Association Responds to Proposed Rules

 Regarding Fire Service Incident Management System, Fire Fighter Safety

                                                                                                                        July 3, 2007

FAX (609) 633-6729

Michael L. Ticktin, Esq.

Chief, Legislative Analysis

Department of Community Affairs

PO Box 802

Trenton, New Jersey 08625-0802

RE:       PRN 2007 – 135

            Fire Service Incident Management

Dear Mr. Ticktin:

The Burlington County Fire Chief’s Association supports the Incident Management System (IMS) for the Fire Service and all emergency responders. Members of the Association completed the revision / NIMS update of the Burlington County ICS policy.  The Association also provides two members to the Emergency Services Advisory Board (ESAB), which acts a conduit between Emergency Services and County government.  Various other committees continue to draft and revise operating guidelines utilized by all of the Burlington County Fire Departments and Emergency Responders.

            We do have some specific concerns related to the above mentioned Proposal.

N.J.S.A. 5:75 – 2.5 Safety Officer

Currently Reads

(a) An incident commander shall appoint a safety officer at every significant emergency event.

1.  “Significant emergency event” means any occasion or instance for which, in the determination of an incident commander, mutual aid assistance is needed to supplement local efforts and capabilities.

6.  When operating in forward or otherwise hazardous positions the safety officer shall be attired in appropriate personal protective equipment (PPE), including self-contained breathing apparatus (SCBA); have radio communication equipment; and be accompanied by another firefighter.

Comments

A “significant emergency event” may or may not warrant mutual aid in some jurisdictions.  In some jurisdictions mutual or automatic aid is standard procedure for most if not all emergency events.  This determination of significant is vague and could be interpreted inconsistently. 

ICS terminology does not include reference to a forward position.

Suggested revision

1.  “Significant emergency event” means any occasion or instance for which, in the determination of the incident commander, he or she cannot effectively monitor conditions to insure the safety of assigned personnel.

6.  When operating in a hazardous area, the safety officer shall be attired in the same level of personal protective equipment (PPE) as the responders assigned to the event, including self contained breathing apparatus (SCBA); have radio communication equipment; and be accompanied by another firefighter.

N.J.S.A. 5:75 – 2.6 Emergency Radio Traffic

Currently Reads

(c) Fire departments shall have a written standard operating guideline or procedure that uses the radio term “emergency traffic” as a designation to clear radio traffic.  An incident commander, safety officer, division or group supervisor, or any member who is in trouble or sees an emergency condition can declare emergency traffic.

(f) 1 The term “mayday” shall not be used when operating with aviation or marine personnel.

Comments

The term “emergency traffic” is certainly appropriate for such conditions as listed in (d).  The fire service has adopted and has been successfully using the term “mayday” in the event of a firefighter down, missing, trapped lost or stuck.  Much effort and many man-hours have gone into training our members on calling the “mayday”.  “Mayday” is an internationally used term for distress.  It is not a term that would be used lightly.

N.J.S.A 5:73-4.3(a) adopts the Thompson Delmar Learning publication titled “Firefighter’s Handbook: Essentials of Firefighting and Emergency Response – New Jersey Edition and Addendum” as the reference text for the Firefighter I certification program.  In Chapter 23 of the text, the section on Firefighter Emergencies states:

To help understand the actions to be taken during an actual or potential firefighter emergency, the firefighter must study procedures for rapid escape and declaring a MAYDAY for lost and trapped situations.  In the key terms at the end of the chapter, MAYDAY is defined as “A universal call for help.  A Mayday indicates that an individual or team, is in extreme danger.”

In accordance with the required text, the use of Mayday is currently being taught by the Eligible Organizations delivering Firefighter I classes.  To now adopt a regulation that says not to use the term Mayday would be counterproductive, misleading and dangerous.

N.J.S.A. 5:73-8.2 adopts the Thompson Delmar Learning “Company Officer Second Edition” as the text for Fire Officer I.  A table in Chapter 2 of the text addresses Improving Firefighter Communication.  Portions read:

            Inadequate communication has a definite negative impact on the safety of emergency personnel and may contribute to injuries or deaths of firefighters, rescue workers, and civilians.

One of the key issues listed is:

Tiered message priority. Keywords to prompt immediate action can be tiered based upon their priority; for example “Mayday” signals a life-or-death situation, whereas “urgent” may be used to signify a potentially serious problem.  Such message headers prompt each crew’s listening priorities and radio discipline.

 A message from a firefighter in extreme danger is “Emergency Traffic”.  It is a special class of “emergency traffic” and should be transmitted as a “Mayday”.

Wording of (f) 1 states: that “Mayday” shall not be used when operating with aviation or marine personnel.  This is misleading, suggesting that a firefighter could use “mayday” if aviation or marine personnel are not involved in the incident.

This Association has adopted a policy, “MAYDAY Guideline” dated June 14, 2006.  This guideline was previously revised in July 2005.  The guideline uses the nationally accepted terminology of “Mayday” and “Urgent”.  All departments within Burlington County utilize this language and use this guideline as a model for their individual suggested operating policies/guidelines.  In addition the Burlington County Emergency Services Training Center, utilizes the guideline as well as the National Fire Academy program “Calling the Mayday: Hands on Training (H134) in their training programs.

Suggested Revision

The wording contained in PRN 2005-370 printed at 37 N.J.R 3762(a) be utilized for the wording of section 5:75-2.6 for this proposal.

N.J.S.A. 5:75-2.7 Evacuation Signal

Currently Reads

(b)  The evacuation signal shall consist of repeated short blasts of an air horn for a period no longer than 10 seconds, followed by 10 seconds of silence.  This sequence of repeated short air horn blasts for 10 seconds, followed by a 10 second period of silence shall be done three times; the total evacuation signal, including periods of silence shall last 50 seconds.

(f)  Once personnel have exited the hazardous area, they shall report to their company officers or assemble in a predetermined area where officers shall take roll of those present.  Personnel accountability tags (PATs) shall be retrieved by firefighters at the time of roll call.  A personnel accountability report (PAR) shall be communicated to the incident commander when the roll call is complete.  If it is determined that personnel are missing, resources shall be immediately focused on the goal of rescuing or locating those missing persons.

Comments

Repeated long blasts of air horns may effectively shut down communications on an emergency scene.  Horns should be sounded in short duration bursts while remaining distinct so as not to be confused with incoming apparatus.  In addition to air horn blasts many jurisdictions utilize on-scene or dispatch based alert tones to notify units of the evacuation plan being in effect.  Both steps should be used in conjunction.

Upon exiting the hazard area, crews should immediately report PAR to their company officer or crew leader.  Time spent retrieving tags may detract from actually completing the PAR.  Maintaining crew integrity will allow for the PAR to be completed just as effectively and more efficiently.

Suggested Revision

(b)  The evacuation signal shall consist of three short air horn blasts, followed by a pause.  This cycle should be repeated three times.  Apparatus on all sides of the incident should utilize this signal to insure that all members can hear the signal.  The total time for the three sets of blasts should last approximately 30 seconds.

(f)  Once personnel have exited the hazardous area, each crew should report PAR to their respective supervisor, company officer or crew leader.  PAR should be communicated to the incident commander when completed.  If it is determined by command that personnel are missing, resources should be immediately focused on the goal of rescuing or locating those persons missing.

N.J.S.A. 5:75-2.8 Rapid intervention crews (RICs)

Currently Reads

(a) If the circumstances dictate it, a rapid intervention crew/company (RIC) shall be designated to standby in a state of readiness should the need arise to initiate a rescue effort for downed or missing firefighters.

(e) More than one RIC may be required for large scale or complex operations.

1.  A rescue group supervisor shall be assigned to manage multiple RICs.

(f)  Fire Departments shall develop and utilize written standard operating procedures/guidelines for using RICs including specialized training for members who will serve on the RIC.

Comments

As previously referenced within this document the State reference texts, Thompson Delmar Learning “Firefighter’s Handbook …” and “Company Officer” both reference the term RIT for Rapid Intervention Teams.  Again to deviate from the required text would be misleading and dangerous.

The Training and Education Advisory Council approved a training standard for the certification of Firefighter II, also using the Thompson Delmar text.  That Proposal was endorsed by the Fire Safety Commission and recommended to the DCA Commissioner for adoption.  It has been printed as PRN 2007-134 and is in the comment period.  Module 14 of the proposed training program is titled” Firefighter Survival (Firefighter Assistance & Search Team – Rapid Intervention Team, FAST-RIT).”

A joint committee of the Safety and Health Advisory Council and the Training and Education Advisory Council studied the question for the need for standardized uniform minimum training for RITs in New Jersey.  The committee concluded that RITs from several departments / jurisdictions are often called to work together and the possibility of deployment from one region of the State to another in times of major incidents makes it desirable for uniform RIT training.

Instructor staff from the Burlington County Emergency Services Training Center, some of which are members of this Association serve on a Training and Advisory Council committee developing state wide curriculum to include minimum basic RIT training.  It would be advisable that any regulation follow that recommendation.

The use of a rescue group supervisor to utilize multiple RITs is advisable however the term rescue could be confused with other incident functions.  The term RIT supervisor should be used to identify the group.

Suggested Revision

(a) If the circumstances dictate it, a rapid intervention team (RIT) shall be designated to standby in a state of readiness should the need arise to initiate a rescue effort for downed or missing firefighters

(e) More than one RIT may be required for large scale or complex operations.

1.  A RIT group supervisor shall be assigned to manage multiple RITs.

(f)  Based on standard operating guidelines developed by the Division of Fire Safety, fire departments shall develop and utilize written standard operating guidelines or procedures for using RITs including specialized training for those members who will serve on the RIT.

Any additional references in the wording of section 5:75-2.8 should be revised by substituting “rapid intervention team (RIT)” for “rapid intervention crew/company (RIC)”.

                                                            Respectfully,

                                                            Chief Ronald W. Devlin

                                                            President

Burlington County Chief’s Association

www.bcfirechiefs.org