OSHA’s 29 CFR 1910.120 is the Hazardous Waste, Operations, and Emergency Response (HAZWOPER) regulation. The “CFR” stands for Code of Federal Regulations. The “Code” means this regulation is law. Unfortunately, laws are typically written in response to an undesired behavior or event. Laws, therefore, are generally reactive by their nature. In states where Federal OSHA does not have jurisdiction, the state OSHA office must adopt regulations similar to 1910.120 and Environmental Protection Agency (EPA) regulations, which are often written similarly, still apply. What happens when you don’t follow an OSHA regulation? At a minimum, your organization will be required to correct any deficiencies discovered during an OSHA investigation. Additionally, OSHA can levy hefty fines for life safety deficiencies or issues previously identified that are not remedied.
So, where does the National Fire Protection Association (NFPA) fall into all of this? NFPA assembles fire service and industry leaders to write standards based on the way we do things. These standards are meant to be primarily proactive. I have heard firefighters criticize NFPA and describe the standard that regulates how many paper towels they can use during a meal. Although no such standard exists, there are plenty of other standards that have the same focus as OSHA, which is worker and public safety. In fact, because of NFPA, we do not have to worry about whether a sprinkler system or fire extinguisher will function. Building and fire codes require that both of these are designed and constructed according to NFPA standards.
NFPA does not have an enforcement arm. NFPA does not conduct an inspection in your fire department to insure that you are testing your apparatus pumps and fire hose according to their standards. NFPA has no ability to require deficiency corrections or levy fines on your department. Although there is no such thing as the NFPA police, they do write national consensus standards. These, by definition, are standards, on which fire service and industry leaders across the nation have come to a consensus, on which we should be basing behaviors. Whether it is the construction of personal protective equipment, testing of self-contained breathing apparatus prior to sale, or the recommended training for an officer, NFPA serves and protects firefighters. So if a firefighter is injured in your department, the NFPA police will not come and arrest the Incident Commander that was in charge of that incident. However, you can bet a paycheck that the national consensus standards that NFPA publishes will be present in the courtroom should any civil or criminal proceedings follow the incident.
Ask the fire investigators in your department and they will tell you that NFPA 921 is a staple among defense attorneys at arson trials. Not only do NFPA standards set a baseline from which we should all be operating, but they are also constantly revised, which is an essential part of being proactive in the fire service. This insures that the standards keep up with changes in staffing patterns, operational changes, and most importantly, technology.
One such NFPA standard is NFPA 1801. It is the Standard of Thermal Imagers for the Fire Service. While thermal imaging cameras (TICs) were once a luxury, they are becoming more and more commonplace among departments everywhere. However, they are still a tool that provides information to firefighters and that information must be interpreted properly. Proper interpretation requires training.
In the department for which I work, we began in the mid 1990s with one TIC — and it was just shy of the size and mass of one of Jupiter’s moons. Today, we have a complement of TICs and usually more than one is present at every structure fire — they’re also much smaller and lighter. There are two primary issues when considering TIC use. The first is training, and the second is standardization. Learning how to use a TIC takes some time. Not only do the functions of a TIC vary somewhat between manufacturer and model, but utilizing a TIC in a burning building also takes some familiarization. Standardization is also important because if we train our folks how our TIC displays information and what button controls which function and then we upgrade to a newer TIC that is designed differently, we will have to re-train our staff.
NFPA 1801 requires standardization among manufacturers. This is important because as we start to see more use of TICs, NFPA 1801 will help to insure that while you are on a mutual aid call at your neighboring department and a firefighter becomes lost or trapped, you don’t have to take an eight-hour class on their TIC in the front yard of the building prior to initiating rescue attempts. NFPA 1801 also requires symbols and icons to look the same and be located on the same place of the TIC screen. This again helps with standardization for firefighters across multiple jurisdictions. NFPA 1801 requires image quality testing both initially — “out of the box” — and post destructive testing. This means that after the Image Recognition Test, Vibration Test, Impact Acceleration Resistance Test, Corrosion Test, Viewing Surface Abrasion Test, Heat Resistance Test, Heat and Flame Test, Product Label Durability Test, Cable Pullout Test, Effective Temperature Range Test, Field of View measurement, Thermal Sensitivity Test, and Durability Test, the image that the TIC provides must be as clear as prior to the testing process. This, too, is paramount as once you begin using TICs, you depend upon them to provide you accurate information.
A few firefighters from the department in which I work once arrived at a single-family dwelling fire with entrapment in another jurisdiction. After donning their PPE and SCBA, they entered the building prior to the first-in engine arriving. Without the protection of a hose line, they searched for the elderly victim that was trapped in a back bedroom utilizing a TIC. The living room flashed over and subsequently the TIC “whited out” — the screen went completely white. When you’ve come to depend upon TICs, you certainly don’t want them becoming saturated at elevated temperatures in the midst of when you need them most. Despite the TICs “white out,” the victim was located and rescued. Again, training on using thermal imagers is as important as training on how to raise a ladder or operate a pump. Firefighters should be taught to use thermal imagers and interpret the information earlier rather than later in an effort to detect deteriorating conditions so that they can avoid being trapped in an untenable environment.
The 2013 version of NFPA 1801 has raised the bar among manufacturers and standardized the information. This will help to simplify training and help to reinforce the more frequent use of and safe application of thermal imagers. This is extremely important for a tool that we are using much more frequently than in the past. Future revisions of NFPA 1801 will continue to address standardization among thermal imaging, which is an ever-advancing technology.
Both NFPA and OSHA exist to provide for the safety of workers and the public. In an unforgiving occupation such as ours, these laws and standards are an essential part of our daily protection.
Be safe and do good.