CS Rescue. We have even come across a business that years earlier determined they did not need a First Aid team since the local fire station was literally around the corner and well within the 3-4 minute response time (OSHA LOI discussing time limits for required medical aid). However, this business is located in a smaller community in the USA and the community actually reorganized their entire FD in a cost cutting measure and this reorganization included a physical reorganization of fire station locations. Yep, the fire station around the corner is now a city day care and community training center for the unemployed. This means the business no longer has a 3-4 minute response time (it actually jumped to 8-10) and now needs to put in place their own first aid team. (IMPORTANT NOTE: the business is also expecting an increase in their property and business continuation insurance premiums due to this response time change – just like your homeowners insurance, location to a fire station and water source are major determinants in premiums!). The beauty of a small community…I went to the Fire Chief and asked if the FD could provide the needed First Aid/CPR training for FREE to this business since the business was struggling to survive in these economic times. The chief went to the town council with the request and they voted unanimously to allow the FD to provide this First Aid/CPR training for FREE to any business impacted by the reorganization of the fire stations (something the city council had no idea would impact their community businesses). Of course they thought I was a consultant trying to drum up “fear business” and had to call the local OSHA office to find out if I was telling the truth about response times and first aid teams! Sad that our profession has this kind of reputation among communities and businesses! None the less, I welcomed this move by the council as it opened the door to discussions with the local OSHA office, in which OSHA was very pleased that the businesses and the local emergency responders were working to together to rectify the problem. Of course, not all businesses were happy as some liked having their head buired in the sand when it came to ER capabilities!
So those articles we read in our local papers about changes to our police, fire, and EMS can have serious repercussions on our businesses, even to the point that it impacts our compliance with regulatory authorities. I written before about the pro’s and con’s of using the local FD for CS rescue and how it could have a serious limitations on our timing to complete entries, but having the FD disband their rescue team or limit the number of rescuers or change to Operations Level rescue could have dire consequences on our business and more so on our EMPLOYEES! A 10-minute phone call could identify any issues and at least put the wheels in motion to rectify the situation.
NOTE: SAFTENG.net LLC could have easily done First Aid training for dozens of businesses in the small community mentioned above, as we were offered this under a blanket PO from the city since the FD was not able to handle the number of training request. We walked away from it and instead helped the city work with the local OSHA office to allow ample time to get all the training conducted for the impacted businesses. We stand 100% behind our moto… We put making a DIFFERENCE BEFORE making a profit! A business that can get quality training for FREE from a local service is something we will NOT stand in the way of.