Writing PPE specifications: Risk assessments
The better the risk assessment, the better the PPE meets the expectations of the organization
In my previous column I explained what a proper risk assessment entailed. I wrote that the risk assessment should include many considerations including threat recognition, performance design, limitations, responsibility and training. The information developed during that process would help the organization develop the proper specification that is appropriate to meet the needs of the organization. Since publishing that column I have received telephone calls and emails asking about risk assessments and specifications.
It appears that in some instances the term "risk assessment" is being batted around by fire departments and used without any supporting documentation. In addition, I have received copies of detailed PPE specifications that stated the specifications were based on a completed risk assessment. In every instance that risk assessment did not accompany the specification and was not available for public review.
The intent of the risk assessment is to create a foundation for a structural PPE specification. The risk assessment should provide a basis for the specification and provide any who reads it with background and the thought process for the various requirements.
This can only be accomplished by thinking the various areas of the risk assessment all the way through and then documenting the decisions. This background not only protects the organization, but also provides the manufacturers with a blueprint on what the organization expects from the PPE.
The risk assessment should be complete, published, and transparent. It is not enough to simply publish a specification and state that the requirements come from an unpublished risk assessment.
A proper specification for the structural ensemble should be a direct reflection of the various threats faced by the organization and explained by the completed risk assessment. Each of these threats should be fully developed in the risk assessment.
For example, a non-fire threat would include a daytime and nighttime visibility risk assessment. This assessment should include relative speeds of the vehicles passing (i.e. how much freeway is in the jurisdiction?) as well as policies and procedures for protecting roadway scenes.
It should also include possible scenarios for backgrounds at night. Are emergency responders working on a dark country road with a simple background or on downtown metropolitan freeways with complicated backgrounds? There is a difference between protecting emergency responders on both the former and the latter.
Night-time accident scenes
Think about the driver approaching a night-time accident scene on a busy metropolitan freeway. There is obviously the lights from the apparatus, flare patterns, police vehicles, street lights, and lights from the surrounding buildings. If firefighters are not readily distinguishable then they are in danger. This is just one example of issues that need to be completely reviewed — and solutions put on paper — before developing a specification.
This transition from risk assessment to technical specification should be completely transparent and every significant performance or design requirement should have the logic behind it clearly spelled out. The risk assessment, especially unpublished, should not be used to justify patented or proprietary designs, fabrics or accessories unless definitive performance expectations are clearly spelled out.
The risk assessment should be developed without specific products in mind, especially proprietary materials and designs and any requirements should be clearly spelled out to remove subjectivity of submittals. It is important that the organization be very specific on the specific desires and requirements.
The last thing that an organization should want is an argument with a manufacturer where the manufacturer states that their product meets the intent of some ambiguous requirement. This is where thinking it all the way through and documenting the process is important.
The development of the specification from the risk assessment can be accomplished in many ways, but it can be tricky. Specific performance and design specifications should not be included in the final specification until there have been field tests by the organization.
It is not to an organization's benefit to have a selection committee as the sole judge on what does or does not meet a specification. This can make things very messy, especially if the decision process is not transparent.
There is nothing wrong with involving the manufacturers in the development of a specification based on the risk assessment. The organization can publish a "request for information" and request "generic" solutions to any performance or design requirements that are necessary based on the risk assessment.
It is to the organization's advantage to put design and performance requirements in PPE specifications that can be built by any manufacturer. This puts the organization in the driver’s seat when dealing with the manufacturers and pricing.
If the organization specifies a garment that can be built the same by every manufacturer, then the organization wins. In this scenario, the organization gets the desired PPE and can make a decision based upon, amongst other things, pricing and customer service. There are certainly exceptions to this rule, but any exception should be carefully documented.
Risk assessment is not a term to be thrown about loosely, but a process that need to be thorough and transparent. When properly completed, the risk assessment will help provide PPE that is appropriate for the threats the members of the department face. The better the risk assessment, the better the PPE meets the expectations of the organization. And that is the goal — PPE that is the right PPE for the job.