Last week we looked at how OSHA investigates your department, and today we will look at why. First and foremost, we need to understand that just being a volunteer department does not make us exempt from OSHA regulations. As a matter of fact, OSHA does not make a differentiation between paid and volunteer, as we are doing the same tasks.
Some may consider this ‘unfair’, but I believe that if we want to be considered ‘professionals’, then we should be held to the same standard. That being said, I am sure many people will disagree. The reason why I say we should be held to the same standard is that the bar is set low…
The first confusion is between OSHA and NFPA. Understand that NFPA sets guidelines and ‘standards’, while OSHA sets regulations. NFPA (http://www.nfpa.org) sets standards in multiple areas, but does not have a regulatory component. OSHA sets minimum requirements, and has the regulatory component to enforce them.
OSHA’s minimums are reasonable, and are there for the safety of everyone involved. While it may be difficult for some departments to comply, their guidelines have a basis in safety. OSHA does not only deal with fire departments, but with all private businesses. They have a ‘general duty’ clause, which says that employers (which volunteer fire departments are considered), have a duty to provide an environment free of recognized hazards.
The general duty clause is purposely vague, and at face value, you could interpret it that we couldn’t even run a department; after all, firefighting is inherently unsafe. OSHA understands, and wants us to be as safe as we can be, while doing a dangerous job. They do not tell us what tactics to use, or how to do our job, but they do say that we have to be prepared.
We need to train in order to be prepared. OSHA wants to see a few things when it comes to training. First of all, someone ‘qualified’ to do the training should lead the training. They would like to see certifications in the topic taught, and a fire service instructor certification, but they are not mandatory. What OSHA does not want to see is someone in charge of training who has two years of experience and can barely tell you which end of the hose the water comes out of.
The training needs to be planned, documented, and the members who attend need to meet the objectives of the training. Training should be a planned thing, not just something done to kill time. OSHA wants to see records of the training. One interesting point they made was to make sure members only receive credit if they actively participate and achieve the objectives of the training.
Participation lists are very important. When OSHA comes in, they talk to your members, and it is amazing what they can say. The representative who gave the program I attended gave this example: Members would sign in at the end of the drill and the signup sheet would be put into the training book. Some members would come by during the week, and sign in like they had attended the training. This may sound minor, but it undermines the entire process, and cheats everyone involved. Sign in lists should be signed last by the training officer, with no names added afterwards.
So what are the ‘required’ minimums of training? OSHA says you have to drill on the duties that your members will be required to perform. This gives you the flexibility to require different levels of training for different classes of firefighters. This does not allow you to just decide that Joe Blow doesn’t need training. It means that if someone is an exterior only firefighter, his or her requirements might be different than an interior firefighter.
Interior firefighters are expected to train at least quarterly on interior firefighting. This does not have to be a ‘live burn’, but should cover interior topics such as hose advancement, rescue, ventilation, fire behavior, etc.
After the last column, one of VolunteerFD.org’s members asked about minimum HAZMAT training. Here’s the scoop. Awareness training is meant for people who are going to activate the emergency system, while operations is for people who will be doing anything with the situation. That means, if you are going to put speedi dry on a spill, your firefighters need to be at the operational level. Even if they are not going to participate in the evolution, they should be trained to the operations level.
The one area that OSHA spends quite a bit of time on is your respiratory compliance program. To put it simply, they want to know how you train and assure that your members are capable of wearing SCBA.
The first component is a pre-employment physical. The physical needs to be done before the member trains with SCBA, and needs to assure that the member is physically fit to wear SCBA. OSHA does not have guidelines on what defines physically fit, but they want to see that someone with an MD after their name has done a physical, and signed off on your member. They do not have a requirement for ongoing physicals, but it is in your department’s best interest to have a physical requirement.
The next requirement is that your members need to annually pass a fit test. It does not have to be the fancy computerized test, but it is best. The problem is, OSHA requires that nothing passes through the seal of the facemask. This means, no beards, no goatees, no long sideburns, they must be clean-shaven, and no passing your glasses through the mask. I know it is controversial, but they are requiring this for our own protection.
The last requirement is that members need to be trained annually on both cognitive and psychomotor skills of using SCBA. If you keep no other training records, SCBA is the most important.
A few last points from OSHA… Officers should be trained to a level higher then the members they are in charge of. It does not have to be a certification, but there should be some minimum requirement for officers. Also, training should be coordinated with your mutual aid companies. A system should be designed to designate the level of training of your members, especially for when you leave town.
OSHA’s requirements aren’t extreme, but remember, if something bad happens, they will be looking at your department. Make sure you do your groundwork and prepare your firefighters so that bad things don’t have to happen.