The meeting provided some very interesting viewpoints, some obvious to all and others presenting new paths to developing a worthwhile standard to protect emergency responders.  

First, I would like to say that I believe that knowing how a thought process develops is important to the understanding of why a conclusion has been reached.  Therefore, I would like provide you with the foundation of how or what shaped me in developing my viewpoint of safety in the fire service. 

I have been in the volunteer system for over 42 years with two different departments holding most officer positions up through deputy chief, and company president of both of them.  I have been a Pennsylvania State fire instructor for 35 years and currently employed part time with the Montgomery County (PA) Fire Academy as a subject matter specialist.  I served for a while on the Pennsylvania State Fire Commissioner's Fire Service Certification Advisory Committee.  In 1997 I retired from the Federal fire service as a Chief Officer from a Naval Air research facility where we provided structural, hazmat, ems, and airfield crash fire rescue protection.

 A Certified Fire Protection Specialist since 1976, as well as, a paramedic since 1979.  I obtained a graduate degree from St. Joseph's University in Public Safety in 1984 and a graduate degree from Temple University in Environmental Health (industrial hygiene) in 1996, along with a Post-Graduate Certificate from St. Joseph's in Environmental Protection.  Seven years with the Marine Corps of which four of them with aircraft crash rescue.

The current volunteer company I am with has evolved into a combination department with career firefighters working Monday through Friday and employing members to cover the weekends.  I have been a weekend employee for nearly 33 years.  This causes a crossover from volunteer status to a corporation employee covered by OSHA.  As you know, Pennsylvania comes under Federal plan protection of employees.

I have been an OSHA 500 and 501 authorized instructor for over twenty years and the company I am currently employed with is a partner with the OSHA Region III MidAtlantic OTI Education Center through a safety council membership.  I am currently a Principle Member of the NFPA 350 Confined Space Safety Technical Committee.    

To the meeting, as it progressed I was pleased to hear the many opinions, most of which confirmed my belief in what I believe to be necessary to protect responders.  I would like to provide you with this based on the discussion item list provided at the meeting.  I unfortunately cannot adequately address law enforcement due to inexperience of their specific management methods, but as a platform I believe every pyramid has a similar base.

Item 1:  I believe that developing a comprehensive document is essential.  There were many references to euphemisms describing fire service practices bring to mind one, that "the traditions of the fire service are the things we do long after we forgot why".  This is true with many emergency response organizations which have been in place for many years with little change in how they do business.  The OSH Act presented an opportunity for companies to re-examine themselves in light of what they do and how that adversely impacts their workers.  I see no difference in attempting to provide emergency services with a document providing them with direction on how to become a better structured organization.  Requiring them to address universally accepted elements of management practice allows them to analyze their work environment for deficiencies.  This analysis will most likely identify new areas previously ignored.  However, the analysis will allow a structured approach to insure their membership a broader safety umbrella.

Item 2:  In harmony with my position in Item 1, I believe a comprehensive approach is essential.  To limit the scope by addressing only those which appear on a national list would be limiting. First, it limits opportunity for organizations to address broader issues which may cause problems because they have failed to consider unknowns.  Secondly, and most importantly, by limiting what an organization should only consider would give the appearance that nothing else is considered important.  This misdirection presents a serious opportunity for disaster.  Essentially, a wilful practice of ignoring unsafe practices because "it will never happen here". 

A program developed to emphasize areas of known high frequency would also allow low frequency incidents recognition.

Item 3:  The skills and knowledge necessary for qualifying firefighters are essentially all the same.  With the evolution of national standards, performance levels covering a broad range of response requirements and are well established, and continually evolving as change defines what is needed.  The short-comings involve failing to equate what tasks are being required with a formalized management program defining what an organization's expectations are and qualified managers.  Outlining and developing the management skill qualifications should be an important consideration alongside the practices an organization recognizes as a program element.

Item 4:  The National Incident Management System is an excellent format to provide guidance for all types of organizations and should be mirrored in any document formed.  When developing the evaluation process found in Item 1 each organization can be provided with direction in how they fit in to an overall picture.  

The most unfortunate aspect of this effort is the failure of what you are attempting to provide coverage for only impacts half of the States.  Federal plan coverage States are at risk of continued injuries and deaths because they are not impacted in such a good program.  Something needs to be done to extend the coverage.  With hazardous materials being enforced through EPA in the Federal plan States oversight a similar extension should be considered.  Perhaps expanding 1919.120(q) with the elements of whatever may be developed in this effort to include organizations who must meet (q) having to follow the same guidelines would permit the Federal plan states to expand their coverage.  Also, with the enormous amount of Federal money being channeled to emergency service entitlement consideration should include adherence to such a program.  I mentioned above my previous membership on the Pennsylvania State Fire Commissioner's Fire Service Advisory Committee.  Twenty years ago we were dealing with how to encourage fire companies to get their personnel to obtain demonstrated skill certification qualification instead of just an attendance certificate for sitting in a training session.  A suggestion was to develop a partnership with insurance providers to equate coverage to departments commensurate to certification of membership.  This not only encourages developed skill performance but more qualified responders reducing the likelihood of mistakes when compared to those less trained/skilled.

In conclusion, the environment we are in today can only survive if we are prepared for it regardless of the complexity or scope of impact.  A number of comments reflected on the possibility of the extinction of some providers.  While true, the need for service coverage within the vacuum of an organization's demise will still exist only to be enveloped by the evolution of another organization.  Growth is good for survival.  That growth can is either internal or external.  If an organization will not change as a result of the evolution of our services it will eventually result in becoming a hazard to its members.  I see this in the NIOSH reports and after action discoveries.

With the significant importance of this topic area may I also suggest consideration of forming and advisory committee to support its development, as well as, continued success as it takes effect, hopefully, and adjusts to our changing environment.

Thank you for the consideration of this important safety document and allowing me to participate at this meeting.  I hope I can be of further assistance as this moves forward.

                                    
                                    Alfred W. Keiss
                                    53 Bridle Way
                                    Newtown Square, PA 19073
