NIMS Can Create Accountability Problems on Scene
You go to a fire in a garden apartment. You have fire showing from the terrace level with extension to the floor above. The chief tells you, "Engine One, you are the Division One Supervisor. You have Engine Two and Truck One in the division with you." You acknowledge the transmission and then get to work stretching a line.
What did you just say yes to? Well, when you accepted the assignment of Division One Supervisor, you said that you were responsible for unit accountability on the division as well as fire attack, ventilation, search, utility control, exposure protection, overhaul, salvage, etc., on the entire division. You are responsible for and accountable for the actions of Engine Two and Truck One even though you cannot see them and cannot know what they are doing. Can you really do this?
Advocates of NIMS as an incident command tool believe that breaking an incident into smaller functional groups allows the incident commander to maintain a safer span of control. In essence, the incident commander has delegated authority over and responsibility for the units in your division to you.
What makes this assignment problematic is that you still have a line to stretch into a smoke-filled apartment, you still have a crew to manage and you still have a fire to fight. This begs the question, "Can you do all those things and still be accountable for what the truck company is doing two apartments over?" When command calls for an accountability check, he/she will expect that you will know where everyone assigned to your division is and what they are doing.
While that sort of division of labor might work on really small structures or small fires, it is nearly impossible to manage in a multi-family dwelling or any other structure with a large footprint. It is impossible to the point that assigning an operating company to a division supervisor role in a structure fire is not accountability but rather the illusion of accountability.
I have been chided before for complaining about NIMS without providing alternative actions. In this case, I have an answer. NIMS is not the appropriate tool for daily operations in residential structures because the span of control rarely exceeds the commander's ability. In one area I am familiar with, a house fire assignment brings four engines, two trucks, a rescue company and chief officers.
This seems like a lot. But if you consider that the rescue company is the de facto RIT company, that only leaves six resources to manage, which is within the three to seven resource span of control recommendation. Further, consider that the first engine is assigned to attack the fire, the second engine provides a back-up line, the third engine goes above, the trucks vent, ladder and search while the fourth engine is in a standby mode.
This means that of the seven dispatched resources, only five are active at any one time. There is no need to break the operation into groups or divisions.
The second most common argument that I hear is that we will only be good at NIMS if we use it everyday. I disagree with that notion because what we are using everyday is not what we would use in a full-blown disaster. Furthermore I have argued extensively that NIMS is the wrong tool in the response phase of disasters.
I am not a one-man crusade against NIMS. I only hope to point out the cases where it is deficient and to avoid relying on it when it is not the most appropriate tool for the job. When I am assigned to Division One and I accept that mission, I am also accepting responsibility for people who I cannot see, who cannot identify me in the dark, who will have trouble finding me and who cannot complete the necessary tasks if they remain close enough for me to control.
One of the central tenets of creating incident objectives in NIMS is that they be S-M-A-R-T, and being truly accountable for a division while fighting a fire is not achievable.