                                       
                                       
                       Emergency Response and Preparedness 
Stakeholder Meeting
                                                               Washington, D.C.
                                                               July 30-31, 2014
                                                                               
                                                                               
                            Meeting Summary Report
                                                                               
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
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                              September 24, 2014

                                       
                                       
                                       
                               TABLE OF CONTENTS
                                       
	Page Number
Acronyms	iii
Introduction	1
Day 1	3
1.	Opening Remarks	3
2.	Administration of the Meeting	4
3.	Suggested Points for Group Discussion	4
3.1	Emergency Phases	4
3.2	Incident Scenarios	7
3.3	Emergency Categorization	10
3.4	Flexibility	14
4.	Closing Remarks	17
Day 2	18
1.	Opening Remarks	18
2.	Administration of the Meeting	18
3.	Suggested Points for Group Discussion	18
3.1	Emergency Phases	18
3.2	Incident Scenarios	24
3.3	Emergency Categorization	27
3.4	Flexibility	30
4.	Closing Remarks	34
Appendix 1. Meeting Agenda	Appendix 1-1
Attachment A.	Appendix 1-5
Attachment B.	Appendix 1-7
Appendix 2. Participant Lists	Appendix 2-1
Appendix 3. Standards Referenced During Meetings	Appendix 3-1



Acronyms 
CDL	Commercial Driver's License
CFR	Code of Federal Regulations
DHS	Department of Homeland Security
DOT	Department of Transportation
EAP	Employee Assistance Program
EMS	Emergency Medical Service
EPA	Environmental Protection Agency
EPCRA	Emergency Planning and Community Right-to-Know Act
ERHMS	Emergency Responder Health Monitoring and Surveillance
FEMA	Federal Emergency Management Agency
FMCSA	Federal Motor Carrier Safety Administration
HAZMAT	Hazardous Material 	
HAZWOPER	Hazardous Waste Operations and Emergency Response 
IFSAC	International Fire Service Accreditation Congress
ISO	Insurance Services Office
LEPC	Local Emergency Planning Committee
LODD	Line-of-Duty Death
MOU	Memorandum of Understanding
MUTCD	Manual on Uniform Traffic Control Devices
NFFF	National Fallen Firefighters Foundation
NFPA	National Fire Protection Association
NIST	National Institute of Standards and Technology
NIJ	National Institute of Justice
NIMS	National Incident Management System
NIOSH	National Institute for Occupational Safety and Health
NRF	National Response Framework
OMB	Office of Management and Budget
OSHA	Occupational Safety and Health Administration
PEC	Project Enhancement Corporation
PPE	Personal Protective Equipment
PSM	Process Safety Management
SBREFA	Small Business Regulatory Enforcement Fairness Act
SERC	State Emergency Response Commission
SCBA	Self-Contained Breathing Apparatus
SOP	Standard Operating Procedure
UL	Underwriters Laboratory
VAP	Vulnerability Assessment Program





Introduction
This report summarizes key discussion points during two stakeholder meetings that the Occupational Safety and Health Administration (OSHA) convened to discuss the early stages of development of a program standard on Emergency Response and Preparedness.  The two full-day meetings were held on July 30 and 31, 2014, at the U.S. Department of Labor in Washington, D.C.  The purpose of the meetings was to obtain opinions from stakeholders on a proposed standard framework aimed to protect the safety and health of emergency response personnel.  The standard framework and background information distributed to stakeholders prior to the meeting is provided in Appendix 1. 
Announcement of the stakeholder meeting was published in the Federal Register on June 4, 2014, and explained that parties interested in attending and participating should register in advance of the meeting.  The stakeholder meetings provided a setting for interested parties to provide verbal comments to be considered in the possible development of a proposed standard.  Forty-nine people participated in the two meetings  -  25 on the first day and 24 on the second day.  Participants represented professional associations, local, state, and federal agencies, industries, career and volunteer fire departments, and academia.  A complete list of meeting participants is provided in Appendix 2.  Members of the general public were allowed to observe the meetings.  Observers were given the opportunity to share comments and opinions at the end of each day. 
Project Enhancement Corporation (PEC) provided a technical writer to attend the meetings and to prepare this summary report.  This report captures the main discussion points that stakeholders raised during the meetings, but is not a verbatim transcript of the meetings.  The content throughout this report reflects the remarks made by stakeholders at the meetings and should not be viewed as the opinions of PEC.  No comments from OSHA or stakeholders should be construed as a definitive indication of what a proposed standard would contain.  All rulemaking options may be considered.


            Emergency Response and Preparedness Stakeholder Meeting
                               Washington, D.C.
                                 July 30, 2014
                                       
                            Meeting Summary Report
                                       
Day 1
Opening Remarks
Bill Perry, Acting Director, Directorate of Standards and Guidance, welcomed the stakeholders to the Emergency Response and Preparedness Stakeholder Meeting, and thanked everyone for taking the time to attend the meeting.  Mr. Perry also welcomed the expert opinions of stakeholders which will help OSHA decide on an appropriate course of action to ensure the health and safety of personnel involved in emergency response, and further emphasized the importance of the discussions as a significant step in helping OSHA consider all options for addressing emergency response and preparedness. 
Mr. Perry explained that the Directorate of Standards and Guidance is responsible for developing occupational safety and health standards, and that a critical part of developing any standard is to make sure that OSHA has the best available information to determine what would be necessary for the development of a standard that is not only protective and feasible, but that reflects the real-world challenges confronted by organizations engaged in emergency response activities.    
Mr. Perry then introduced some of the members of DOL staff who have been working on the emergency response project.   
Andy Levinson, Deputy Director in the Directorate of Standards and Guidance.  
Mark Hagemann, Director of the Office of Safety Systems. 
Mat Chibbaro, Fire Protection Engineer (Project Officer). 
Bill Hamilton, Fire Protection Engineer. 
Cherron Cox, Economist.
Amy Tryon, Attorney, Office of the Solicitor.
Shannon Lindey, Safety and Health Specialist. 
 Bill Perry introduced Jordan Barab, Deputy Assistant Secretary of Labor for Occupational Safety and Health.  Mr. Barab welcomed and thanked everyone for participating in the meeting.  He addressed the importance of the meeting, and emphasized the need to protect emergency responders making reference to the many catastrophic incidents such as 9/11, and the West, Texas Explosion.  Mr. Barab recognized the lack of regulatory oversight for the protection of emergency responders and stressed the value of having gathered together a panel of experts to help OSHA make intelligent decisions and develop a standard that will provide the protection and flexibility needed in this dynamic work environment.   
Administration of the Meeting
Meeting facilitator Barbara Upston, of Management Consulting Associates, provided the stakeholders with an overview of the meeting format.  Ms. Upston explained that the meeting should be considered an informal forum to present comments, and encouraged the stakeholders to provide their points of view.  She explained that although the meeting was being recorded and a summary report will be developed, no attribution will be made to individual commenters. 
Ms. Upston also provided the stakeholders with an overview of the agenda, and presented the specific questions that OSHA requested the stakeholders to address. 
Suggested Points for Group Discussion
Current OSHA standards do not address the full range of hazards that the emergency response community faces. The following remarks are important steps in helping OSHA consider all options for addressing emergency response and preparedness.  The following is a summary of the key stakeholder comments made during the meeting.  Comments are grouped together by topic and day, without reference to the identity of the commenter.
Emergency Phases
Discuss pros and cons of an Emergency Response and Preparedness standard concentrating on preparing for emergencies such as pre-incident planning and training versus comprehensively covering all phases of emergency response, including emergency operations. OSHA understands that the comprehensive option would need to account for the varied and fluctuating nature of emergency incidents that call for dynamic risk assessments.
Stakeholders provided the following comments in favor of a comprehensive standard:
The majority of participants expressed the view that a comprehensive standard is urgently needed and would be of great value to raise awareness within the emergency response community to prevent fatalities and injuries. 
A comprehensive standard could also be an opportunity to cover an "all hazards approach" to build internal resilience within entities/establishments.  
Funding for specific trainings and other requirements under the standard would be easier to secure. 
As a result of the standard, operating costs could actually be reduced by using mutual aid and working closer together among entities.
According to the emergency response and preparedness standard framework, emergency service entities would need to determine the range and level of services intended to provide, however, stakeholders recommend that the standard provides flexibility for fluctuations and services provided by an entity/establishment as these tend to change.
Fire service is overwhelmingly under-regulated currently and would benefit from this rulemaking.
This effort aligns with the NFFF Life Safety Initiatives. 
Stakeholders provided the following recommendations for the development of a comprehensive standard:
The development of a comprehensive standard should provide emphasis on the following components:
       Description of capabilities, communication of services to be provided, awareness and communication of services/tasks not provided, plans for unfulfilled services, and communication of mutual aid response partners.  
       A vulnerability assessment for determining emergency response capabilities that could be improved by preparation and/or training.
       Laying out the emergency response processes to identify and communicate risks within a worksite.  
       Training for the prevention of injuries and fatalities - OSHA's Disaster Site Worker Training Program is a great tool that should be publicized. 
       Preparedness training combining job hazard analysis with specific incidence of tasks giving known scenarios. 
       A wellness/fitness component. 
A common starting point for the development of the standard should be the National Response Framework (NRF) and the National Incident Management System (NIMS) structures. 
To make entities accountable, provide a timeframe for implementation and adoption.
Create a performance-based standard to provide a greater level of protection. 
Take into account the variety of demographics, in terms of an entities' size and resources, by allowing some flexibility.
Consistently interpret the various standards.   
Utilize consensus standards as a framework [i.e., National Fire Protection Association (NFPA), National Institute of Justice (NIJ)], understanding that OSHA can only reference specific editions of standards. 
Utilize the National Institute for Occupational Safety and Health (NIOSH) Emergency Responder Health Monitoring and Surveillance (ERHMS) documents. ERHMS is currently used as a national technical assistance document for protecting responders before, during and after an emergency.
Clearly define what the standard applies to and what the limits are. 
Use and coordinate with 29 CFR 1910, Occupational Safety and Health Standards and 29 CFR 1926, Safety and Health Regulations for Construction. 
Encourage upstream organizational responsibility.  
Include flight attendants as first responders.  
For skilled support personnel such as the towing industry, there could be a requirement for specific training such as the National Traffic Incident Management Responder Training. 
* Include general statements to deal with post-incidents.
* Involve the state plan states who can then engage their stakeholders.
Stakeholders provided the following concerns about a comprehensive standard:
It is important to balance employee safety versus the services provided in a community. It may be possible that the standard would push services out as a result of lack of funds needed to comply with the standard requirements. 
Funding would be needed to comply with the requirements put forth in the standard; oftentimes such funding is not available.
* The law enforcement exception could eliminate potential fire service members engaged in law enforcement activities such as fire investigations, bombing investigations, active hazardous materials (HAZMAT) investigations, which are included in the core missions of the fire service. 
If the towing industry is not considered as first responders as a whole, they may not be covered under the standard. However, OSHA considers this industry as skilled support personnel. 
* In parts of the country where OSHA has no jurisdiction, NFPA standards would be applied as default instead of OSHA's regulations. 
Stakeholders provided the following suggestions:
* Change title to Emergency Preparedness and Response.
* A standard concentrated on preparedness should be considered as a separate regulatory document combining 29 CFR 1910.120(q), Emergency Response Program to Hazardous Substance Releases, and 29 CFR 1910.156, Fire Brigades.
Other questions posed by OSHA:
* OSHA question:  What should happen if a community does not provide the necessary funding for delivering the services an organization needs? 
       A community should decide what types of services to provide, to what level, and recognize what services they are not capable of performing according to their capabilities and funding resources. 
* OSHA question:  Are there a large number of emergency responders not following the risk management sections of NFPA 1500, Standard on Fire Department Occupational Safety and Health Program?
       Yes, it is a widespread problem, and 
       To resolve it, there should be higher level management accountability. 
Incident Scenarios
Discuss the pros and cons of an OSHA Emergency Response and Preparedness standard comprehensively covering all facets of emergency response and preparedness versus concentrating on scenarios known to cause most line-of-duty deaths (LODDs) and injuries.  Possible scenarios include sudden cardiac events, vehicle related events, and interior offensive operations that are conducted when defensive operations are warranted.  Consider the following for the discussion:
The 2012 Federal Emergency Management Agency (FEMA) firefighter fatality report indicates that 55 percent of LODDs involve stress/overexertion and 22 percent involve vehicle collisions.
The 2012 NFPA firefighter fatality report indicates that 42 percent of LODDs involve sudden cardiac death (27 of 64) and 31percent are vehicle-related (20 of 64).
The offensive vs. defensive attack issue is a common theme in fire service publications.
The attachment showing NIOSH firefighter fatality reports that cite pre-incident planning
The attachment showing NFPA and FEMA overviews of 2012 firefighter injuries.
Stakeholders provided the following comments regarding a comprehensive standard covering all facets of emergency response and preparedness:
* A comprehensive list could be created using training standards and core competencies already in place.
* A comprehensive approach based on facts would be greatly effective and would help to prepare for the unknowns. 
* A comprehensive approach providing every scenario is not possible; instead using general categories according to type of incident would be more effective. 
* Allow jurisdictions to identify by themselves what the most likely hazards would be and be prepared for that, instead of creating a comprehensive list. 
* Cancer is a huge issue; possibly 800 firefighter deaths per year.
Stakeholders provided the following comments regarding a standard concentrating on scenarios known to cause most LODDs and injuries: 
 The regulation should not be limited to the most common LODDs; it should concentrate on a broader scale.  Scenario preparation should be completed at the risk assessment stage.  
 Concentrating on scenarios causing the most LODDs would not be a good approach since these may change in the future.
 Traffic safety can be improved by a combination of engineering, education, and enforcement strategies. For example, finding the appropriate balance between vehicle and personnel visibility would help prevent roadway fatalities. There could be great difficulty regulating the wellness and fitness of personnel to reduce the risk of cardiac arrest since these fatalities occur more often after fire ground operations than during operations, according to the NIOSH fatality investigation series. 
 A wellness and fitness program would greatly influence the prevention of cardiac arrests. 
 Cardiac arrest incidents can be prevented by mandating physicals, prophylactic use of aspirin, behavioral changes (i.e., smoking ban) among other practices. 
 Injuries have to be taken into account as much as LODDs. 
 Expand injury definition to include psychological injury.  There is a wealth of research/information on the topic that should be included in the prevention of injuries for emergency responders.   
 Cancer is a cumulative effect as a result of occupational hazards for emergency responders. For example, more firefighters have died as a result of cumulative effects from 9/11 than from the 9/11 incident itself.  
Stakeholders provided the following general comments during this session: 
   *    The NIOSH website has information from the U.S. Fire Administration on firefighter fatalities and includes an option to distinguish wildland firefighting fatalities.
   *    The Charleston 9 post-incident video presents how the department changed to a culture of safety as a result of the incident. 
   *    Defining the employer (i.e., political jurisdiction, worker compensation) would help relieve the burden of costs for those organizations (e.g., volunteer departments) that struggle to find resources. 
   *    Focusing on the costs on the back side is not necessary, instead changing behaviors and practices on the front side should be the focus. Better planning and training would reduce injuries and fatalities. 
   *    The 16 Firefighter Life Safety Initiatives launched in 2007 has helped change the cultural issues of the fire service. 
Other questions posed by OSHA:
 OSHA question:  Are most entities doing an NFPA 1582, Standard on Comprehensive Occupational Medical Program for Fire Departments, medical evaluation annually?  Is it appropriate in industrial settings as well as municipal emergency response? 
       Line workers working with emergency responders hold commercial driver licenses and their activities are regulated by the Federal Motor Carrier Safety Administration (FMCSA).  They are required to have annual physicals in order to renew their license.
       Most "big agencies" and some "medium size ones" do annual physicals, but "small ones" occasionally do it. 
       Effectively communicating the need to make changes is a key for improving health conditions. Good example is Phoenix Fire Department Tier 4 program.  Generally, Tier 1 means health condition is good, Tier 2 encompasses health issues that the firefighter can manage on their own, Tier 3 means there are health issues that need attention, Tier 4 means the health condition is not appropriate to perform firefighting operations.   
       Two issues related to NFPA 1582 according to fire chiefs include:
      oo Loss of identity of those who can no longer perform firefighter duties due to health related issues.
      oo Costs of delivering physicals. A possible solution might be partnering with public health departments to provide annual physicals.  
       NFPA 1582 does not necessarily need to be given to every firefighter, but instead be given to individuals who are performing risky operations.  For example, a New York law mandates annual physicals for firefighters commensurate with their duties.  Another example is the pack test that qualifies individuals for the three levels of wildland firefighting duties. 
       Most firefighters are not receiving annual physicals, especially volunteers.  This situation is probably caused by the lack of resources to cover the costs.   
       Physicals are not specific to the job when provided by contractor health clinics when compared to internal health units.  OSHA should standardize what a physical should be composed of, incorporating recent research findings to be more effective.
       Having regulations to prescreen future emergency responders would be helpful to prevent unfit personnel from entering the service. 
       High costs of physicals are a burden, there is no flat fee, depending on subsequent tests and other variables the cost could increase and reach the thousands. 
       There is already a mandate for a physical profile (29 CFR 1910.134, Respiratory Protection; 29 CFR 1910.120, Hazardous Waste Operations and Emergency Response).  What needs to be done is to tie regulations together.  
       Physicals are not the same across the board; appropriate criteria should be based on duties and activities related to the job description.  
       Job exposures should also be considered. 
       There is available research on the relationship between heat stress and cardiac arrest. 
       OSHA should also consider age, in other industrialized countries there are restrictions on age based on the activities to be performed. 
       Determining fitness for wearing Personal Protective Equipment (PPE) is a medical necessity that should be addressed before requiring the use of PPE. 
* OSHA question:  Many departments/entities pick and choose what standards to follow according to their needs/resources.  What should be different/modified from NFPA standards to fit an OSHA framework? 
       There are already consequences from not following consensus standards, however a regulation would prove much more effective and would possibly drive a change for safer operations. 
* OSHA question:  What should a wellness/fitness program look like?  Should OSHA provide specifics or be limited to require a wellness/fitness program? 
       OSHA should provide some specifics in addition to the requirement.
       OSHA should definitely prescribe physicals in the regulation. 
Emergency Categorization
NFPA 600 (industrial fire brigades) contains different provisions for defensive exterior and offensive interior operations, but NFPA 1710 and 1720 (fire department organization and deployment) contain no such categorization.  Discuss the pros and cons of an OSHA Emergency Response and Preparedness standard categorizing defensive and offensive separately for all fire service organizations performing structural firefighting.  Such an approach may be warranted because, unless an immediate threat to life exists, working incident operations are effectively defensive until adequate resources arrive to transition to offensive.  Where fire service resources are spread out, the defensive phase may be lengthy.
Stakeholders provided the following comments regarding an Emergency Response and Preparedness standard categorizing defensive and offensive separately for all fire service organizations performing structural firefighting: 
 Point of clarification: NFPA 1710 and 1720 are industry standards in the fire service, hence these are categorized as defensive/offensive.  An emerging category being used is offensive exterior operations. 
 An all hazards approach should combine operational awareness and different training levels. 
 Many fatalities occur as a result of misinterpreting defensive operations as offensive.  
 LODD reports from NIOSH do not address how lacking on-the-scene resources cause fatalities. Among the critical factors of size-up, resources are definitely a factor to consider. 
 An emergency preparedness standard goes beyond fire operations, thus it is unclear how emergency categorization (Discussion Item 3) would apply to all hazards.  Instead, analogies from 29 CFR 1910.120(q), Emergency Response Program to Hazardous Substance Releases, could be broadly applied as an emergency response framework versus specifically categorizing a regulation based on offensive/defensive operations. 
 Having appropriate training and resources are the ultimate drivers for successful, safe, and effective operations. 
 Typing fire departments based on capabilities could boost mutual aid among departments and would also result in safer operations.  
 Declaring mode of operations and capabilities with respect to the type of emergency situation could result in certain levels of safety in the regulation.  
 The emergency response entities would benefit if the language and thought process would be of similar nature as the professional response community versus firefighting operations (i.e., risk considerations, severity, lifesaving vs. recovery, stabilization). 
 Standardize/institutionalize the size-up process to evaluate the risk in a standard format, in which offensive/defensive could be a component.  The size-up process has the greatest potential to protect firefighters. 
Other questions posed by OSHA:
    OSHA question:  Is typing, in terms of characterizing an organization depending on their capabilities, a concept that could be applied to organizations beyond fire departments (e.g., construction worker employers, support services, industrial facilities)?  Is such typing currently happening among support services and others?
 The towing industry has been categorizing their capabilities for 20 years.  Close relationships were established with state police departments to develop categories 1, 2, and 3 towing capabilities to deal with different incidents. (Officers are trained to identify and request the appropriate category  -  size and type  -  of tow truck needed at an incident.)
 In the industry side, capabilities might be assessed according to the training level provided under 29 CFR 1910.120(q) (i.e., awareness, operational, specialist level).  However, in reality whether the response actions are followed according to the training depend on the resources available and level of knowledge at the time of the emergency.  Categorization may not work on the industry side; different phases may occur in a single emergency and cannot be predicted.  Categorizing may not allow flexibility to respond to an emergency. 
 In the construction industry assessing capabilities is very infrequent. In Seattle, local emergency responders work closely with the construction industry through a disaster response program. Active engagement includes cross training for pre-planning among the fire department and construction workers. 
 NFPA 600, and to some degree 29 CFR 1910.156, allow following a framework to define the scope of services/capabilities for an emergency.  By defining the scope of services, expectations for personnel and requirements for training can be defined.  
 Every incident dictates the phases (e.g., moving from offensive to defensive).  The level of preparedness to deliver those services can be dictated through the regulation.  Incident typing and categorization is a job for FEMA, not for OSHA. 
 Size-up needs to be a continuous process and be defined before an incident occurs and not just during the incident. 
 NIMS describes five levels of complexity, with varying needs for incident management, based on the type and complexity of an incident or event.  Such framework along a self-assessment could be used to build typing of a department regardless of hazard.  Such typing drives the level of training, skill requirements, PPE requirements, among other factors for an organization.    
    OSHA comment:  There are differences in approaches within NFPA standards, OSHA is looking to create common ground so that the emergency response community as a whole (e.g., industrial setting, municipal) understands the framework.   
 It is difficult to type an incident before arriving to the scene.  A 911 call only provides very basic information.  However, the basic questions to determine a size-up are:
   oo          What is on the scene?
   oo          What resources/assistance are on their way?
   oo          What else is needed?
   oo          What can be obtained outside of the department? 
 The Insurance Services Office (ISO) types the capabilities of fire departments.  There is also FEMA's National NIMS Resource Typing Criteria.  However, typing itself does not prevent incident fatalities.  In an incident, there were about 50 firefighters that lost their lives from a Type 1 fire, the size-up was not accurate, leading to the fatalities.  Institutionalizing the size-up process would provide greater protection. 
   *    OSHA question:  What would be the size-up elements that should be required in the standard? 
 According to the Blue Card Command Certification Program there are several items to size-up before engaging a fire.
   oo          Building type;
   oo          Action plan;
   oo          Strategy; 
   oo          Resource determination;
   oo          A 360 walk-around; and
   oo          Follow-up report. 
 Another size-up element would be interior hazards. 
 In addition to gathering the correct information for a size-up, communicating such information with field responders is critical, especially if aid is coming from a different jurisdiction. 
 From the Environmental Protection Agency (EPA) Emergency Planning and Community Right-to-Know Act (EPCRA) Tier II reporting requirements, departments should gather information about hazards from the State Emergency Response Commission (SERC) and Local Emergency Planning Committees (LEPC) as part of the pre-planning process. 
   *    OSHA question:  OSHA has a sense that the emergency response community is not getting the information from EPA's Emergency Planning Community Right-to-Know reporting.  Is the reporting not getting done?  To what extent do emergency responders actively look for this information directly from establishments? 
 A study looking at five rail incidents related to crude oil and ethanol found lack of pre-planning and use of available knowledge/resources (e.g., LEPCs, commodity flow studies).  Some of the jurisdictions identified rail as a hazard but did not use commodity flow studies for determination of better planning.  The reporting and information is available but communities are not prepared or capable of processing that information. 
 Availability of data varies by region.  Some communities do not have the knowledge to process the data. 
 From a municipal fire department perspective, the information/data is available but does not go out to the responder level. 
 From a research institution perspective, the information is reported.  The institution has the initiative to share the information directly with local responders. 
 Industries should be responsible of communicating their hazards to local emergency responders. 
 There are already plenty of regulations in the private sector for reporting. 
 Is OSHA looking to require some type of reporting regarding worker safety and health related to catastrophic release information?   
 OSHA response:  OSHA recognizes that the lack of available information about site hazards has been an issue for local emergency responders.  Whatever needs to be done to protect the safety and health of emergency responders will be considered as part of the regulation. 
 OSHA question:  Is behavioral health and wellness a topic that could be addressed by OSHA?
 Any legislation to support the mental wellness of the workers would be of great value. 
 The National Fallen Firefighters Foundation (NFFF) has launched an initiative on behavioral health. There are available research studies looking at different programs. 
 OSHA comments:  Suicide data gathering is difficult since second occupation (i.e., volunteer firefighter) is not reported. 
oo          Trauma exposure under the worker compensation system is extremely difficult to be recognized as a worker compensation claim.  There have been improvements in access to the Employee Assistance Program (EAP) with the Mental Health Parity and Addiction Equity Act.  However, occupational trauma exposure in the worker compensation system is extremely outdated, does not follow current research findings, and does not provide accurate treatment protocols.  There are a lot of prescriptions that serve to lubricate the suicide machinery. 
oo          A respondent resilience training project started a couple of years ago as a result of the epidemiology of the world trade center incident.  Such training makes a difference for the uniform services, and could also help skilled support personnel.  OSHA should consider mental health as a training piece.
oo          Psychological only claims are a challenge for the worker compensation system, and states handle them differently.  A physical injury that drives a psychological problem is usually covered as well as a psychological issue resulting in physical harm (i.e., ulcers as a result of stress).  However, mental-mental claims are a challenge. 
* OSHA question:  Are there any statistics on mental health issues (i.e., suicides, drug abuse) among the emergency response community? 
       Over 300 suicides a year is a non-official conservative estimate.
       The nature of the personnel could be described as adrenaline addicted. How does this relate or exacerbate the mental/physical health issues of the emergency response community? 
       Might also be a result of a cumulative effect? 
       There is available research that proves that emergency responders are at a higher risk of traumatic stress, which causes safety management system risk. 
Flexibility
Discuss how an OSHA Emergency Response and Preparedness standard could build in the flexibility to cover organizations of all sizes and complexity.  Discuss additional considerations and flexibility that may need to be built in for state plan states that cover municipal firefighters, including volunteers in some cases.
Stakeholders provided the following comments regarding flexibility:
 OSHA should look beyond individual constituencies. 
 Minimum expectations have to be in place in order to raise the standard. 
* By getting the standard in place, a majority will adopt it; however, there would be some that would not.  In any case, the majority will benefit and others will eventually follow. 
* An OSHA standard would be more pronounced and would strengthen the standards that are already in place.  Regulations are good when they are needed, and an Emergency Response and Preparedness standard is long overdue. 
* In the private sector, by having a mutual aid agreement there is no need to train workers, to have an industrial fire brigade, or to worry about the collateral duty of all employees.  Is OSHA looking to turn that around and have some type of responsibility/liability by having to train workers or to raise the bar on the expectations of a mutual aid agreement? 
* The separation should be clear between the responsibilities of a response organization and a private entity, and it goes back to the requirements of 29 CFR 1910.38, Emergency Action Plans and 29 CFR 1910.120.  In the emergency response requirements there is an opt-out.  Private entities have the option to decide the level of engagement of their employees in an emergency situation.  
* Most worker compensation claims are a result of human error.  How can human error be prevented? 
 Using similar principles on the exit requirement which allows for conformance with NFPA standards as an alternative compliance method should be encouraged. 
 The standard should follow the National Response Framework (NRF) and the NIMS structure.  
 Operational risk management should be considered in the decision making process.  The Below 100 is an initiative to reduce police LODDs to fewer than 100 per year with five key concepts which could be adapted to the emergency respond community.  Key concept 4 is "What is important now?" which tactically translates into what decision should be made at the moment of an incident.  Key concept 5 is "Complacency kills."  Tactical operations/actions should not be dictated, instead the process to make good decisions should be provided. 
 The emergency response regulation should have a separate focus from private industry because of the criticality of decisions such as saving lives.
 Let states deal with flexibility.
Other questions posed by OSHA: 
   *    OSHA question:  How should OSHA address training?  Should OSHA look at NFPA 1001 series of standards?  State and individual fire departments are doing their own training, and others are just looking at specific scopes.  How does OSHA think about training beyond requiring training to fulfill expectations/capabilities? 
 Best safety records are seen on services based on standards and certifications.  Training certifications with built-in mandatory learning and continuing educating hours would be most beneficial.  Vague training requirements are hard to fund and validate.
 OSHA question:  Are there particular certifications that are most useful or not useful?
 NFPA 1001 Firefighter 1 and 2 Certification are lifetime certifications.  There needs to be more institutionalization of certifications.
 Some large city fire academies provide good training as state academies.  There needs to be continuous training and re-certifications to make sure skill levels are up. 
    OSHA question:  If OSHA decides to require certain certification/training program such as NFPA 1001, is that going to cause problems/rage within the emergency response community?  If so, what would be minimum training requirements? 
 From the construction worker perspective, the emergency response entity should mandate some basic training that includes hazard identification and awareness, PPE, decontamination, and familiarity with incident command systems.  After 9/11, the disaster site worker course was developed including the topics previously mentioned.  There are 5,000 trainers ready to provide the training, however, there is not a significant demand to provide it. 
 Certification is needed whether it is NFPA 1001, establishing a performance based standard, or establishing a curriculum that is reviewable.  For the rail industry, there is pending legislation for a training requirement (14 CFR 243, Passenger Manifest Information).  A similar standard could be developed with an option to develop the training that meets the standard, is documented, and is reviewable.  There needs to be some degree of flexibility for organizations to comply. 
 The exemption of the fire service from the Commercial Driver License (CDL) requirement should be changed. 
 In Federal OSHA states there are no requirements to be a firefighter apart from the hazardous materials awareness training governed by EPA.  Certification training developed by NFPA consensus standards could be the minimum training standards. NFPA 1001, 1021 are appropriate for departments providing certain level of services.  Training should be commensurate to the type of fire department.  For example, for an all hazards fire department the NFPA 1670 or 29 CFR 1910.120 should be met. 
 Training requirements should be as focused as possible.
 Do not mandate NFPA compliance.
 Might lose volunteers if training requirements are onerous. 
OSHA asked for additional general comments:
   *    Does OSHA have a mechanism for an advisory committee during the rulemaking process? 
   *    OSHA response:  OSHA has the authority to convene a standards advisory committee governed under the Federal Advisory Committee Act for soliciting members and involving the public.
   *    Can OSHA do an introductory trial phase before the standard is implemented nationally in order to evaluate its effectiveness and impact? 
   *    OSHA response:  It is an intriguing idea; however, a regulation has never been piloted before to evaluate its effects.  OSHA would have to carefully evaluate such option.  Perhaps, if a state plan adopts it, that information could be used to evaluate the outcome. 
   *    Are there any states looking to implement a regulation similar to what OSHA is contemplating at this meeting?
   *    OSHA response:  OSHA is not aware of any states looking to implement such regulations. 
   *    It could be possible to move forward in phases.  Maybe by categorizing departments, there could be deployment of phases in certain timeframes.  The Department of Transportation is doing something similar with the tanker standard based on commodity groups. 
   *    OSHA comments:  Phasing a standard has been done in the past and could be done again.  In the electrical transmission standard, phases were rolled out in different timeframes to build the program up in a stepwise approach.
   *    California and New York (post-group) have adopted a minimum of standard requirements for emergency preparedness. 
OSHA welcomed observer comments:
* Since the emergency response community is in need of the standard, to speed up the process, it may be useful to look into developing a guidance documents and provide it in a shorter time frame. 
* The scope of the standard may be too narrow. It may be useful to involve more agencies so that the standard fits into a much larger picture. 
* OSHA comment: OSHA will engage with other agencies as part of the Office of Management and Budget (OMB) interagency review. Also, OSHA is engaged with the Department of Homeland Security (DHS) with respect to chemical safety and security. 
* Caution against extending too far into private sector because those who are already heavily regulated (i.e., Oil and gas industry) would probably be prevented from making progress. 
* NFPA standards are an infrastructure that can be used as a guide for the entire responder community.
* OSHA should consider enabling the development of frameworks for addressing occupational risks and standard operational procedures as complementary measures to the standard. 
Closing Remarks
OSHA representatives thanked the stakeholders for their participation and informed them that the meeting report will be publicly available in the docket. Mr. Perry acknowledged the productivity of the meeting, and thanked everyone for their participation. 
                              *     *     *     *
            Emergency Response and Preparedness Stakeholder Meeting
                               Washington, D.C.
                                 July 31, 2014
                            Meeting Summary Report
Day 2
Opening Remarks
Bill Perry, Acting Director, Directorate of Standards and Guidance, welcomed the stakeholders to the Emergency Response and Preparedness Stakeholder Meeting, and thanked everyone for taking the time to attend the meeting. Mr. Perry made the same opening remarks as at the Day 1 session (see Section 2 of this report). 
Later in the meeting, Dr. David Michaels, Assistant Secretary of Labor, expressed his gratitude to all attendees for taking the time to express their comments and help OSHA ensure that their regulations to protect emergency responders are effective.  Dr. Michaels made allusion to the difficult and challenging situations emergency responders face such as in the tragic events of West, Texas. He stressed how the federal government needs to be consistent to meet worker requirements and improve regulations. Dr. Michaels concluded by thanking all the stakeholders for their participation and encouraged everyone to keep engaging with this effort. 
Administration of the Meeting
Le'Angela Ingram, the Day 2 meeting facilitator, covered the same administrative details as on Day 1.
Suggested Points for Group Discussion
Current OSHA standards do not address the full range of hazards that the emergency response community faces.  The following remarks are important steps in helping OSHA consider all options for addressing emergency response and preparedness.  The following is a summary of the key stakeholder comments made during the meeting.  Comments are grouped together by topic and day, without reference to the identity of the commenter.
Emergency Phases
Discuss pros and cons of an Emergency Response and Preparedness standard concentrating on preparing for emergencies such as pre-incident planning and training versus comprehensively covering all phases of emergency response, including emergency operations.  OSHA understands that the comprehensive option would need to account for the varied and fluctuating nature of emergency incidents that call for dynamic risk assessments.
Stakeholders provided the following comments in favor of a comprehensive standard:
* Limiting the standard on preparedness will limit the scope of protection to the workers. Looking at the statistics provided, the injuries and fatalities are not limited by the lack of preparation/education but from incidents in ground operations. 
* A standard with a comprehensive view will benefit the emergency response community as a whole.   
* A comprehensive approach is needed for emergency responders including skilled support personnel.  In fact, the skilled support community is largely uninformed about emergency planning and preparedness.  The only applicable guidance is 29 CFR 1910.120, but even with that the community remains confused about their obligations.  For example, during a rail car explosion, a water pipe incident occurred where public workers were unsafely trying to deal with the situation and were exposed to many risks.  
* The standard needs to be comprehensive; it cannot be solely focused on training. 
* Within the fire service, NFPA standards are often referred to as recommended practice.  NIOSH LODD reports are evidence that injuries and fatalities are repeatedly occurring from the same causes (e.g., communication, training, preparedness).  A comprehensive standard is needed to reduce those injuries and fatalities. 
* There are small volunteer response organizations that do not communicate effectively despite available standards and guidance.  Having a framework that guides responding agencies to establish better communication to prevent episodes such as the West, Texas incident will be a way to improve risk communication and leading to safer operations. 
* Lack of guidance is a source of frustration for emergency responders when trying to comply with applicable regulations.  Part of the problem is that regulations are not comprehensive enough.  A comprehensive standard would be helpful. 
* A piece of a chemical hazard and safer alternatives training emphasizes OSHA's outdated regulations.  The importance of updating these standards and regulations will have a large impact. 
* A comprehensive standard would help alleviate some of the confusion arising from the many standards, guidelines, trainings and other documents addressing emergency preparedness and response. 
* A comprehensive standard would also address the cultural issues that may be rooted in the jurisdiction authorities as much as in the emergency response community. 
* A comprehensive standard would help alleviate a great number of disparities not only among states but among counties.  In California, every county has different standards to determine Emergency Medical Services (EMS) certified personnel.  By having a comprehensive standard, training could be streamlined and such disparities would no longer cause problems.
Stakeholders provided the following concerns about a comprehensive standard:
* Providing a framework for responder agencies such as guidance for an occupational safety plan with specific references (i.e., NFPA standards) could be used instead of a standard.  Plan details would not be provided; instead the jurisdiction would be required to do so.  Consequences for not complying could be further discussed.  The emergency response community is not ready for a strong regulatory oversight, however, demands guidance to improve responder safety. 
Stakeholders provided the following general comments and questions, which were followed by questions from OSHA:
* Can OSHA clarify who the audience will be? 
 OSHA Response:  OSHA is open to address the emergency community as a whole including emergency scene responders, medical responders, fire hazmat, operations and skilled support personnel among many others, but excluding law enforcement.  OSHA is not addressing criminal or crime prevention activities.  OSHA is contemplating a program standard which requires the development of a plan followed by training and carrying out of the plan.  The program standard would apply to any emergency response group, and there will be plenty of flexibility to accommodate the different needs of the groups.  From previous incidents/catastrophes, it is now clear that skilled support personnel are important players working side by side with emergency responders. 
    On the Emergency Response Stakeholder Meeting Participant Package, there is a note referring to the possibility of replacing the emergency response portion of the Hazardous Waste Operations and Emergency Response (HAZWOPER) standard.  Is the HAZWOPER standard going to be moved, modified, or re-written?  There are a large number of union members from the collateral duty of chemical emergency response that are trained based on the HAZWOPER standard.  There are many facilities where it is already difficult to have employees take time off to complete training. 
       OSHA Response:  The note on the HAZWOPER standard only indicates that if a comprehensive standard is to be developed all the various standards scattered among the already existing ones are going to be brought together into the new standard.  Nonetheless, the comprehensive standard will be available for public comments. 
 For clarification, is OSHA looking to take holistic approach to emergency response including competencies, training, preparedness, response activities on the scene, recovery activities? 
       OSHA Response:  Yes, OSHA will take a holistic approach including preparedness. 
 Would emergency receivers in hospitals be included/considered as emergency responders and covered by the proposed standard?
       OSHA Response:  Considering emergency receivers as response personnel and to be included in the standard has not been previously discussed.  There might be a separation among responders in the incident scene and those who get involved outside the scene.  However, at this point anything is on the table. 
* OSHA question:  The framework was developed using the NFPA standards as source material, would there be appropriate standards, aside from OSHA's guidance document, for first receivers that could be a helpful source document? 
       The Joint Commission has published hospital standards, and NFPA standards may also be a resource. 
       Several programs have looked at hospital based decontamination, and in the last 14 plus years, there is evidence that as high as 60 percent of patients are transported directly to a hospital often before first responders arrive on scene.  As a result, first receivers may be considered in the discussion. 
       The standard should cover first receivers.  There is evidence that training has been done with the American Nurses Association and other nurse unions documenting the hazards. 
       The emergency medical services are part of the preparedness aspect of emergency response.  In the past, incidents such as SARS have worsened due to the lack of connectivity between responders and first receivers. 
       First receivers definitely need to be included in the process because they represent the hospital's element of emergency response and also because their primary job duty is not decontamination. 
* OSHA question:  Are there any comments from non-municipal response industrial settings? 
       The energy production sector is already heavily regulated for emergency preparedness by other agencies and committees thus have robust emergency preparedness plans.
 How would that integrate with the standard? 
       OSHA response:  OSHA will align with other federal agencies specially FEMA's NIMS.
 The energy production sector has emergency response plans already approved by the different state agencies.  Would OSHA have a separate approval and enforcement piece? 
       OSHA response:  OSHA does not review and approve plans in advance.  The oil and gas industry is substantially different from all the other groups that would be covered by industrial fire brigades.  The oil and gas industry emergency preparedness plans probably go beyond what is expected from most industrial facilities based on the nature of the industry. 
* How does OSHA avoid a standard from becoming outdated in the long term? 
       OSHA response:  When a standard is adopted, incorporation by reference is required by referencing specific editions of source documents (i.e., NFPA standards).  For program standards like NFPA 1500, OSHA does not generally incorporate the entire standard because they are not intended to be enforceable and tend to dramatically change.  When OSHA uses incorporation by reference, there is a policy that accepts the newest version of the referenced document.  OSHA also has a consensus standard update to renew consensus product standards.  Compliance options are also provided in standards which provide some flexibility for compliance. 
* When does OSHA see the emergency response stage ending?  Would the standard apply to the recovery process as well?  Would the standard apply to both private and public EMS providers? 
       OSHA response:  Private EMS would be covered everywhere (i.e., Federal states and state plan states), and public EMS would only be covered in state plan states. 
* Many fire departments are volunteer or combination departments. Would those be considered private EMS? 
       OSHA response:  Volunteer fire departments are covered at the discretion of the state plan states.  Federal OSHA does not cover them.  However, the standard would drive a cultural change for better practices and safer operations.
* OSHA question:  OSHA has not determined when emergency response ends.  What are your thoughts?  For example, is overhaul in fire scenarios an important part?  In non-fire scenarios when do emergency response operations end? 
       Biological and pandemic events have not been discussed in the application of the standard, but every response has its own circumstances for determining when response ends and efforts shift to recovery.  From a national training perspective, first responders need to understand when the standard may potentially end. 
       The start and end definition of a response is strictly tied to the situation, the level of response needed, the amount of people in need, and providing a general definition could be extremely difficult. 
       Many workers assisting with clean-up and other recovery efforts are mostly unprepared.  These skilled support personnel should be adequately trained and protected. 
       OSHA comments: When the authority having jurisdiction decides that all hazards are abated and no further protection is required, would that be considered the end of the response phase? 
       Post evaluation is also an important aspect of emergency response because lessons learned would provide important information for preparing for the next event. 
       Leadership is more important than culture in order to apply the requirements of a standard. 
* OSHA question:  Are post-incident evaluations required for every response provided?  Are post-incident evaluations delivered as written reports for every incident or are they more informal? 
       For significant incidents, there are structured debriefings that serve to evaluate Standard Operating Procedures (SOPs).  For small incidents, a conversation about the event is used and is as beneficial as a structured debriefing. 
       Small and significant incident conversations and debriefings should be included in standards as part of a post-incident evaluation. 
       A key for post-incident evaluations is to refer to them as lessons learned. 
       After action reviews become a learning environment, and do not necessarily need to be a written report or round table conversation.
       From a safety management systems perspective, a documented debriefing would be useful in preparedness planning. 
       OSHA should limit the description of post-incident analysis methods and focus on what should be accomplished.  For major incidents such as loss of life, some criteria should be met as part of the post-evaluation. 
       A formal or informal post-incident analysis is a simple daily command function.  For a more strategic point of view for reducing LODDs, the causes (e.g., poor communication, lack of command structure, lack of situational awareness, operating offensively in defensive conditions) and incident management should be the focus. 
       Action reporting after an incident cannot be considered lessons learned.  Lessons learned means there was a positive change.  Tangible lessons learned should be incorporated in post-evaluations in order to positively drive a change.
       In the utilities sector, a successful best practices program provides subject matter experts to review and alert partners about risks and provide recommendations. 
* OSHA question:  Is the accreditation process for fire departments rigorous enough to improve the quality of emergency response services?  Or is there some accreditation for industrial settings?  
       Accreditations help but are not enough.  The Charleston 9 team had the best accreditation rating, but they did not follow procedures as expected.  The accreditation is an important part of the process, but having the standard allows for the necessary training, preparedness, equipment, and everything else. 
       NFFF Vulnerability Assessment Program (VAP) a web-based tool that helps departments assess their existing capabilities against known causes of LODDs by identifying the gap leading to the incident.  The VAP could be a solid tool to develop recommended practices.
       Accreditation programs that fulfill components of OSHA requirements should be encouraged as elements or indicators of partial compliance. 
       Since accreditation is not mandatory, agencies decide whether to do them.
       In some industrial settings, OSHA standards are used as accreditation in a very holistic approach.  Emergency response plans are reviewed and approved by state and Federal agencies.  Many volunteer Type 4-5 incident commanders use the blue card program for accreditation.  The blue card program is being used to create and industrial setting blue card accreditation program.  
       Incident command system training should be required.  
* OSHA question:  How can OSHA prevent the issue of personnel engaging in offensive operations during defensive situations? 
       Incident commanders must have the basic understanding of command functions so that responders operating in the hazard zone have the strategies and communications needed to perform.  The blue card program is an excellent response model for deploying, controlling, and communicating with resources that can be used in the development of the standard. 
       Building construction and fire behavior training is needed to prevent the issue of engaging in offensive operations during defensive situations. 
       National Institute of Standards and Technology (NIST) and Underwriters Laboratory (UL) are good sources of information for research findings regarding legacy versus modern fuels, furnishing and building construction. 
       The offensive/defensive discussion is quite recent.  A few years back, offensive tactics and operations were leading in the field and in training.  Due to the changing stability in modern building construction offensive tactics are increasingly more dangerous and likely to cause more LODDs.  
       Training for avoiding specific tactics is a key. 
       Identify criteria in a generic way (e.g., resource, equipment, personnel, among others) instead of looking at specific incidents to categorize and make decisions about offensive/defensive tactics.
       Consider risk of occupational disease.
       Pre-incident and competence planning to recognize capabilities should be included in the regulation. 
* Current tactics in criminal scenes do not allow emergency responders until the situation is deemed safe, however people in the scene needing medical assistance are not receiving immediate attention and probably die.  Is OSHA considering evaluating this situation for the development of the standard? 
* OSHA response:  OSHA is not trying to engage in the operations of criminal activities.  The tactical and operational details go beyond the scope of OSHA's regulatory authority.  The processes, systems and training to ensure the safety of emergency responders are OSHA's responsibilities. 
* Higher education institutions either public or private have some degree of emergency response personnel, and some of the most dangerous chemicals are used in institutional research laboratories.  Has OSHA considered including emergency response personnel working for academic institutions as part of the standard? 
       OSHA response:  OSHA would definitely be interested in including emergency responders working in academic institutions.
* In situations where there are shared components of emergency response and criminal activities, how would the standard apply? 
       OSHA response:  OSHA is trying to stay away from the criminal activity side, but where complex scenarios occur, OSHA has not decided how to deal with such scenarios.  
Incident Scenarios
Discuss the pros and cons of an OSHA Emergency Response and Preparedness standard comprehensively covering all facets of emergency response and preparedness versus concentrating on scenarios known to cause most LODDs and injuries.  Possible scenarios include sudden cardiac events, vehicle related events, and interior offensive operations that are conducted when defensive operations are warranted. Consider the following for the discussion:
 The 2012 FEMA firefighter fatality report indicates that 55 percent of LODDs involve stress/overexertion and 22 percent involve vehicle collisions.
 The 2012 NFPA firefighter fatality report indicates that 42 percent of LODDs involve sudden cardiac death (27 of 64) and 31 percent are vehicle-related (20 of 64).
 The offensive vs. defensive attack issue is a common theme in fire service publications.
 The attachment showing NIOSH firefighter fatality reports that cite pre-incident planning.
 The attachment showing NFPA and FEMA overviews of 2012 firefighter injuries.
Stakeholders provided the following comments regarding a comprehensive standard covering all facets of emergency response and preparedness:
* In the last twenty years, there have been 4,500 ambulance crashes, some related to sleep inertia, risking emergency responders and patients.  The conversation about occupational risks needs to be broadened and include topics such as motor vehicle crashes in addition to cardiac arrest, cancer, and others.
* The discussion needs to be broadened from firefighter fatalities on the EMS side.  Motor vehicle crashes are caused not only by human error but from mechanical failure.  In the preparedness and planning side, making sure that all equipment including vehicles is properly functioning for the activities to be performed.  Patient handling is also a topic that should be discussed as a source of emergency personnel injuries. 
* The standard should include all hazards.  By focusing on specific scenarios, many emergency responders would not be covered.  By using the proposed list, the focus is on firefighters and many other emergency responders would be left out. 
* The standard should be all encompassing.
* A comprehensive standard is warranted.
* Discussing the behaviors that cause injuries and deaths would be beneficial for training and planning.  Describing scenarios would be helpful but the standard needs to be comprehensive.  Generic lessons that apply to all responders include driving, health and welfare, medical ability, work practices, risk assessment. 
* At the local level, the greatest benefit will come from a comprehensive standard. 
* In some areas such as the utility sector, there are good regulations and mechanisms that can be used as a framework. 
* Without a comprehensive standard, skilled support personnel would not be covered.
* Follow existing approaches for protective standards that currently work effectively (e.g., respiratory protection fit testing).   
* Is the intent of the standard to drive a cultural change and be more proactive or to become more responsive based on the most common LODDs?  Who is responsible for the standard in an incident?  Does it apply to a shelter management team and public health officials?  Defining the intent and audience is needed. 
Other questions posed by OSHA:
* OSHA question:  Many emergency responders are not covered by Department of Transportation's (DOT's) CDL requirements.  How does OSHA address the issue of appropriate training for drivers?  Is there a need to do the Triple K standard or NFPA standards for emergency response vehicles?  How does OSHA address the maintenance issues on emergency response vehicles?
       Existing standards that are already widely adopted and well-perceived should be components of the approach OSHA decides to follow. 
       Deterioration of vehicle safety elements should be managed by the authority/employer. 
       There are plenty of emergency vehicle operator courses, and no particular standard has identified the need for them.  There are new ambulance safety standards being developed by a consensus process that OSHA could look at. 
       Many small, volunteer, and combination departments are insured.  Some regulation is held by insurance companies requiring emergency vehicle operation training. 
       Many LODDs related to vehicle accidents happen in privately owned vehicles driving from/to the station or to the scene.  Departments should have a policy in place regarding the use of privately owned vehicles.
* OSHA question:  For driving a tanker truck, a quint, or a large vehicle, are there NFPA standards for driver training?  Is there some type of minimum training that emergency responders have to do? 
       Interception, speed limit exceedance, climate variation policies are the type of issues departments should be asked to have in place to protect emergency responders.
       When a department has emergency responders that ignore the policies and restrictions of using personal vehicles, there is a lack of leadership.  An important element of the standard should require leadership involvement for enforcement. 
       Leadership personnel should be competent enough to be responsible for the actions of others.  A regulation should address competency for leadership to be successful. 
       Organizational leadership within many departments is missing.  OSHA could help address the leadership issue from a strategic level perspective. 
       OSHA should base decisions on science.  There is plenty of data available (i.e., ambulance crash statistics) for some of the emergency response community.  However, there is not an injury data repository for emergency responders. 
       Appropriate training should be derived from recognized hazards. 
* OSHA question:  How could leadership be specified and/or described to ensure departments operate safely?  What good leaders should do to make sure their departments operate safely?
       Strategic and basic functions of command: incident management practices, pre-planning activities, preparation activities (e.g., vehicle maintenance).
       The standard should encourage, promote, and enforce leadership.  A problem that is identified, addressed, and changed is a demonstration of leadership. 
       Employee participation should also be required in the standard similar to the confined space entry standard requirement for an annual review.  Good leadership also means listening to employees' concerns and requirements. 
       A safety management system for responder agencies should define leadership starting with the head of an organization.  In the operational level, leadership may depend on the circumstances of the incident scene and who is present at the time. 
       Benchmarks should be defined as well as identifiable measures such as certifications. 
       The standard should define a broad set of leadership competencies, such as policy enforcement, documenting/reporting, establishing criteria for institutionalizing policy, integrating a performance loop for action, review, and improvement.  
       Using the Process Safety Management (PSM) framework of the chemical and oil and gas industries would be beneficial and long-lasting. 
Emergency Categorization
NFPA 600 (industrial fire brigades) contains different provisions for defensive exterior and offensive interior operations, but NFPA 1710 and 1720 (fire department organization and deployment) contain no such categorization.  Discuss the pros and cons of an OSHA Emergency Response and Preparedness standard categorizing defensive and offensive separately for all fire service organizations performing structural firefighting.  Such an approach may be warranted because, unless an immediate threat to life exists, working incident operations are effectively defensive until adequate resources arrive to transition to offensive.  Where fire service resources are spread out, the defensive phase may be lengthy.
Stakeholders provided the following comments regarding an Emergency Response and Preparedness standard categorizing defensive and offensive separately for all fire service organizations performing structural firefighting:
* From an industry point of view, if a robust municipal emergency response department is available, the facilities would not need to provide industrial firefighter brigades.  But in rural locations where there is a limited municipal resource for emergency response, a facility could train for interior and exterior fire brigades. 
* In the hazardous material (HAZMAT) response community, there are three levels of knowledge: awareness, operations, and technician.  Higher hazard engagement requires a higher level of knowledge.  Levels of knowledge could be part of a standard in terms of hazards, engagement, PPE, and could be more productive than trying to identify tactical responses as with the comparison between NFPA 600 and 1710. 
* The standard could serve as a roadmap for any emergency response entity to decide whether to engage in certain activities.  The standard should provide guidance on training and equipment needed to engage in an activity.  
* Fire departments are commonly assumed to engage in certain activities such as confined space rescue even if the fire department is not capable of performing such duties.  The standard could help avoid such assumptions and instead define the capabilities of emergency response entities.
Other questions posed by OSHA:
* OSHA question:  Is the skilled support section of the HAZWOPER standard working properly?  Are there specifics that should be done differently? For skilled support personnel in emergency response scenarios, what should be done to make sure interpretation is accurate? 
       The language between skilled support and technician operations must be distinct to avoid confusion.  The difference between skilled support and technician operations is very slim. 
* OSHA question:  How can the standard be re-written to make such distinction?  Skilled support personnel are not related to emergency response entities but are called in upon to provide a service.  How can OSHA make sure skilled support personnel are trained and protected?
       Training should be required (i.e., 10 hour disaster site worker, construction outreach).  Some element for working together with emergency responders before an emergency occurs.  Clearly define who is responsible for the skilled support personnel in case of an accident. 
       Skilled support personnel including public workers need to be trained at an operations level.  Planning for emergencies cannot be an afterthought as it currently occurs with skilled support personnel employers.  Better communication should be established with local emergency planning committees. 
       Skilled support personnel should, at least, be required to get some training to be better prepared. 
       First responders should know their skilled support personnel, and make sure they are trained and qualified to perform the tasks. 
       Training has to be in place, especially in the disaster preparedness and planning stage. 
* OSHA question:  To what extent do fire departments choose a skilled support team in advance?  How much pre-planning is conducted with skilled support personnel?  How can OSHA make sure that skilled support personnel are qualified and have the necessary training to perform?  What can be done to improve the relationships and preplanning between emergency response and skilled support teams?
 The fire department should be responsible for meeting with skilled support groups and have a robust emergency management contacts network and relationship. 
 Getting to know skilled support resources varies by department, but relationships should be built before an incident happens. 
 Oftentimes, volunteer fire departments work closely with county's office of emergency management to get heavy equipment or skilled support resources needed to respond to an emergency.  Building those relationships are vital to perform the necessary activities. 
 If a resource is not available in the mutual aid list, requests are made to local, regional, or state emergency management offices to get the skilled support resources needed.  In an industrial setting, skilled support resources are prequalified and contracted out. 
 Typing equipment through NIMS is an effective tool to obtain the right equipment and the correct skilled support personnel.
 How could the OSHA standard process align with the standard revitalization on emergency response that is happening in the Department of Homeland Security (DHS)? 
 OSHA response:  An OSHA representative working closely with the PSM response to the executive order is part of the current OSHA standard process.  OSHA is working to coordinate with other federal agencies, but the local emergency planning commission piece is led by EPA and outside the scope of OSHA.  Nonetheless, EPA and OSHA did a pilot program in New York/New Jersey to improve communication between emergency responders and federal agencies.  The pilot program was discussed in the executive order response.  OSHA will continue to coordinate with other federal agencies.  A big challenge is the variability of resources and engagement among the many local emergency planning commissions. 
* OSHA question:  Are there comments about medical evaluations and wellness/fitness programs?  How often should exams be administered?  What components should be included in a medical evaluation?  
 An annual medical should be administered to all first responders and be a priority in the standard.  Wellness/fitness programs should be mandatory and comprehensive.  For departments that do not have monetary resources a minimum baseline should be required.  The benefits from pre-screening are manifold specially for preventing cardiac arrest fatalities. 
 A tiered approach is needed to prevent departments from disbanding due to lack of funding.  For small volunteer departments, medicals could be an issue due to financial hardship. 
 Annual physicals and a wellness/fitness program are extremely important.  A tiered approach would be helpful and departments must commit to it. 
 Physicians need to be involved and understand the rigors and stress that emergency responders experience during operations. 
 Weight issues should also be communicated between physicians and first responders. 
 When assessing capabilities, the level of medical evaluation could be tied together.  
 Medical screening should be holistic across all emergency responders, be risk based, and age based. 
 Cost sensitivity for medical screenings should provide options such as scaling up the process, compliance timing permission, or Federal funding support. 
 Physical requirements should be different for EMS personnel and firefighters due to the nature of their activities. 
 Physical exams and requirements for public workers may not be welcomed. 
 Physicals are important for all emergency responders, however smaller departments would certainly face challenges when trying to fund them.  Logistical challenges for small rural departments include finding a medical facility that provides a specific physical exam.
 Firefighter rehabilitation and medical monitoring during training and/or during an emergency scene need to be considered. 
 Personnel resources as well as physical fitness are needed to conduct a task safely (i.e., carrying an overweight patient).
 Having the tools needed to perform a task is crucial.  Moreover, funding for advanced equipment that could help perform tasks safer would be greatly beneficial. 
 NFPA 1582 is a great resource for safety management standards, but responder monitoring is not included.  An occupational illness could be carried once a responder is no longer active in the service.  Monitoring could be an important component to make sure workers are protected from possible occupational illness even after leaving the service. 
 Firefighter suicide is also a topic that should be discussed.  During 2014 alone, there have been 40 cases reported.  Included in the annual physical, a mental health exam and monitoring are needed.  
 OSHA comment:  Suicide data is very hard to obtain, especially for volunteer personnel because secondary occupation is not captured when demographics are documented. 
 The health component within the fire industry has been transforming.  Lessons learned from past incidents such as 9/11 and Charleston have started conversations about resiliency, peer intervention, clinician training, psychological first aid, and other components. 
 A behavioral health component has to be included in the standard. 
 A list of exposures, conditions, occupation(s) for private physicians would serve as a guideline.
 Flexibility has to be included as part of the physical exams component.
 Occupational cancer is also an issue. Early detection and treatment of occupational cancer are needed.  NIOSH has data. Death certificates list last occupation which may not be firefighter. Adding cancer deaths could double the number of LODDs.
 Behavioral health is a big issue.  A behavioral program called "Share the Load" was designed to provide behavioral health resources to fire departments. 
 Data possibly available from the Veterans Administration.
 Medical coding standards need to change.

Flexibility
Discuss how an OSHA Emergency Response and Preparedness standard could build in the flexibility to cover organizations of all sizes and complexity.  Discuss additional considerations and flexibility that may need to be built in for state plan states that cover municipal firefighters, including volunteers in some cases.
Stakeholders provided the following comments:
* There is a sense of fear in some fire departments about the potential scope of future OSHA enforcement. 
* A good approach would be to create a strategic standard that is performance based and that provides the basic functions of command, pre-incident planning, preparedness activities, and that utilizes the incident management process from NIMS. 
* A performance based standard that grows as the fire service gets more experienced would be successful. 
* In addition to performance based, the standard should be risk-based (i.e., challenges that have to be confronted) and competency-based (i.e., training). Using this framework, the standard can be scalable to any size or situation.  
* For industrial settings, it is important that the standard be inclusive rather than exclusive since full-time and part-time employees are part of the emergency response teams.  The HAZWOPER is a good model that goes beyond regular full-time teams. 
* The standard should include a component of support for state plan states.
* OSHA comment:  For OSHA standards, there is an internal outreach component in which OSHA field personnel are trained and prepared to engage with the public that are dealing with the standards. 
Other questions posed by OSHA:
* OSHA question:  OSHA's intent is to stay away from tactics.  Are there any sensitive topics that could raise resentment among the emergency response community and that OSHA should stay away from? 
* Have there been discussions with state agencies that would have to take the standard forward?  In the past, issues have arisen when trying to decide what players are involved in a standard (i.e., volunteers, private employees, public employees). 
       OSHA response:  Each state decides whether volunteers are considered employees and if they are covered under certain standards.  OSHA has spoken to some state plan administrators and they would be participating in the development of the standard process. 
* OSHA question:  How much is the multi-employer issue (i.e., combination departments, career-volunteer) a problem for the emergency response community?  Has the multi-employer issue been worked out at the state and local level?
       Multi-employer relationships are key for emergency responders.  In the industrial sector, mutual aid agreements have to be put in place with emergency responder teams.  There could be some sensitivity if emergency responders contracted for an industrial setting are affected by the standard. 
       If the standard is developed as highly enforcement oriented, the community might not see the benefits it aims to provide. 
       If the standard becomes widely accepted and implemented, it could affect other programs that are already in place and working properly (i.e., NIMS). 
       If the standard duplicates what other Federal programs are already doing, it could weaken the credibility of the standard. 
       Interstate jurisdictional differences (e.g., siren use permit across counties) could become a problem and have to be taken into consideration. 
       Employer responsibility should be clearly defined to prevent confusion about mutual-aid agreement practices. 
       The standard could actually strengthen mutual-aid responses.  The framework is strong enough to be applied to any department. 
       Public employees are covered under state plan states.  The interpretation of standards varies greatly among states.  In states with safety and health plans of their own, OSHA standards are used as the baseline.  In states where there is not direct protection, OSHA standards or less stringent interpretations are assimilated. 
       State plan states would be a source of information about successes and failures of plan implemented.
* OSHA question:  How should OSHA address training?  Should everyone use NFPA standards for training?  Are fire academies using something else besides NFPA standards? 
       Training should be competency based and trainees should be required to demonstrate those competencies. 
       Emergency services and some skilled support services have some type of training leading to certification.  The standard should identify core competency areas that lead to external certification.  
       There are 1.7 million responders already accredited by Pro Board and the International Fire Service Accreditation Congress (IFSAC).  The training component should recognize and rely on the accreditations already in place. 
       Training should be competency based, and include lessons learned and drills.
       Addressing training in detail will lead into tactics, which should be avoided in the standard.  Instead, the standard should lay out basic competencies and require certifications as proof of training. 
OSHA opened the discussion to anything that has not been addressed and that OSHA should know:
* If the standard becomes too detailed, there is a possibility that some departments, especially small ones, will lose focus and will not see the benefits.  The standard should not lose its focus of protecting emergency responders. 
* Specialized equipment may not be readily available.  It is important to establish relationships with distributors to make sure equipment is available when emergencies happen. 
* OSHA question:  Do departments have enough equipment (i.e., PPE, respiratory protection, other) to be prepared for emergencies and be able to sustain operations? 
       NFPA did a fire needs assessment three years ago, to which roughly 8,000 agencies responded.  Results showed that about 60 percent of responders said they had enough self-contained breathing apparatus (SCBAs) for everyone on duty.  The majority of the 40 percent of the departments that did not have enough equipment are located in small communities (i.e., population of <= 5,000). 
       Having the adequate respiratory protection is a challenge because the equipment has to be certified by NIOSH. 
       Interoperability and compatibility of equipment (e.g., masks and canisters from different manufacturers) is a challenge.  Interoperability should be part of the preparedness aspect of the standard. 
* OSHA question:  Are there policies and procedures that OSHA could use to improve communications in response operations so that incident commanders receive all the crucial information?
       In a performance based standard, the basic functions of command should be established and the operating divisions should be required to provide can reports. 
       Communication could be divided out into three parts, the decision that there is a need for communications to be established, the message, and the tool to send the message. 
       Make sure emergency operators have a communication model.
       Make sure there is accountability.
       NFPA 1001 has a component that requires personnel to demonstrate the ability to prepare on scene messages to be delivered up the chain of command.  Such component would help OSHA stay at a high level and avoid detailed requirements. 
       Avoid specifying technologies, processes, types of messages, and content. 
* OSHA question:  Are roadway struck-by fatalities a big problem in the emergency response community?  To what extent are emergency responders following the marking, blocking, and signage training provided by the national highway administration? 
       Accidents are happening even though responders follow all procedures to prevent such accidents. 
       Departments could establish SOPs using the Manual on Uniform Traffic Control Devices (MUTCD) or any other source of information that can prevent fatalities and injuries from roadway accidents. 
       A key would be to build relationships with law enforcement and follow the standards, policies, and SOPs already established. 
       Blocking apparatus may be a limited resource in some departments, and could become a burden for smaller departments. 
* OSHA question:  OSHA is considering wildland, do participants have any experience with wildland?  Any opinions about interface issues?
       If wildland is to be considered, there are many other parameters to contemplate.  To become wildland firefighters there are specific guidelines to follow. 
       Wild fires are more frequent and are happening in unexpected areas sometimes even shifting to urban areas.  This emerging issue should be integrated into the discussion as the standard is developed. 
       NFPA recently completed a wildland firefighter respirator standard. 
 Tribal firefighters provide great help with wildland fires.  Would tribal stakeholders be able to participate in OSHA's standard development process?  Would they be protected?
       OSHA response:  Generally, OSHA does not have authority and jurisdiction over tribal lands.  A number of factors including the tribe itself, the type of treaty, whether they have their own fire or emergency services department, or having a memorandum of understanding (MOU) between a tribal land and a governmental entity may affect how tribal emergency responders could be protected.  Nonetheless, allowing tribal stakeholders to participate would be valuable. 
       OSHA comment:  As part of the rulemaking process, an executive order requires OSHA to do outreach to tribal councils to give them the opportunity to provide feedback. 
OSHA opened the discussion to observers:
* Wildland firefighting should be kept on the agenda. 
* Small departments would find it cumbersome to comply with the standard if it becomes too stringent and detailed. There needs to be consideration with those that have a very limited budget. 
* OSHA comment:  OSHA is already very sensitive to that issue.  The Small Business Regulatory Enforcement Fairness Act (SBREFA) is part of the rule making process that provides a voice in the development of new regulations.  Under the SBREFA process the financial impact to small businesses is studied and alternatives are considered to make sure protection is achieved while minimizing burdens. 
Closing Remarks
OSHA representatives thanked the stakeholders for their participation and informed them that the meeting report will be publicly available in the docket.  Mr. Perry acknowledged the productivity of the meeting, and thanked everyone for their participation. 


                              *     *     *     *
                                       

Meeting Agenda
Occupational Safety and Health Administration Stakeholder Meeting Emergency Response and Preparedness
                                       
                        July 30-31, 2014
Washington, DC
Thank you for participating in OSHA's stakeholder meeting. Enclosed is the information you will need to help prepare for the meeting, including a brief background of the Agency's emergency response & preparedness rulemaking efforts. Although prepared remarks will not be accommodated, OSHA encourages all participants to formulate thoughts in advance regarding the four items that will be discussed during the meeting. The discussion will be informal and led by a facilitator. The meeting will be recorded for the sole purpose of preparing a summary report. This report will list the participants and their affiliations, but will not attribute specific remarks to any individual person.
                                Meeting Agenda

            9:00 Opening Remarks 
            9:10 Introductions 
            9:20 Administrative Details and Ground Rules 
            9:30 Discussion Item 1: Scope  -  Emergency Phases
            10:45 Morning Break
            11:00 Discussion Item 2: Scope  -  Incident Scenarios
            12:00 Lunch Break 
            1:00 Discussion Item 3: Emergency Categorization
            2:00 Afternoon Break
            2:15 Discussion Item 4: Flexibility
            3:30 Closing Remarks
            4:00 Meeting Conclusion 

  *** Please plan to arrive before 8:30 in order to pass through security ***


                                  Background
On September 11, 2007, OSHA published a 41-question Request for Information and received 85 responses covering the scope of emergency response operations, personal protective clothing and equipment, training and qualifications, medical evaluation and health monitoring, safety, and economic impacts related to potential regulatory action. In 2010, Emergency Response and Preparedness was removed from the regulatory agenda due to resource constraints. However, emergency response workers continue to face considerable occupational health and safety hazards. 
OSHA expects the focus of any regulatory action to be on emergency workers such as firefighters, emergency medical workers, rescue technicians, and HAZMAT technicians. However, allied workers such as law enforcement officers, security officers, and emergency management specialists are sometimes exposed to the same hazards during emergency incidents. OSHA does not intend to regulate law enforcement or security work related to criminal activities or crime prevention.
Current OSHA standards are out-of-date, conflict with industry consensus standards and standards adopted by other federal agencies (e.g., DHS/FEMA), and do not address the full range of hazards facing emergency responders; nor do they reflect changes in protective equipment performance or safety and health practices. While the Agency has historically been concerned primarily with industrial fire brigades, recent events (e.g., hurricanes, wildfire outbreaks, and other disaster response efforts) and changes in the federal government's approach to emergency response & preparedness may warrant updating the OSHA's standards.
OSHA must consider the use of consensus standards in its rulemaking. Options include incorporation by reference, integration of provisions, and compliance alternatives. The National Fire Protection Association's primary standard on this topic is NFPA 1500, Standard on Fire Department Occupational Safety and Health Program. The 2013 edition of NFPA1500 contains mandatory references 47 to other secondary NFPA standards. Secondary standards include 1000-series professional qualifications, 1500-series safety & health programs, 1800-series PPE, and 1900-series apparatus & equipment.

            Emergency Response and Preparedness Standard Framework
For purposes of discussion, the following is a conceptual outline of elements that a comprehensive OSHA Emergency Response & Preparedness standard may contain. A program standard such as this could be implemented by any type of organization (fire department, industrial fire brigade, emergency medical provider, etc.) of any size by first determining the range and level of services they intend to provide. These service types would then govern the remaining elements of the program. Some elements of the framework may be best suited for a non-mandatory appendix.
   
   Employer Establishment of Emergency Services to Provide
        oo          Range of services: firefighting (structural, wildland, aircraft, marine, other), EMS, HAZMAT, technical rescue, water rescue, disaster management, etc.
        oo          Level of service (incipient / exterior / interior)
   
   Emergency Response & Preparedness Program
        oo          Safety & health program   ●   Program administration   ●   Employee participation
        oo          NIMS compatibility   ●   Coordination with others (law enforcement, skilled support, etc.)
        oo          Standard emergency operating procedures
        oo          Safety at responder's facilities (stations, training academies, etc.)
        oo          Program evaluation
   
   Personnel Preparedness
      oo Physical fitness & routine medical surveillance
      oo Behavioral health, wellness, & atypically stressful event protocol
      oo Training, professional qualification, professional development, & proficiency
   
   Equipment Preparedness
   oo          Protective clothing   ●   Work uniforms   ●   Vehicle safety      
   oo          Protective equipment (respiratory, infection control, hearing, eye, PASS, ropes, etc.)
   oo          Tools and other equipment (hose, ladders, rescue tools, thermal imaging cameras, monitors, radios, etc.)
   
   Pre-incident Planning
      oo Developed by a competent person
      oo Identify hazards & Special Hazards
      oo Resources needed (water supply, mutual aid, etc.)
      oo On-site emergency action plan?
      oo Exposures and evacuation zone
   
   Emergency Operations 
      oo Incident management   ●   Communications
      oo Incident safety   ●   Traffic control   ●   Accountability   ●   Rapid intervention
      oo Medical monitoring   ●   Rehabilitation
   
   Post-incident Analysis
      oo Evaluate adequacy and accuracy of pre-incident plan
      oo Lessons learned


Note: A proposed standard could incorporate and/or replace related current OSHA standards such as the fire brigade standard, the interior firefighting provisions in the respiratory standard (including the "Two In  -  Two Out" rule), and the emergency response portion of the HAZWOPER standard. 
                           Meeting Discussion Items
Item 1: Scope  -  Emergency Phases. Discuss the pros and cons of an Emergency Response & Preparedness standard concentrating on preparing for emergencies such as pre-incident planning and training versus comprehensively covering all phases of emergency response, including emergency operations. OSHA understands that the comprehensive option would need to account for the varied and fluctuating nature of emergency incidents that call for dynamic risk assessments.
Item 2: Scope  -  Incident Scenarios. Discuss the pros and cons of an OSHA Emergency Response & Preparedness standard comprehensively covering all facets of emergency response & preparedness versus concentrating on scenarios known to cause most line-of-duty deaths (LODDs) and injuries. Possible scenarios include sudden cardiac events, vehicle related events, and interior offensive operations that are conducted when defensive operations are warranted. Consider the following for the discussion:
   * The 2012 FEMA firefighter fatality report  indicates that 55% of LODDs involve stress/overexertion and 22% involve vehicle collisions
   * The 2012 NFPA firefighter fatality report indicates that 42% of LODDs involve sudden cardiac death (27 of 64) and 31% are vehicle-related (20 of 64)
   * The offensive vs. defensive attack issue is a common theme in fire service publications
   * The attachment showing NIOSH firefighter fatality reports that cite pre-incident planning
   * The attachment showing NFPA & FEMA overviews of 2012 firefighter injuries
Item 3: Emergency Categorization. NFPA 600 (industrial fire brigades) contains different provisions for defensive exterior and offensive interior operations, but NFPA 1710 and 1720 (fire department organization and deployment) contain no such categorization. Discuss the pros and cons of an OSHA Emergency Response & Preparedness standard categorizing defensive and offensive separately for all fire service organizations performing structural firefighting. Such an approach may be warranted because, unless an immediate threat to life exists, working incident operations are effectively defensive until adequate resources arrive to transition to offensive. Where fire service resources are spread out, the defensive phase may be lengthy.
Item 4: Flexibility. Discuss how an OSHA Emergency Response & Preparedness standard could build in the flexibility to cover organizations of all sizes and complexity. Discuss additional considerations and flexibility that may need to be built in for state plan states that cover municipal firefighters, including volunteers in some cases. 

Select NIOSH Firefighter Fatality Investigation Reports in which pre-incident planning was listed as an issue
                                    NIOSH #
                                    Killed
                                    Injured
                   Pre-incident planning deficiencies cited
F2011-30
1
1
Unaware of structural deficiencies
F2011-22
2
1
Silo firefighting tactics
F2011-20
1
0
Building information
F2011-14
1
0
Building information
F2011-05
1
several
Building information
F2010-38
2
0
Building and occupancy information
F2010-30
0
7
HAZMAT info (combustible metals) & firefighting tactics
F2010-16
1
0
Building and contents  information
F2010-14
1
0
Silo firefighting tactics
F2009-31
1
8
Building information, HAZMAT information (combustible metals), & firefighting tactics
F2009-21
0
1
Building information (lightweight construction)
F2008-37
1
0
Occupancy information
F2008-07
2
1
Building and contents  information
F2008-03
0
9
Building information
F2007-37
2
0
Building information (demolition, standpipes)
F2007-18
9
0
Building and contents  information
F2007-07
1
0
Building information (lightweight construction)
F2007-02
1
0
Occupancy information
F2007-01
1
1
Building information
F2006-27
2
0
Building information
F2006-26
1
1
Building information (lightweight construction)
F2006-24
1
0
Building information (lightweight construction)
F2006-07
2
0
Building information
F2005-34
1
0
Building information (manlift in silo)
F2005-09
1
0
Building and occupancy information
F2005-03
2
4
Building information (renovations)
F2004-17
2
29
Building information (structural stability)
F2004-10
1
0
Building information
F2004-04
1
0
Building information
F2003-32
2
8
Building information(oxygen-limiting silo) & firefighting tactics
F2003-18
2
0
Building information (lightweight construction)
F2003-03
1
0
HAZMAT info (Compressed nitrous oxide)
F2002-50
3
0
Building and contents  information
F2002-44
1
2
Building and contents  information
F2002-06
2
1
Building information (lightweight construction)
F2001-23
3
0
Building and contents  information
F2001-13
1
1
Building information
F2001-03
0
3
Building information (lightweight construction)
F2000-13
2
0
Building information (lightweight construction)
99-F47
6
0
Building and occupancy information

                                       
                                       

                           2012 Firefighter Injuries
Overview from NFPA report

 69,400 firefighter injuries occurred in the line of duty in 2012, a slight decrease of 1.0%. 
 In addition to injuries, there were 8,150 exposures to infectious diseases, and 19,200 exposures to hazardous conditions. 
 31,490 or 45.4% of all firefighter injuries occurred during fireground operations. An estimated 13,820 occurred during other on duty activities, 4,190 while responding/returning from an incident, 7,140 during training activities, and 12,760 occurred at non-fire emergency incidents. 
 The Northeast reported a higher number of fireground injuries per 100 fires than other regions of the country. 
 The major types of injuries received during fireground operations were: strain, sprain, muscular pain (55.2%); wound, cut, bleeding, bruise (12.2%); thermal stress (5.8%) burns (5.7%). Strains, sprains, and muscular pain accounted for 58.5% of all non-fireground injuries. 
 The leading causes of fireground injuries were overexertion, strain (27.5%) and fall, slip, jump (23.2%).

Overview from FEMA report
 An estimated 81,070 firefighter injuries occur annually in the United States. 
 49 percent of firefighter injuries occur on the fireground and 6 percent occur while responding to or returning from a fire incident. 
 Overexertion/strain is the leading cause of fire-related firefighter injuries at 25 percent. 
 38 percent of all fire-related firefighter injuries result in lost work time. 
 The majority of fire-related firefighter injuries (87 percent) occur in structure fires. 
 On average, structure fires have more injuries per fire than nonstructure fires. 
 Firefighter injury fires are more prevalent in July (10 percent) and peak between the hours of 2 and 5 p.m. 
 



Participant Lists
   Emergency Response and Preparedness Stakeholder Meeting
Participant Lists

                           Wednesday, July 30, 2014
Last Name
First Name
Representing Organization 
Binder
David
Philadelphia LEPC, TRANSCAER, Tanner Ind.
Brunacini
John
Blue Card Command
Clifford
Brian
Federal Bureau of Investigation - Technical Hazards Response Unit
Delaney
Lisa
NIOSH
Duggan
Martha
National Rural Electric Cooperative Association
Ellis
Daniel
Chicago Office of Emergency Management and Communication
Fargo
Cristine
International Safety Equipment Association
Flint
William
Center for Campus Fire Safety
Gast
Larry
Arizona Division of Occupational Safety and Health
Groszewski
Robert
Gary Fire Department (retired)
Healy
Heather
Association of Flight Attendants -CWA, AFL-CIO
Hughes
Chip
HHS NIEHS 
Johnson
William 
MA Statewide Towing Association
Keiss
Alfred
Highland Park Fire Company
Kistner
Daniel
Texas Fire Chiefs Association
Maday
Mark
Union Pacific Railroad
Martineau
Cynthia
Towing and Recovery Association of America
Miller
Richard
International Association of Fire Chiefs
O'Connor
Kevin 
International Association of Fire Fighters
Parker
David
Industrial Commission of Arizona
Ramsay
James
American Society of Safety Engineers
Rice
Warren
VA Department of Labor and Industry
Taylor
Bob
PRB Coal Users Group
Tobia
Matthew
International Association of Fire Chiefs Safety, Health and Survival Section Chair
Trahan
Chris
Building and Construction Trades Department, AFL-CIO



                           Thursday, July 31, 2014 
                                       
Last Name
First Name
Representing Organization
Booth
Donald
International Union of Operating Engineers NTF
Breen
James
Roco Rescue, Inc.
Brody
Charlotte
BlueGreen Alliance 
Brown
Diane
AFSCME
Clapp
Glenn
High Point Fire Department
Colton
Craig
3M Personal Safety Division
Finger
David
National Volunteer Fire Council
Flanagan
Michael
MA Department of Labor Standards
Goldfarb
Zachary
East Meadow Fire Department
Harris
Dr. Scott
UL Workplace Health and Safety
Jodhpurkar
Jeetendra
American Gas Association
Jordan
Thomas
Virginia Department of Emergency Management
Monier
Jerry
LSU National Center for Biomedical Research and Training
Morawetz
John
International Chemical Workers Union Council
Morrison
Patrick
International Association of Fire Fighters
Pepper
Stephen
Phillips 66 
Robinson
Kathy
National Association of State EMS Officials
Sander
Russell
Texas Fire Chiefs Association
Siarnicki
Ronald
National Fallen Firefighters Foundation
Teel
Lisa
Campus Safety Health and Environmental Management Association
Watkins
Blake 
HES-Emergency Management
Weinstock
Deborah
NIEHS Worker Education and Training Program
Willette
Kenneth
National Fire Protection Association
Woulfe
John
International Association of Fire Chiefs
                                       



Standards Referenced During Meetings
Code of Federal Regulations (CFR)
Occupational Safety and Health Administration
29 CFR 1910, Occupational Safety and Health Standards
   29 CFR 1910.38, Emergency Action Plans
   29 CFR 1910.120, Hazardous Waste Operations and Emergency Response
   29 CFR 1910.120(q), Emergency Response Program to Hazardous Substance Releases
   29 CFR 1910.134, Respiratory Protection
   29 CFR 1910.156, Fire Brigades
29 CFR 1926, Safety and Health Regulations for Construction
Department of Transportation
14 CFR 243, Passenger Manifest Information
National Fire Protection Association
NFPA 600, Standard on Industrial Fire Brigades
NFPA 1001, Standard for Fire Fighter Professional Qualifications
NFPA 1500, Standard on Fire Department Occupational Safety and Health Program
NFPA 1582, Standard on Comprehensive Occupational Medical Program for Fire Departments
NFPA 1710, Standard for the Organization and Deployment of Fire Suppression Operations, Emergency Medical Operations, and Special Operations to the Public by Career Fire Departments
NFPA 1720, Standard for the Organization and Deployment of Fire Suppression Operations, Emergency Medical Operations, and Special Operations to the Public by Volunteer Fire Departments

